Datasets:
title: DOJ Epstein Files, Data Set 9 (EFTA00175892)
source: DOJ Epstein Files, Data Set 9
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date: '2026-01-01'
category: DOJ Data Set
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CM/ECF - Live Database - flsd
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LRJ
U.S. District Court
Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80994-KAM
Jane Doe No. 6 v. Epstein
Assigned to: Judge Kenneth A. Marra
Cause: 28:1331 Federal Question
Date Filed: 09/10/2008
Jury Demand: Plaintiff
Nature of Suit: 710 Labor: Fair Standards
Jurisdiction: Federal Question
| Plaintiff |
| Jane Doe No. 6 |
| Adam D. Horowitz |
| Herman & Mermelstein, P.A. |
| 18205 Biscayne Blvd. |
| Suite 2218 |
| Miami , FL 33160 |
| Jeffrey Marc Herman |
| Herman & Mermelstein |
| 18205 Biscayne Boulevard |
| Suite 2218 |
| Miami, FL 33160 |
Fax: 931-0877
Email:
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Stuart S. Mermelstein
Herman & Mermelstein
18205 Biscayne Boulevard
Suite 2218
Miami, FL 33160
Fax: 931-0877
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?617389682623668-L_801_0-1
10/8/2008
EFTA00175892
CM/ECF - Live Database - flsd
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V.
Defendant
Jeffrey Epstein
represented by Robert Deweese Critton , Jr.
Burman Critton Luttier & Coleman
515 N Flagler Drive
Suite 400
West Palm Beach , FL 33401-2918
| Date Filed | # | Docket Text |
|---|---|---|
| 09/10/2008 | 1 | COMPLAINT against Jeffrey Epstein Filing fee $ 350.00. Receipt#: 544159, filed by Jane Doe No. 6.(mg) (Entered: 09/11/2008) |
| 09/10/2008 | 2 | Summons Issued as to Jeffrey Epstein. (mg) (Entered: 09/11/2008) |
| 09/15/2008 | 3 | NOTICE of Attorney Appearance by Robert Deweese Critton, Jr on behalf of Jeffrey Epstein (Critton, Robert) (Entered: 09/15/2008) |
| 10/03/2008 | 4 | SUMMONS (Affidavit) Returned Executed by Jane Doe No. 6. Jeffrey Epstein served on 9/23/2008, answer due 10/14/2008. (Herman, Jeffrey) (Entered: 10/03/2008) |
| 10/06/2008 | 5 | ORDER OF TRANSFER. Case reassigned to Judge Kenneth A. Marra for all further proceedings. Judge Daniel T. K. Hurley no longer assigned to case. Signed by Judge Daniel T. K. Hurley on 10-6/08. (gp) (Entered: 10/07/2008) |
| 10/08/2008 | 6 | CERTIFICATION AND ORDER OF TRANSFER TO MAGISTRATE JUDGE. Magistrate Judge James M. Hopkins no longer assigned as referral judge in case. Case transferred to Judge Marra's paired Magistrate Judge Linnea R. Johnson. Signed by Magistrate Judge James M. Hopkins on 10/8/08. (lw1) (Entered: 10/08/2008) |
| PACER Service Center | |||
| Transaction Receipt | |||
| 10/08/2008 17:41:02 | |||
| PACER Login: | du4480 | Client Code: | |
| Description: | Docket Report | Search Criteria: | 9:08-cv-80994-KAM |
| Billable Pages: | 1 | Cost: | 0.08 |
https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?617389682623668-L_801_0-1
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EFTA00175893
Case 9:08-cv-80094-KAM Document...1 Entered ... FLSD Docket 09/11,J08 Page 1 of 7
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
CASE NO.:
08-CV-80994-Hurley-Hopkins
JANE DOE NO. 6,
vs.
Plaintiff,
JEFFREY EPSTEIN,
FILED by VT D.C.
ELECTRONIC
Defendant.
SEPT. 10, 2008
```markdown
COMPLAINT
```markdown
STEVEN M. LARIMORE
CLERK U.S. DIST. CT.
S.D. OF FLA. MIAMI
Plaintiff, Jane Doe No. 6 (“Jane” or “Jane Doe”), brings this Complaint against Jeffrey Epstein, as follows:
Parties, Jurisdiction and Venue
Jane Doe No. 6 is a citizen and resident of the State of Florida, and is sui juris.
This Complaint is brought under a fictitious name to protect the identity of the Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a minor.
Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
This is an action for damages in excess of $50 million.
