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Mk r EFTA00257027 MySpace.com - Female - LOX =I, Florida - www.myspace.comi Page 1 of 13 Sponsored Links Bob Dylan Collection M-Base Ringtones Find Sexy Girls Im A Barbie Girl Ringtone A must-have! 5 decades of music & 10.000* Ring*nes! Gel Free Make an Instant Connection Find Get Complimentary Ringtones videos. Sample the collection now Ringtones Nth 9 99/rn Subsoil/lion Sexy Singles neat you Download The Ones You Want boodpan hylarak con/free Free SestengDoanioads corn tor:arms:nu Cs corn RocionesDoymbrad mAlsrbeGal User Shortcuts People Search home I browse I Search I invite I film I mail I Plops I favorites I forum I groups I events I mvspoce lv I music t comedy I classifieds mood: excited view my: arcs I videos CO Send Message ca. Forward to Friend •8j Add to Friends M . Add to Favorites 80 IM / Block User •e; Add to Group :8 Rank User myspace url: hIlo://www.mysP0Ce.cOm/ hlip://profile.myspace.com/index.cfm?fuseaction—usersiewprofile&friendid= 2/1/2008 EFTA00257028 MySpacc.com - 17 - Fcmalc - LOX —I, Florida - wv‘w.myspace.col MI:2 of 13 displaying 50 ot 291 comments ( view all add common' ) an 30 008 :3 om hey how are you? • amwourmv uenning http://protile.myspace.comfindex.cfm?fuseaction=usenviewprofile&friendidH 2/1/2008 EFTA00257029 MySpace.com - - 17 - Female - LOX 1, Florida - www.myspace.conv Page 3 of 13 ion 29 2008 4:47 pm BEST FRIEND. SISTER. ion 19 2008 9:03 om OTHER HALF. .111111 ion 29 2008 8:58 on' inn 29 7008 ft:50 am ion 27 2008 9:37 am http://profile.myspace.com/index.efin?fuseaction=user.viewprofilatfriendith 21/2008 EFTA00257030 MySpace.com - 17 - Female - LOX =], Florida - eim,..ymace.conEM Page 4 of 13 THIS iS WHAT BESTFMENDS LOOK LIKE. • 2, 200 ,6 or. Ian 2, 20. ',Born an 2, 200. htlp://profile.myspace.conilindex.efm?fuseaction=user.viewprofiled.iendid 2/1/2008 EFTA00257031 MySpace.com -M. 17 - Female - LOX -1, Florida - www.myspace.comij Page 5 of 13 on 23 2008 10:52 am ices 23 2000 I 455 urn monied Straight on 22 2008 9:34 pm on 21 2008 8:57 gm on 22 2008 10:IS gm on 22 2008 9. 32 om http://profile.myspace.com/index.cfin?fuseaction=user.viewprofilacfriendid 2/1/2008 EFTA00257032 MySpace.com -■- 17 - Female - LOX =1, Florida - unvw.myspace.comi Page 6 of 13 on 22 2008 9:27 Om inn 21 7008 9:48 pm on 1 7008 9. 13 Dm ion 21 2008 8:32 om http://profile.myspace.com/index.c fm?fuseaction—userviewprolile&friendid= 2/1/2008 EFTA00257033 MySpace.com - - 17 - Female - LOX 1, Florida - www.myspace.com Page 7 0113 00 21 2008 8.20 pm ion 21 2008 7:59 pm 1 ion 21 2008 7:56 pm http://profIle.myspace.com/index.cfm?fuseaction=user.viewproffle&friendid 2/1/2008 EFTA00257034 MySpace.com - 17 - Female - LOX =], Florida - www.myspace.coml Page 8 of 13 -■ on 21 2008 7:53 0m on 21 2008 7:48 om http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid=. 2/1/2008 EFTA00257035 MySpace.com - 17 - Female - LOX =], Florida - www.myspace.comi Page 9 0113 ion 21 20C8 6:26 Om on 21 2008 5,50 Dm on 21 008 5;33 pm on 21 008 5:76 nrn http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid 2/1/2008 EFTA00257036 MySpace.com -■- 17 - Female - LOX =], Florida - www.myspace.con] Page 10 of 13 ion 21 2008 4: 10 pm on 21 2008 3:55 om ian 21 2008 . 47 am on 21 2008 10:40 urn 'an 2 2908 10: 4 am ion 21 2008 9:31 am an 21 2008 9:16 am http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid= 2/1/2008 EFTA00257037 MySpace.com - ■ - 17 - Female - LOX =], Florida - www.myspace.comil Page 11 of 13 an 21 2008 9:24 om on 21 008 9 08 am on 21 2008 8:49 am ion 1i 2008 8:35 om ion 21 2008 8:37 om I Ian 20 2008 7'48 Dm http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendidH 2/1/2008 EFTA00257038 MySpace.com - - 17 - Female - LOX 1, Florida - www.myspace.com] Page 12 of 13 ■ on 21 2008 8:22 om On 21 2008 6: 2 om on 20 2008 7: 17 Dm ion 20 2008 2:43 Pm ion z0 2008 10 om add comment g.tmg 1 1R,A I Mu I RfiXRAY. I RISIX..tigk I Siatakcit.10M9ct I fg1220.... PAY.8.04.9. 