Datasets:
title: DOJ Epstein Files, Data Set 9 (EFTA00175901)
source: DOJ Epstein Files, Data Set 9
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CM/ECF - Live Database - flsd
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JMH
U.S. District Court
Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80993-DTKH
Jane Doe No. 7. Epstein
Assigned to: Judge Daniel T. K. Hurley
Referred to: Magistrate Judge James M. Hopkins
Cause: 28:1391 Personal Injury
Date Filed: 09/10/2008
Jury Demand: Plaintiff
Nature of Suit: 710 Labor: Fair Standards
Jurisdiction: Federal Question
```markdown
Plaintiff
Jane Doe No. 7
Adam D. Horowitz
Herman & Mermelstein, P.A.
18205 Biscayne Blvd.
Suite 2218
Miami , FL 33160
305-931-2200
Fax: 305-931-0877
Email: ahorowitz@hermanlaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
# Jeffrey Marc Herman
Herman & Mermelstein
18205 Biscayne Boulevard
Suite 2218
Miami , FL 33160
305-931-2200
Fax: 931-0877
Email: jherman@hermanlaw.com
**LEAD ATTORNEY**
**ATTORNEY TO BE NOTICED**
Stuart S. Mermelstein
Herman & Mermelstein
18205 Biscayne Boulevard
Suite 2218
Miami , FL 33160
305-931-2200
Fax: 931-0877
Email: lrivera@hermanlaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?707770149002069-L_801_0-1
10/8/2008
EFTA00175901
CM/ECF - Live Database - flsd
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<table><tr><td>Defendant</td></tr><tr><td>Jeffrey Epstein</td></tr></table>
# Robert Deweese Critton , Jr.
Burman Critton Luttier & Coleman
515 N Flagler Drive
Suite 400
West Palm Beach , FL 33401-2918
561-842-2820
Fax: 561-515-3148
Email: rcrit@bclclaw.com
**LEAD ATTORNEY**
**ATTORNEY TO BE NOTICED**
<table><thead><tr><th>Date Filed</th><th>#</th><th>clear</th><th>Docket Text</th></tr></thead><tbody><tr><td>09/10/2008</td><td>1</td><td>⊢</td><td>COMPLAINT against Jeffrey Epstein Filing fee $ 350.00. Receipt#: 544158, filed by Jane Doe No. 7.(vt) (Entered: 09/10/2008)</td></tr><tr><td>09/10/2008</td><td>2</td><td>⊢</td><td>Summons Issued as to Jeffrey Epstein. (vt) (Entered: 09/10/2008)</td></tr><tr><td>09/15/2008</td><td>3</td><td>⊢</td><td>NOTICE of Attorney Appearance by Robert Deweese Critton, Jr on behalf of Jeffrey Epstein (Critton, Robert) (Entered: 09/15/2008)</td></tr><tr><td>10/03/2008</td><td>4</td><td>⊢</td><td>ACKNOWLEDGMENT OF SERVICE Executed as to 2 Summons Issued, 1 Complaint Acknowledgement filed by Jane Doe No. 7. (Herman, Jeffrey) (Entered: 10/03/2008)</td></tr><tr><td>10/03/2008</td><td>5</td><td>⊢</td><td>NOTICE of Striking 4 Acknowledgment of Service filed by Jane Doe No. 7 by Jane Doe No. 7 (Herman, Jeffrey) (Entered: 10/03/2008)</td></tr><tr><td>10/03/2008</td><td>6</td><td>⊢</td><td>SUMMONS (Affidavit) Returned Executed by Jane Doe No. 7. Jeffrey Epstein served on 9/23/2008, answer due 10/14/2008. (Herman, Jeffrey) (Entered: 10/03/2008)</td></tr></tbody></table>
<table border="1"><tr><td colspan="4">PACER Service Center</td></tr><tr><td colspan="4">Transaction Receipt</td></tr><tr><td colspan="4">10/08/2008 17:38:56</td></tr><tr><td>PACER Login:</td><td>du4480</td><td>Client Code:</td><td></td></tr><tr><td>Description:</td><td>Docket Report</td><td>Search Criteria:</td><td>9:08-cv-80993-DTKH</td></tr><tr><td>Billable Pages:</td><td>1</td><td>Cost:</td><td>0.08</td></tr></table>
https://ecf.flsd.uscourts.gov/cgi-bin/DktRpt.pl?707770149002069-L_801_0-1
10/8/2008
EFTA00175902
Case 9:08-cv-8JJ93-DTKH Document 1 Entered on FLSD Docket 09/.J/2008 FILIPAGE 167 D.C.