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.
Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because Plaintiff alleges a claim under the laws of the United States. This Court has supplemental
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jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein which form part of the same case or controversy.
- This Court has venue of this action pursuant to 28 U.S.C. §§1391(a) and 1391(b) as a substantial part of the events or omissions giving rise to the claim occurred in this District.
Factual Allegations
At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, approximately 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.
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 2004, Jane Doe, then approximately 13 years old, fell into Epstein’s trap and became one of his victims.
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.
Epstein’s scheme involved the use of young girls to recruit underage girls. These underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Epstein, upon information and belief, generally sought out economically disadvantaged underage girls from western Palm Beach County who would be enticed by the money
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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.
Epstein’s plan and scheme reflected a particular pattern and method. The underage victim would be brought or directed to Epstein’s mansion, where she would be led up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. The girl would then find herself alone in the room with Epstein, who would be wearing only a towel. He would then remove his towel and lie naked on the massage table, and direct the girl to remove her clothes. Epstein would then perform one or more lewd, lascivious and sexual acts, including masturbation.
Consistent with the foregoing plan and scheme, when Jane Doe was only 13 years old, she was recruited by another girl to give Epstein a massage for monetary compensation. Jane was 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. As directed by Epstein, Jane stripped to her underwear. Epstein then sexually assaulted Jane during the massage. In addition, Epstein masturbated during the massage. Epstein then paid Jane money.
As a result of this encounter with Epstein, Jane experienced confusion, shame, humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
COUNT I
Sexual Assault and Battery
Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane Doe, creating a reasonable fear of imminent peril and sexual assault.
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Epstein intentionally inflicted harmful or offensive sexual contact on the person of Jane Doe.
Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts were intentional, unlawful, offensive and harmful.
Epstein's plan and scheme in which he committed such acts upon Jane Doe were done willfully and maliciously.
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 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
Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
Epstein's conduct was intentional or reckless.
Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds of decency.
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.
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
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damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing severe emotional distress to Jane Doe.
- 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.
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.
COUNT III
Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422
Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
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.
Epstein's acts and conduct are in violation of 18 U.S.C. §2422.
As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal injury, including mental, psychological and emotional damages.
Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a reasonable attorneys' fee.
WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey Epstein for all damages available under 18 U.S.C. §2255(a), including without limitation, actual and compensatory damages, costs of suit, and attorneys’ fees, and such other and further relief as this Court deems just and proper.
HERMAN & MERMELSTEIN, P. A.
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JURY TRIAL DEMAND
Plaintiff demands a jury trial in this action on all claims so triable.
Dated: September 10, 2008
Respectfully submitted,
By: Jeffrey M. Herman (FL Bar No. 521647)
Stuart S. Mermelstein (FL Bar No. 947245)
Adam D. Horowitz (FL Bar No. 376980)
HERMAN & MERMELSTEIN, P.A.
Attorneys for Plaintiff
18205 Biscayne Blvd., Suite 2218
Miami, Florida 33160
Tel:
Fax:
HERMAN & MERMELSTEIN, P. A.
www.hermanlaw.com
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EFTA00175899
original
| I(a) PLAINTIFFS JANE DOE NO. 6, (b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF PALM BEACH COUNTY (EXCEPT IN U.S. PLAINTIFF CASES) | DEFENDANTS JEFFREY EPSTEIN COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT NEW YORK (IN U.S. PLAINTIFF CASES ONLY) |
| (c) ATTORNEYS(FIRM NAME, ADDRESS, AND TELEPHONE NUMBER) Herman & Mermelstein,P.A.,18205 Biscayne Blvd., Suite 2218,Miami, FL 33160, | ATTORNEYS(IF KNOWN) |
| II. BASIS OF JURISDICTION (PLACE AN X ONE BOX ONLY) | III. CITIZENSHIP OF PRINCIPAL PARTIES | PLACE AN X IN ONE BOX FOR AND ONE FOR DEFENDANT Incorporated of Principal Place of Business in This State Incorporated and Principal Place of Business in Another State Foreign Nation | PLAINTIFF | ||||
| (For Diversity Case Only) | PTF | DEF | PTF | DEF | |||
| □1. U.S. Government | X 3. Federal Question | Citizen of This State | □1 | □1 | □4 | □4 | |
| Plaintiff | (U.S. Government Not a Party) | Citizen of Another State | □2 | □2 | |||
| □2. U.S. Government | □4. Diversity | Citizen or Subject of a Foreign Country | □3 | □3 | □5 | □5 | |
| Defendant | (Indicate Citizenship of Parties in Item III) | ||||||
IV. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE. DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY.)