18XSPAKIUDAP10.0tiR0S0 I alLsASIU.A21-82.9. http://protile.myspace.com/index.cfm?fuseaction=user.viewprofilettfriendid 2/1/2008 EFTA00257039 MySpace.com - - 17 - Female - LOX =I, Florida - www.myspace.co Page 13 of 13 02003-2008 myspace.com. all rights reserved. http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid 2/1/2008 EFTA00257040 Florida D.A.V.I.D. Individual Summary Page Page 1 of_ STATE OF FLORIDA Department of Highway Safety & Motor Vehicles Driver And Vehicle Information Database (DAVID) I DIGITAL IMAGES ARE FtESIRICIED 1O LAW ENFORCEMENT USE PURSUANT TO S. 321142(41, FLORIDA STATUTES - IMAGES INCLUDE PHOTOGRAPHS AND SIGNATURES Individual Summary Page DI. ID Nianlscr Class Status F. VALID All Addresses On File Date of Birth Sex Ileietil slate Of Binh Florida Restrictions Endorsements Issue Date Duplicate Expiration Date Date 03-23-13 SSN Primp) lifilmhor Conditional Messages: MOTORCYCLE TEMPORARY PERMIT UNTIL: AFE DRIVER 1.aw enforcement officers may continue to accept the insurance card indicating Property Damage only, as also including PIP, until June 30. 2008. Vehicle Information Acquired Record VIN l\pe i Color Body Make Date Reg ALUMINUM/ - View- TRUCK SILVER TRUCK DODGE 08-31-05 View MOTORCYCLE RED MOTORCYCLE Driver License Fransactions Transaction Issue Tic Change Record OLIO Number Update Time re Issue I> pe Tv -c Fl. Disp Date Date •I.% 05-30- I 144-0' View 11-14-07 EXO Exam Only ------ 06 10:18:48 05-30- 05-31-06 View 05.30.06 06 18:25:23 DI. Renewal/CIPS 06-20- 12-12-05 Address --- View 12-09-05 00 17:47:22 DL Chan eiCIPS 06-20- 04-29-05 View 04-28-05 00 00:06:53 DL Duplicate None Lost https://www.hsmv.ficjn.netiservIct/DLSummary I/25,2008 EFTA00257041 Florida D.A.V.I.D. Individual Summary Page Page 2 of _ 06-20- 10-24-03 Duplicate Nnne Lost UU 15:56:05 03-23-01 Replacement 03-23-01 10:07:42 06-20- Original 06-20-00 00 Historical Driver License Activity ( Vehicle Insurance Previous Vehicles Photo Array ( Signature Array ( New Search ( Main Menu https://www.hsmv.flejn.net/servletIDLSurnmary 1/25/2008 EFTA00257042 EFTA00257043 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: JANE DOE NO. 1, by and through ot3- 80069 JANE DOE's FATHER as parent and natural guardian, and JANE DOE's FATHER, and JANE DOE's STEPMOTHER, individually, CiV-MARIA Plaintiffs, IAMISTRAIE JUDGE vs. 1OHNSON FILED by D.C. INTAKE JEFFREY EPSTEIN, Defendant. JAN 2 4 2008 0CLELArttcRENuCE.8.. IADisTADDO.G.TX. S.D. OF FLA.. PT. LAUD. COMPLAINT Plaintiff, Jane Doe No. 1 ("Jane" or "Jane Doe"), by and through Jane Doe's Father as parent and natural guardian, and Jane Doe's Father and Jane Doe's Stepmother, individually, bring this Complaint against Jeffrey Epstein, as follows: Parties, Jurisdiction and Venue 1. Jane Doe is a citizen and resident of the State of Florida. She is a minor under the age of 18 years. 2. Jane Doe's Father brings this action individually and as parent and natural guardian of Jane Doe. Jane Doe's Father is a citizen and resident of the State of Florida. 3. Jane Doe's Stepmother brings this action individually. Jane Doe's Stepmother is a citizen and resident of the State of Florida. 4. 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 HERMAN St MERMELSTEIN, P. A. www.hermanlaw.com EFTA00257044 minor. 5. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 6. This is an action for damages in excess of $50 million. 7. 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. 8. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial part of the events or omissions giving rise to the claim occurred in this District. Factual Allegations 9. 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. 10. 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 2005, Jane Doe, then 14 years old, fell into Epstein's trap and became one of his victims. 11. 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. 