SEPT. 10, 2008
# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
```markdown
STEVEN M. LARIMORE
CLERK U.S. DIST. CT.
S.D. OF FLA. MIAMI
CASE NO.:
08-CV-80993-Hurley-Hopkins
JANE DOE NO. 7,
vs.
Plaintiff,
JEFFREY EPSTEIN,
Defendant.
COMPLAINT
Plaintiff, Jane Doe No. 7 (“Jane” or “Jane Doe”), brings this Complaint against Jeffrey Epstein, as follows:
Parties, Jurisdiction and Venue
Jane Doe No. 7 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
HERMAN & MERMELSTEIN, P. A.
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08-CV-80993 hurley-Hopkins 1 Entered on FLSD Docket 09/2/2008
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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 16 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. Haley Robson, a Palm Beach Community College student from Loxahatchee, Florida recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Ms. Robson, upon information and belief, generally sought out economically disadvantaged
HERMAN & MERMELSTEIN, P. A.
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EFTA00175904
08-CV-80993 hurley-Hopkins
Entered on FLSD Docket 09/2/2008
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underage girls from western Palm Beach County 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.
Epstein’s plan and scheme reflected a particular pattern and method. The underage victim would be brought to Epstein’s mansion, where she would be introduced to Sarah Kellen, Epstein’s assistant. 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. The girl would then find herself alone in the room with Epstein, who would be wearing only a towel. He would direct he rigl to give him a massage. Epstein would then perform one or more lewd, lascivious and sexual acts, including masturbation and touching the girl’s vagina.
Consistent with the foregoing plan and scheme, when Jane Doe was 16 years old, she was recruited by Haley Robson to give Epstein a massage for monetary compensation. Jane was brought to Epstein’s mansion in Palm Beach. Once there, Jane was introduced to Sarah Kellen, who led her up the flight of stairs to the room with the massage table. In this room, Jane was directed by Epstein to give him a massage. During this massage, Epstein sexually assaulted Jane and masturbated. Epstein then paid Jane money.
Jane returned on many occasions to the Palm Beach mansion to provide Epstein with massages for money. On those occasions, Epstein engaged in sexual contact and activity with Jane, which included, among other things, Epstein touching Jane's breasts, placing a vibrator on her vagina and masturbating himself. This sexual abuse continued over a period of approximately 18-24 months.
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Case 9:08-cv-8...93-DTKH Document 1 Entered FLSD Docket 09...2/2008
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- As a result of these encounters 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 15 above.
Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane Doe, creating a reasonable fear of imminent peril and sexual assault.
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. 7 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 15 above.
Epstein's conduct was intentional or reckless.
HERMAN & MERMELSTEIN, P. A.
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EFTA00175906
Case 9:08-cv-8...93-DTKH Document 1 Entered FLSD Docket 09.../2008
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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 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. 7 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 15 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.
HERMAN & MERMELSTEIN, P. A.
www.hermanlaw.com
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EFTA00175907
Case 9:08-cv-8...93-DTKH Document 1 Entered FLSD Docket 09/ J/2008
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- Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a reasonable attorneys' fee.
WHEREFORE, Plaintiff Jane Doe No. 7 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.
