EPSTEIN
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Court Records Doe v. Epstein, No. 909-v-
==================== DOCUMENT: Court Records__Doe v. Epstein, No. 909-v-80469 (S.D. Fla. 2009)__001.txt ====================
METADATA_SOURCE: Court RecordsDoe v. Epstein, No. 909-v-80469 (S.D. Fla. 2009)
METADATA_FILENAME: 001.pdf
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Mar. 24, 2009
09-80469-Civ-RYSKAMP/VITUNAC
Case 9:09-cv-80469-KAM Document 1 Entered on FLSD Docket 03/25/2009 Page 1 of 5
JANE DOE II
Plaintiff,
vs.
JEFFREY EPSTEIN,
and SARAH KELLEN,
Defendants.
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
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CASE NO.:
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COMPLAINT
FILED by
RB
D.C.
ELECTRONIC
STEVEN M.LARIMORE
CLERK U.S. DIST. CT.
S. O. Of FLA.· MIAMI
1.
Plaintiff, JANE DOE 11, hereby sues JEFFREY EPSTEIN and SARAH
KELLEN, and states:
JURISDICTION AND VENUE
2.
This is an action for damages in excess of $75,000, exclusive of interests,
costs and attorney's fees.
3.
Venue is proper in this Court as all acts occurred in Palm Beach County and
all parties reside and/or do business herein.
PARTIES
4.
Ms. DOE II is a natural person residing in Palm Beach County, Florida. During
the events giving rise to this claim, she was a minor but has now reached majority. She files
this suit under a pseudonym to protect her privacy because the acts alleged occurred while
she was a minor.
SCANNED
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09-80469-Civ-RYSKAMP/VITUNAC
Case 9:09-cv-80469-KAM Document 1 Entered on FLSD Docket 03/25/2009 Page 2 of 5
5.
Defendant EPSTEIN is a natural person, who is an adult, and who resides
and/or does business in Palm Beach County, Florida, and who committed the acts alleged
within the jurisdiction of Palm Beach County, Florida, within the boundaries of the United
States District Court in and for the Southern District of Florida. Defendant KELLEN is a
natural person, who is an adult, believed to reside in the State of New York, but who
committed the acts alleged within the jurisdiction of Palm Beach County, Florida, within the
boundaries of the United States District Court in and for the Southern District of Florida.
6.
Defendant EPSTEIN is believed to now be incarcerated in the Palm Beach
County Jail for crimes committed that are related to and/or similar to the claims in this case.
FACTS
7.
Defendant EPSTEIN was, at all times relevant to this action, a part time
resident of Palm Beach County, Florida. All acts complained of herein occurred at his estate
residence in the Town of Palm Beach, Florida.
8.
Defendant EPSTEIN has a history of enticing young women, who are minors
(under 18 years of age), and soliciting them to engage in prostitution for his own sexual
gratification.
9.
Defendant EPSTEIN, in agreement with two (2) persons he employed for this
purpose, HALEY ROBSON and Defendant KELLEN, conspired with these other two, and
others, to solicit young women of the type Defendant EPSTEIN preferred, blonde, attractive
in appearance, and younger than 18 years of age, to provide sexual gratification for him by
engaging in acts of prostitution.
10.
Defendants EPSTEIN and KELLEN entered into a criminal conspiracy to
solicit young women for acts of prostitution, including the Plaintiff, here in Palm Beach
County.
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09-80469-Civ-RYSKAMP/VITUNAC
Case 9:09-cv-80469-KAM Document 1 Entered on FLSD Docket 03/25/2009 Page 3 of 5
11.
From about June, 2003 until on or about February, 2005, Defendants
EPSTEIN and KELLEN persuaded, induced, or enticed the Plaintiff to come to Defendant
EPSTEIN's home and provide Defendant EPSTEIN with "massages" which escalated into
sexual encounters between Defendant EPSTEIN and the Plaintiff designed to fulfill his
unnatural sexual desires for young women or even younger girls who were minors. These
acts included Defendant EPSTEIN's request that he wanted the encounter to be like a
"porn video." Defendant EPSTEIN would script lines for the Plaintiff to say, including calling
out his name and requesting that he perform a certain sexual act "harder,"while he touched
the Plaintiffs vagina with a vibrator or with his fingers; alternately, he would masturbate in
the presence of the Plaintiff after demanding her to disrobe and walk in front of him in
provocative sexual poses. Defendant EPSTEIN would pay the Plaintiff a fee of $200 on
each occasion after he ejaculated while masturbating in the presence of the Plaintiff.
12.
Defendant EPSTEIN touched Plaintiffs vagina, or penetrated Plaintiffs
vagina, using his fingers and/or a vibrator on multiple occasions, during the time that
Plaintiff was a minor, causing personal injury to her.
13.
In violation of 18 U.S.C. §2422(b),Defendants EPSTEIN and KELLEN
knowingly persuaded, induced, or enticed the Plaintiff to engage in acts of prostitution, when
the Plaintiff was under the age of 18, approximately on or about the following dates that
Plaintiff can document based on payments received: 6/16/03, 7/2/03, 4/9/04, 6/7/04,
7/30/04, 8/30/04, 10/9/04, 10/12/04, 10/30/04 and 11/9/04. In addition, Plaintiff believes that