12. An integral player in Epstein's Florida scheme was a Palm Beach HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com -2- EFTA00257045 Community College student from Loxahatchee, Florida. She recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's plan,a,rould be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or someone on his behalf directed Ms. to bring one or more underage girls to the residence. Ms. upon information and belief, generally sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas 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. 13. Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at Epstein's mansion, Mr.Mould introduce each victim to ==, Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. There were photographs of nude women lining the stairway hall and in the bedroom. Ms. 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. recruited Jane Doe to give Epstein a massage for monetary compensation. Ms. brought Jane to Epstein's mansion in Palm Beach. Jane was introduced to 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 HERMAN 5, MERMELSTEIN, P. A. www.hermanlaw.com -3- EFTA00257046 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. again who brought Jane home. Jane was paid $300 by Epstein. Ms. 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. COUNT I 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, deniands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this Court deems just and proper. HERMAN & MERMELSTEIN, P. A. vtnivw.hermanlaw.com -4- EFTA00257047 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 Do; 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. COUNT HI 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 HERMAN & MERMEI-STEIN, P. A. whrw.hermanlaw.com -5- EFTA00257048 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 fiuther relief as this Court deems proper. JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action. Dated: January 2008 Respectfully submitted, BERMAN & MERMELSTEIN, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 B Stuart S. Mermelstein Florida Bar No. 947245 Adam D. Horowitz Florida Bar No. 376980 HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com -6- EFTA00257049 Billionaire investor sued for alleged sexual assault of teen Page 1 of 3 HOME' SARASOTA VENICE MANATEE EAST MANATEE CHARLOTTE NORTH PORT ENG NewsoaDer ads I Browse rlassifieds p ffieraliffilta f sa WFR sptirdwiestraoRnwsiNfPRM ATI9/4 Slibcrriber se ii .ers I Magazines Become a member of HeraldTribune.com I Join now I Login NEWS I COMMUNITY BUSINESS SPORTS A&E OPINION JOBS AUTOS REAL ESTATE CLASSI Local Florida Nation World Politics Health Weather Crime Photos SNN Video Obit The news and informati Sarasota, Manatee & Ch Subscribe tod c9 Discus his article Billionaire investor sued for alleged sexual SI 0 Letter to editor assault of teen MI Print this article THE ASSOCIATED PRESS Adver e E-mail this article WEST PALM BEACH, Fla. -- Mother woman is suing a New York Too nation Southern Residents billionaire, claiming he sexually assaulted her when she was underage. Assess Tornado Damage University norms The unidentified woman says she was 16 when she was brought to Smashed at Tenn Schen Jeffrey Epstein's Palm Beach mansion and paid $200 to give the Death and Damage From money manager a massage. Instead, she claims he abused her. Tornadoes No Fatalities in Gas Plant The suit filed Wednesday in federal court is seeking more than $50 Fxolosion million in damages from Epstein. Too news 51058814defll31USPeSt Jias troubled history with Another teenage girl made similar claims against Epstein in a lawsuit WILLI fi led last month. Sarasota County PlertInnc chief drawing more fire Epstein also faces a felony charge of solicitation of prostitution. A School nmierts mild start conviction could send him to prison for five years. on hormwed dime Risk issue worries Florida Epstein's attorney has denied the allegations, but did not return phone insurance panel Adver messages Wednesday. 