EPSTEIN
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Jane was contacted by this girl by telephone. Jane was then picked up and brought to Epstein's
mansion in Palm Beach. Once there, she was led up the flight of stairs to the room with the massage
table. Epstein came into the room and directed Jane to remove her clothes and give him a massage.
Jane was frightened and felt trapped. As directed by Epstein, Jane removed her clothes. Epstein
then during the massage touched Jane on her breasts and vagina, and he grabbed her hand and placed
it on his penis. Epstein masturbated himself during the massage. Epstein then left money for Jane.
14.
As a result of this encounter with Epstein, Jane experienced confusion, shame,
humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
MERMELSTEIN & HOROWITZ, P. A.
www.sexabuseattorney.com
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COUNTI
Sexual Assault and Battery
15.
Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
16.
Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane
Doe, creating a reasonable fear of imminent peril and sexual assault.
17.
Epstein intentionally inflicted harmful or offensive sexual contact on the person of
Jane Doe.
18.
Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts
were intentional, unlawful, offensive and harmful.
19.
Epstein's plan and scheme in which he committed such acts upon Jane Doe were done
willfully and maliciously.
20.
As a direct and proximate result of Epstein's assault on Jane, she has suffered and will
continue to suffer severe and permanent traumatic injuries, including mental, psychological and
emotional damages and loss of enjoyment of life.
WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this
Court deems just and proper.
COUNT II
Intentional Infliction of Emotional Distress
21.
Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
22.
Epstein's conduct was intentional or reckless.
23.
Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds
of decency.
MERMELSTEIN & HOROWITZ, P. A.
www. sexabuseattorney. com
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24.
Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted
in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health
to be significantly impaired.
25.
Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
reason to know that his intentional and outrageous conduct would cause emotional distress and
damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing
severe emotional distress to Jane Doe.
26.
As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe
has suffered and will continue to suffer severe mental anguish and pain, psychological and emotional
injuries and los of enjoyment oflife ..
WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
Court deems just and proper.
COUNTIII
Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422
27.
Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
28.
Epstein used a facility or means of interstate commerce to knowingly persuade,
induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or
sexual activity for which any person can be charged with a criminal offense.
29.
On June 30, 2008, Epstein entered a plea of guilty to violations of Florida§§ 796.07
and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-
00938 lAXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and
scheme as alleged herein.
MERMELSTEIN & HOROWITZ, P. A.
www.sexabuseattorney.com
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30.
As to Plaintiff Jane Doe, Epstein could have been charged with criminal violations of
Florida Statute §796.07(2) (including subsections (c), (d), (e), (f), (g), and (h) thereof), and other
criminal offenses including violations of Florida Statutes §§798.02 and 800.04 (including
subsections (5), (6) and (7) thereof).
31.
Epstein's acts and conduct are in violation of 18 U.S.C. §2422.
32.
As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal
injury, including mental, psychological and emotional damages.
33.
Plaintiff hired Mermelstein & Horowitz, P.A. (f/k/a Herman & Mermelstein, P.A.), in
this matter and agreed to pay them a reasonable attorneys' fee.