EPSTEIN
page 1 / 13 . OCR, unverified
Court Records Doe v. Epstein, No. 908-cv
==================== DOCUMENT: Court Records__Doe v. Epstein, No. 908-cv-80069 (S.D. Fla. 2008)__001.txt ====================
METADATA_SOURCE: Court RecordsDoe v. Epstein, No. 908-cv-80069 (S.D. Fla. 2008)
METADATA_FILENAME: 001.pdf
----------------------------------------
Case 9:08-cv-80069-KAM Document 1 Entered on FLSD Docket 01/25/2008 Page 1 of 7
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.:
JANE DOE NO. 1, by and through
08-80069
JANE DOE's FATHER as parent and natural
guardian, and JANE DOE's FATHER, and
JANE DOE's STEPMOTHER, individually,
Plaintiffs,
vs.
JEFFREY EPSTEIN,
Defendant.
I
----------------
COMPLAINT
CIV-MARRA
MAGISTRAlE JIJ.D.G&
JOHNSON
JAN 2 4 2008
CLARENCE MADDOX
CLERK u.s. o~T-i.fu•o
S,D. OF FLA, •
•
'
Plaintiff, Jane Doe No. 1 ("Jane" or "Jane Doe"), by and through Jane Doe's Father as parent
and natural guardian, and Jane Doe's Father and Jane Doe's Stepmother, individually, bring this
Complaint against Jeffrey Epstein, as follows:
Parties, Jurisdiction and Venue
1.
Jane Doe is a citizen and resident of the State of Florida. She is a minor under the
age of 18 years.
2.
Jane Doe's Father brings this action individually and as parent and natural guardian of
Jane Doe. Jane Doe's Father is a citizen and resident of the State of Florida.
3.
Jane Doe's Stepmother brings this action individually. Jane Doe's Stepmother is a
citizen and resident of the State of Florida.
4.
This Complaint is brought under fictitious names to protect the identity of the Minor
Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
HERMAN & MERMELSTEIN, P. A.
www.hermanlaw.com
- 1 -
Case 9:08-cv-80069-KAM Document 1 Entered on FLSD Docket 01/25/2008 Page 2 of 7
mmor.
5.
Defendant Jeffrey Epstein is a citizen and resident of the State ofNew York.
6.
This is an action for damages in excess of $50 million.
7.
This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
U.S.C. § 1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
and (ii) is between citizens of different states.
8.
This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial
part of the events or omissions giving rise to the claim occurred in this District.
Factual Allegations
9.
At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52
years old. Epstein is a financier and money manager with a secret clientele limited exclusively to
billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his
principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach,
FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
10.
Upon information and belief, Epstein has a sexual preference and obsession for
underage minor girls. He engaged in a plan and scheme in which he gained access to primarily
economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
them money. In or about 2005, Jane Doe, then 14 years old, fell into Epstein's trap and became one
of his victims.
11.
Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted
girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas.
12.
An integral player in Epstein's Florida scheme was Haley Robson, a Palm Beach
HERMAN & MERMELSTEIN, P. A.
www.hermanlaw.com
- 2 -
Case 9:08-cv-80069-KAM Document 1 Entered on FLSD Docket 01/25/2008 Page 3 of 7
Community College student from Loxahatchee, Florida. She recruited girls ostensibly to give a
wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's
plan, Ms. Robson would be contacted when Epstein was planning to be at his Palm Beach residence
or soon after he had arrived there. Epstein or someone on his behalf directed Ms. Robson to bring
one or more underage girls to the residence. Ms. Robson, upon information and belief, generally
sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas who
would be enticed by the money being offered - generally $200 to $300 per "massage" session - and
who were perceived as less likely to complain to authorities or have credibility if allegations of
improper conduct were made. This was an important element of Epstein's plan.
13.
Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at
Epstein's mansion, Mr. Robson would introduce each victim to Sarah Kellen, Epstein's assistant,
who gathered the girl's personal information, including her name and telephone number. Ms. Kellen
would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition
to other furnishings. There were photographs of nude women lining the stairway hall and in the