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All rights reserved. privacy Colley I Member http://www.heraldtribune.com/article/20080206/APN/802060750 2/6/2008 EFTA00257052 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. COMPLAINT Plaintiff, Jane Doe No. 2 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey Epstein, as follows: Parties, Jurisdiction and Venue 1. Jane Doe No. 2 is a citizen and resident of the Commonwealth of Virginia, and is sui juris. 2. 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. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. 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. 6. This Court has venue of this action pursuant to 28 U.S.C. §139I(a) as a substantial HERMAN 5. MERMELSTEIN, P. A. www.hermanlaw.com -I- EFTA00257053 part of the events or omissions giving rise to the claim occurred in this District. Factual Allegations 7. 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. 8. 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 2004-2005, Jane Doe, then approximately 16 years old, fell into Epstein's trap and became one of his victims. 9. 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. 10. Epstein's scheme involved the use of young girls to recruit underage girls. (Upon information and belief, the young girl who brought Jane Doe to Epstein was herself a minor victim of Epstein, and will therefore not be named in this Complaint). Under Epstein's plan, underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. The recruiter would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or someone on his behalf would direct the recruiter to bring one or more underage girls to the residence. The recruiter, upon information and belief, generally sought out economically disadvantaged underage girls from western Palm Beach County who would be enticed by the money being offered - generally $200 to $300 per HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com -2- EFTA00257054 "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. 11. Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at Epstein's mansion, the underage victim would be introduced to MI= Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms.= would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. There were photographs of nude women lining the stairway hall and in the bedroom. 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 and touching the girl's vagina. 12. Consistent with the foregoing plan and scheme, Jane Doe was recruited to give Epstein a massage for monetary compensation. Jane was brought to Epstein's mansion in Palm Beach. Once at the mansion, Jane was introduced to who led her up the flight of stairs to the room with the massage table. In this room, Epstein told Jane to take offher clothes and give him a massage. Jane kept her panties and bra on and complied with Epstein's instructions. Epstein wore only a towel around his waste. After a short period oftime, Epstein removed the towel and rolled over exposing his penis. Epstein began to masturbate and he sexually assaulted Jane. 13. After Epstein had completed the assault, Jane was then able to get dressed, leave the room and go back down the stairs. Jane was paid $200 by Epstein. The young girl who recruited Jane was paid $100 by Epstein for bringing Jane to him. 14. As a result of this encounter with Epstein, Jane experienced confusion, shame, HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com -3- EFTA00257055 humiliation and embarrassment, and has suffered severe psychological and emotional injuries. COUNT I Sexual Assault 15. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 16. Epstein tortiously assaulted Jane Doe sexually. Epstein's acts were intentional, unlawful, offensive and harmful. 17. Epstein's plan and scheme in which he committed such acts upon Jane Doe were done willfully and maliciously. 18. 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. 19. 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. 