EPSTEIN
page 6 / 13 . OCR, unverified
follows:
1. JANE DOE NO. 1 is a minor child, 17 years of age, who is under the joint control of her
parents and natural guardians, JANE DOE'S FATHER and JANE DOE'S MOTHER, who are
divorced.
2. JANE DOE NO. 1 will be 18 on May 13, 2008. See affidavit of JANE DOE'S MOTHER
(attached hereto as EXHIBIT "A'').
3. JANE DOE NO. 1 has been estranged from JANE DOE'S FATHER since Thanksgiving
Day, November 22, 2007. See Exhibit "A" (Affidavit of JANE DOE'S MOTHER).
Case 9:08-cv-80069-KAM Document 4 Entered on FLSD Docket 01/29/2008 Page 2 of 2
4. JANE DOE'S FATHER filed this lawsuit against Defendant Jeffrey Epstein without the
knowledge, consultation or consent of JANE DOE NO. 1. See Exhibit "A" (Affidavit of JANE
DOE'S MOTHER).
5. JANE DOE NO. 1 does not want this lawsuit to be prosecuted on her behalf by JANE
DOE'S FATHER. See Exhibit "A" (Affidavit of JANE DOE'S MOTHER).
6. Pursuant to Local Rule 7.1.A.3, counsel for Intervenor-Plaintiff JANE DOE'S
MOTHER, in a good faith attempt to resolve this dispute, made a reasonable effort to confer with
all parties who may be affected by this motion to stay. Counsel for Intervenor-Plaintiff JANE
DOE'S MOTHER conferred with Counsel for JANE DOE'S FATHER, who do not agree to the
Court entering a stay in this action.
WHEREFORE, Intervenor-Plaintiff, JANE DOE'S MOTHER, moves the Court to stay
these proceedings pending JANE DOE NO. 1 reaching the age of majority at which time she can
decide whether, and how, to continue prosecution of this action.
I HEREBY CERTIFY that a true and correct copy of the foregoing was filed electronically
on January 29th, 2008 with the Clerk of the Court through ECF, and that ECF will send an e-notice
of the electronic filing to the following: Jeffrey M. Herman, jherman@hermanlaw.com; Stuart S.
Mermelstein,
smerme 1 stein@hermanlaw.com;
Adam
D.
ahorowitz@henna.nl aw.com.
Respectfully submitted,
ls/Theodore J. Leopold, Esq.
THEODORE J. LEOPOLD, ESQ.
Florida Bar No. 705608
RICCI~LEOPOLD, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens FL 33410
Phone: 561-684-6500;
Fax: 561-515-2610
Email: tleopold@riccilaw.com
Page 2 of2
Horowitz,
==================== END OF Court Records__Doe v. Epstein, No. 908-cv-80069 (S.D. Fla. 2008)__004.txt ====================
==================== DOCUMENT: Court Records__Doe v. Epstein, No. 908-cv-80069 (S.D. Fla. 2008)__005-01.txt ====================
METADATA_SOURCE: Court RecordsDoe v. Epstein, No. 908-cv-80069 (S.D. Fla. 2008)
METADATA_FILENAME: 005-01.pdf
----------------------------------------
Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 1 of 7
EXHIBIT A
Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 2 of 7
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-80069 CIV-MARRA/JOHNSON
JANE DOE NO.1, by and through
JANE DOE's FATHER as parent and natural
guardian, and JANE DOE's FATHER, and
JANE DOE's STEPMOTHER, individually,
Plaintiffs,
JANE DOE'S MOTHER, individually and as parent
and natural guardian of JANE DOE NO. 1,
Intervenor-Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
I
------------------
INTERVENOR'S COMPLAINT
Intervenor-Plaintiff, JANE DOE's MOTHER, individually and as parent and natural
guardian of JANE DOE NO. 1, by and through the undersigned counsel, brings this Complaint
against Defendant JEFFREY EPSTEIN, and as grounds states as follows:
Parties, Jurisdiction and Venue
1. Jane Doe No. 1 is a citizen and resident of the State of Florida. She is a minor under the
age of 18 years.
2. Jane Doe's Mother brings this action individually and as parent and natural guardian of
Jane Doe No. 1. Jane Doe's Mother is a citizen and resident of the State of Georgia.
Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 3 of 7
3. 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 minor.
4. Defendant Jeffrey Epstein is a citizen and resident of the State ofNew York.
5. This is an action for damages in excess of Fifty Million ($50,000,000.00) Dollars.
Factual Allegations
6. 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.
7. 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