ACTION FOR SEXUAL ASSAULT UNDER 18 U.S.C. §2422 AND STATE LAW
IVa. 5 days estimated (for both sides) to try entire case
NATURE OF SUIT
(PLACE AN X IN ONE BOX ONLY)
A CONTRACT
| A CONTRACT | A TORTS | B FORFEITURE PENALTY | A BANKRUPTCY | A OTHER STATUS |
|---|---|---|---|---|
| □ 110 Insurance | PERSONAL INJURY | □ 810 Agriculture | □ 422 Appeal 28 USC 158 | □ 400 Status Reappointment |
| □ 120 Marine | □ 390 Airplane | □ 825 Drug Related Sequestration of Property 21 USC 811 | □ 423 Withdrawal 28 USC 157 | □ 401 Bank and Banking |
| □ 130 Apparel Instrument | □ 315 Apparel Product Liability | □ 825 Personal Injury Product Liability | □ A PROPERTY RIGHTS | □ 402 Banks and Banking |
| □ 100 Receiving Overtime & Equipment Liability | □ 300 Adhesive Label & Sticker | □ 825 Adhesive Label & Sticker | □ 825 Copyrights | □ 403 Residential and Institutional Organizations |
| □ 150 Recovery of Defiled Student Loans (Civilian) | □ 340 Marine Product Liability | □ 825 Military Ring | □ 825 Occupational Health Other | □ 404 Selective Service |
| □ 153 Recovery of Overtime & Equipment Liability | □ 350 Motor Vehicle Product Liability | □ 825 Other Personnel Property Management | □ 825 Trademark | □ 405 Commercial Compliance Exchange |
| □ 160 Stockholder's Sole | X 300 Other Personal Injury | □ 825 Property Management Product Liability | □ B SOCIAL SECURITY | □ 406 Agricultural Act |
| □ 190 Central Product Liability | □ 801 HLA (130ff) | □ 407 Reassessment and Institutional Organizations | ||
| A REAL PROPERTY | A CIVIL RIGHTS | A LABOR | □ 803 Bankruptcy (623) | □ 408 Patient |
| □ 216 Land Condensation | □ 441 Employment | X 710 Fish Later Standards Act | □ 804 OWNCNVN (465ff) | □ 409 Appeal of Five Determination of Legal Action |
| □ 220 Furniture B | □ 442 Employer Accommodations | X 710 Fishery Art Act | □ 804 SSD Tile XX | □ 410 Discrimination of State Statutes |
| □ 240 Tools & Equipment | □ 443 Waiters | X 710 Federal Labor Law Act | □ 804 IRS (40ff) | □ 410 Decisional relief and state law claims for defamation |
| □ 245 Test Product Liability | □ 444 Other Civil Rights | X 710 Federal Labor Law Act | A FEDERAL TAX SUITS | □ 410 Decisional relief and state law claims for defamation |
| □ 260 All Other Real Property | □ 807 Taxes (U.S. Plaintiff or Defendant) | □ 410 Decisional relief and state law claims for defamation |
VI. ORIGIN
x 1. Original □ 2. Removed from □ 3. Remanded from □ 4. Refilled □ 6. Multidistrict Litigation □ 7. Appeal to District Judge from Proceeding State Court Appellate Court (Specify) □ 5. Transferred from another district Magistrate Judgment
VII. REQUESTED IN COMPAINT
CHECK IF THIS IS A UNDER F.R.C.P. 23 □ CLASS ACTION DEMAND $ Check YES only if demanded in complaint JURY DEMAND: □ NO
VIII. RELATED CASE(S) IF ANY
Jane Doe 2 Jeffrey Epstein JUDGE KENNETH A. MARRA DOCKET NUMBER 08-CV-80119-MARRA-JOHNSON
Jane Doe 3 Jeffrey Epstein JUDGE KENNETH A. MARRA DOCKET NUMBER 08-CV-80232-MARRA-JOHNSON
Jane Doe 5 Jeffrey Epstein JUDGE KENNETH A.MARRA DOCKET NUMBER 08-CV-80380-MARRA-JOHNSON
DATE Sep 10 2008 SIGNATURE OF ATTORNEY OF RECORD
STATES DISTRICT COURT FOR OFFICE USE ONLY: Receipt No. Amount: Date Paid: M/f/p:
EFTA00175900