2 demands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive damages, costs, and such other and further reliefas this Court deems just and proper. COUNT II Intentional Infliction of Emotional Distress 20. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 21. Epstein's conduct was intentional or reckless. 22. Epstein's conduct was outrageous, going beyond all bounds of decency. 23. 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 trauma and damage to Jane Doe. HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com -4 - EFTA00257056 24. t As a direct and proximate result of Epstein's intentional or reckless con et, Jane Doe, has suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiff Jane Doe No. 2 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. JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action. Dated: February 2008 Respectfully submitted, HERMAN & MERMELSTEIN, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 By: Jeffrey M. Herman Florida Bar No. 521647 Stuart S. Mermelstein Florida Bw.c.RI MM Adam D. Horowitz Florida Bar No. 376980 HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com -5- EFTA00257057 MySpace.com - View Photo Page 1 of 3 MySpace.com Privacy I Help I SlynOut DISCOVER WINEH~USE et RETIE MUSIC. MUSIC MONKEYS User Shortcuts People Search c"" Home I Browse I Search I Invite I Film I Mail I Slogs I Favorites I Forum I Groups I Events I MySpace TV I Music I Comedy I Classifieds Back to Profile tli photos I Upload Photos Back to Albums My Photos - View Photo Previous I Next Assoc. http://viewmorepics.myspace.com/index.cfm?fuseaction=viewlmage& friendl &al buml D=151911&imagel D=116... 1/25/2008 EFTA00257058 MySpace.com - View Photo Page 2 of 3 . - • And my twins LOVE ME hahahaha!!!! 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All Rights Reserved. http://viewmorepics.myspace.com/index.cfm?fuseaction=viewlmage&friendlD= al bum ID=151911&imageID=116... 1/25/2008 EFTA00257060 iview More Pictures Page 1 of 4 MySpace.com Privacy I Help I SignOut 41 britney did what?? powered by User Shortcuts: People Search Google Home I Browse I Search I Invite I Film I Mail I Blogs I Favorites I Forum I Groups I Events I MySpace TV I Music I Comedy I Classifieds Back to Profile 4 photos I Upload Photos Back to Albums My Photos Listing 41-60 of 64 1 2 3 4 of 4 (Previous i blext> 1 Comment(s) 0 Comment(s) ), Post A Comment 0 Comment(s) 1 Comment(s) http://viewmorepies.myspace.com/index.cfm?fuseaction=user.viewPicture&friendID albumId=151911 1/25/2008 EFTA00257061 View More Pictures Page 2 of 4 0 Comment(s) 3 Comment(s) 2 Comment(s) o Comment(s) 0 Comment(s) 1 Comment(s) i comment(s) 1 comment(s) http://viewmorepics.myspace.com/index.cfm?fuseaction=usenviewPicture&friendID= albumld=151911 1'25/2008 EFTA00257062 View More Pictures Page 3 of 4 » Poct A Comment 0 Comment(s) 0 Comment(s) 1 Comment(s) 0 Comment(s) 0 Comment(s) http://viewmorepics.myspace.coni/index.cfm?fuseaction=user.viewPicture&friendlD= albumfd=15191 1 1,25/2008 EFTA00257063 * *View More Pictures Page 4 of 4 Listing 41-60 of 64 1 2 3 4 of 4 < Previous I Next > Sponsored Links tib1aLet lte_O pimp Your Profile Free "2007 Diet Of The Year" Qgutd You Be a Mechanic? 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Search powered Google Home I Browse I Search I Invite I Film I Mall I Blogs I Favorites I Forum I Groups I Events I MySpace TV I Music I Comedy I Classifieds Back to Profile photos I Upload Photos Sack to Albums My Photos - View Photo Previous I Next http://viewmorepies.myspace.com/index.cfmffuseaction=viewimage&friendIEMalbumID=151911&imageID=116... 1/25/2008 EFTA00257065 MySpace.com - View Photo Page 2 of 3 Listing - 1 of 1 Sponsored Links From Comment Wee Forest Folk Free Shipping on all Orders Quick Ship • 5/6 Club htm://viewmorepics.myspace.com/index.cfm?fuseaction=viewlmago&friendID=] bum11: 1519118cimage1D-116... 