JURY TRIAL DEMAND
Plaintiff demands a jury trial in this action on all claims so triable.
Dated: September 10, 2008
Respectfully submitted.
By: ___
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: 305-931-2200
Fax: 305-931-0877
HERMAN & MERMELSTEIN, P. A.
6
www.hermanlaw.com
EFTA00175908
| I(a) PLAINTIFFS JANE DOE NO. 7, (b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF ORANGE 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, (305) 931-2200 | ATTORNEYS (IF KNOWN) |
II. BASIS OF JURISDICTION
(PLACE AN X ONE BOX ONLY)
| For Diversity Case Only | PTF | DEF |
|---|---|---|
| Citizen of This State | □ 1 | □ 1 |
| Citizen of Another State | □ 2 | □ 2 |
| Citizen or Subject of a Foreign Country | □ 3 | □ 3 |
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
PTF DEF
□ 4 □ 4
□ 5 □ 5
□ 6 □ 6
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
- 110 Insurance
- 234 Marital Act
- 160 Noise Instrument
- 180 Recovery of Charges
- 190 Recovery of Worker Assignment
- 181 Medical Act
- 185 Recovery of Dilated Eyes
- 186 Recovery of Disease
- 190 Blackjacker's Suits
- 190 Control Product Liability
A REAL PROPERTY
- 210 Land Condemnation
- 234 Construction B
- 240 Tools to Land
- 240 Tools to Land
- 290 All Other Real Property
A CIVIL RIGHTS
- 441 Voting
- 424 Employment
- 424 Housing accommodations
- 444 Welfare
- 440 Other Civil Rights
B PRISONER PETITIONS
- 510 Motors to Variable Sentence Habas Corp
- 530 Governmental Provision
- 534 Dead Penalty
- 550 Civil Rights A or B
B FORFEITURE PENALTY
- 810 Agriculture
- 820 Other Food & Drug
- 820 Drug Restricted Use of Property IUC 881
- 830 Liver Lap
- 830 Rail & Traffic
- 860 Occupied Health
- 860 Other
A BANKRUPTCY
- 422 Appeal 28 USC 158
- 423 Windward 28 USC 157
A PROPERTY RIGHTS
- A Copyrights
- B Patents
- C Trademark
B SOCIAL SECURITY
- HK Hk (19699)
- BLack Long (923)
- DWDCWOW (400tg)
- SZD We Wk
- RBS RB (400tg)
A FEDERAL TAX SUITS
- 870 Taxes (U.S. Point-of-Delivery)
- 871 WS-Third Party 28 USC 7800
A OTHER STATUS
- 420 State Respondent
- 420 Antitrust
- 420 Bank and Banking
- 420 Corporate or Academic B
- 420 Deposition
- 470 Risks Infused into Organizations
- 801 Selective Service
- 801 Selective Service
- 801 Customer Challenge 12UWC410
- 892 Aggravant Ats
- 892 Economic Stabilization Act
- 894 Federal Information Act
- 894 Federal Information Act Under Equal Access to Justice
- 900 Constitutionality of State
- 900 Other Statuary Actions A or B
VI. ORIGIN
x 1. Original □ 2. Removed from □ 3. Remanded from □ 4. Refilled □ 6. Multidistrict Litigation
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 4 Jeffrey Epstein JUDGE KENNETH A.MARRA DOCKET NUMBER 08-CV-80380-MARRA-JOHNSON
Jane Doe 5 Jeffrey Epstein JUDGE KENNETH A.MARRA DOCKET NUMBER 08-CV-80381-CIV-MARRA-JOHNSON
DATE September 10, 2008 SIGNATURE OF ATTORNEY OF RECORD
UNITED STATES DISTRICT COURT S/F 1-2 REV. 9/94
FOR OFFICE USE ONLY: Receipt No. Amount: Date Paid: Mifo:
EFTA00175909