EPSTEIN
page 2 / 13 . OCR, unverified
bedroom. Ms. Kellen would then leave the girl alone in this room, whereupon Epstein would enter
wearing only a towel. He would then remove his towel, lay down naked on the massage table, and
direct the girl to remove her clothes. He then would perform one or more lewd, lascivious and
sexual acts, including masturbation and touching the girl's vagina with a vibrator.
14.
Consistent with the foregoing plan and scheme, Ms. Robson recruited Jane Doe to
give Epstein a massage for monetary compensation. Ms. Robson brought Jane to Epstein's mansion
in Palm Beach. Jane was introduced to Sarah Kellen, who led her up the flight of stairs to the room
with the massage table. She was alone in the room when Epstein arrived wearing only a towel. He
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Case 9:08-cv-80069-KAM Document 1 Entered on FLSD Docket 01/25/2008 Page 4 of 7
removed his towel, and laid down naked on the massage table. He demanded that Jane remove her
clothes. In shock, fear and trepidation, Jane complied, removing her clothes except for her
underwear. Epstein then sexually assaulted Jane.
15.
After Epstein had completed the assault, he left the room. Jane was then able to get
dressed, leave the room and go back down the stairs. She then met Ms. Robson again who brought
Jane home. Jane was paid $300 by Epstein. Ms. Robson was paid $200 by Epstein for bringing Jane
to him.
16.
As a result of this encounter with Epstein, the 14-year old Jane experienced
confusion, shame, humiliation, embarrassment and the assault sent her life into a downward spiral.
COUNTI
Sexual Assault
17.
Plaintiff Jane Doe by and through her Father, as parent and natural guardian, repeats
and realleges paragraphs 1 through 16 above.
18.
Epstein tortiously assaulted Jane Doe sexually in or about 2005.
19.
This sexual assault was in violation of Chapter 800 of the Florida Statutes, which
recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane.
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.
WHEREFORE, Plaintiff Jane Doe, by and through her Father, as parent and natural guardian,
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.
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Case 9:08-cv-80069-KAM Document 1 Entered on FLSD Docket 01/25/2008 Page 5 of 7
COUNT II
Intentional Infliction of Emotional Distress
21.
Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane
Doe's Father and Jane Doe's Stepmother, individually, repeat and reallege paragraphs 1 through 16
above.
22.
Epstein's conduct was intentional or reckless.
23.
Epstein's conduct was outrageous, going beyond all bounds of decency.
24.
Epstein's conduct caused severe emotional distress not only to Jane Doe, but also to
her parents, Jane Doe's Father and Jane Doe's Stepmother. Epstein knew or had reason to know that
his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe's
parents.
25.
As a direct and proximate result of Epstein's intentional or reckless conduct, Jane
Doe, Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe
mental anguish and pain.
WHEREFORE, Plaintiffs Jane Doe by and through her Father, as parent and natural
guardian, Jane Doe's Father and Jane Doe's Stepmother demand 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
Loss of Parental Consortium
26.
Plaintiff Jane Doe's Father repeats and realleges paragraphs 1 through 16 above.
27.
Epstein's tortious conduct is the direct and proximate cause of damages to Jane Doe's
Father, consisting of parental loss of comfort, companionship and society and healthcare costs
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Case 9:08-cv-80069-KAM Document 1 Entered on FLSD Docket 01/25/2008 Page 6 of 7
associated with the treatment of Jane.
28.
Jane Doe's Father experienced and will continue to experience great mental anguish,
pain and suffering from the time that Defendant's tortious conduct occurred.
WHEREFORE, Plaintiff Jane Doe's Father demands judgment for loss of consortium
damages, costs and such other and further relief as this Court deems proper.
JURY TRIAL DEMAND
Plaintiffs demand a jury trial in this action.
Dated: January Ji, 2008
HERMAN & MERMELSTEIN, P.A.
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Respectfully submitted,
HERMAN & MERMELSTEIN, P.A.
Attorneys for Plaintiffs
18205 Biscayne Blvd.
Suite 2218
Miami, Florida 33160
Tel: 305-931-2200
Fax:
By: __
"'"'-----~----
30~-931-0877
fofM.Herman
j erman@hermanlaw.com