1/25/2008 EFTA00257066 MySpace.com - View Photo Page 3 of 3 wwwchertylanecollaction.com X0X0 Folk Music that Rocks Dave Rowe Trio.Maine fok music Sounds like lobster tastes www daverowetno con- Rosourco Entertainment The Md-South entertainment experts Great bands, prices, and service. www REGmemphis.com Folk Ringtones Get the top Folk music ringtones Pick any Folk music ringtone now FokMusic RogtonezFinder. corn About I FAQ I Terms Privacy I Safety Tips I Contact MySpace I Advertise I MySpace International I MySpace Latino ©2003-2008 MySpace.com. All Rights Reserved. http://viewmorepics.myspace.com/index.cfm?fuseaction-viewlmagadriendl lbwn1D=151911&image1D-116... 1/25/2008 EFTA00257067 ViEw More Pictures Page 1 of 2 MySp. Privacy I Help I SignOut User Shortcuts: People Search pbuwerti Goosle Home I Browse I Search I Invite I Film I Mail I Blogs I Favorites I Forum I Groups I Events I MySpace TV I Music I Comedy I Classifieds Back to Profile ii photos I Upload Photos Back to Albums My Photos Listing 61-64 of 64 1 2 3 4 of 4 Previous st A Comment os Commen » Post A Comment 1 Comment(s) 1 Comment(s) 0 Comment(s) 1 Comment(s) Listing 61-64 of 64 1 2 3 4 of 4 < Previous hup://viewmorepics.myspace.com/index.cfm?fuseaction=user.viewPicture&friendID= bumld=151911 1/25/2008 EFTA00257068 'V•tew More Pictures Page 2 of 2 Sponsored Links Upload Music Video Don't Buy Gold NYCO Music Video l'HQyabut 55 Pounds" Upload Your Video To OurStage. Learn how to make 200 gold an hour. 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No Convincing January 23, 2008 8:02 PM Or Explaining with my hahah thats sum good shit Revolutionary Unique Online Business Opportunity. FitnnlonuTIncuyhAction corn Credit Reports Check Your Credit Report Online. Look For Signs of Identity Theft. vnnv-ReportsCredif info Stop Your Divorce Stop by Step Instructions on How To Stop Your Divorce Right Now. January 23, 2008 7:08 PM www StopYourD.vorce con It says ... omg !!! yummmmmmmmyy love this pic.. you guys look hott together 11 Immediate Love Results 1 Free Reading 1865 503 5454 JAYDEN Stops Divorce.BreakupCreating Lies VVVVVV BRINCSBACKLOVER COM http://viewmorepics.myspace.com/index.cfm?fuseaction=viewlmage&friendIDH bumla=10930928dmagelD-13... 1/25/2008 EFTA00257072 . • MySpace.com - View Photo Page 4 of 4 amid I FAQ I terms I Privacy 1 Safety Tips I ContactittySone I Advertise I MySpace International I Mlfrantin0 ©2003.2008 MySpace.com. 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On 21 2008 4:10 •m http://profile.myspace.com/index.cfm?fuseaction—user.viewprofile&friendith 2/13/2008 EFTA00257083 , MySpace.com -M 17 - Female - LOX =], Florida - www.myspace.com Page 11 of 11 jon 21 20D8 3:5S pm wnot's gOOO Ion 21 2008 11:47 am ay beautiful thanks for the odd.. Cheek us out and leave some love.. let us know what yo think.. 'an 21 2008 10:40 am 'an 21 2003 10:14 am odd comment about I faq I terms I pr vocy I safely lips I contact myspoce report abuse I advertise I rnyspoce international I myspoce lotino C2003-2008 myspace.com. all rights reserved. http://profile.myspace.com/index.cfm?fuseaction=user.viewprofile&friendid=1 2/13/2008 EFTA00257084 Florida D.A.V.I.D. Individual Summary Page Page 1 ot I STATE OF FLORIDA Department of Highway Safety & Motor Vehicles Driver And Vehicle Information Database (DAVID) (AURAL IMAGES ARE RESIRIC IED I O LAW ENFORCEMENT USE PURSUANT TO S. 322.142(4), FLORIDA STATUTES - IMAGES INCLUDE PHOTOGRAPHS AND SIGNATURES Individual Summary Page DL.ID Number Class Status ID CARD VALID ( All Addresses On File LOXAHATCHEE FL 334704014 Date of Birth Sex Height State Of Birth Florida Restrictions Endorsements III Duplicate Expiration Date Date 05-13-10 SSN Form Number Conditional Messages: UNDER 21 UNTIL: AFE DRIVER ORGAN DONOR I an enforcement officers may continue to accept the insurance card indicating Property Damage only. as also including Pit', until June 30. 2008. chicle Information Record VIN c ('olor Body II Make Acquired Date Rez DiVer LICCIISC Trans Knolls Record DLAD Number transaction issue I ipclate Time I.ie Issue Type Change FL Date Date TN pc !ti .: Disp 02-05-07 View 02-01-07 05-I2-06 II) Duplicate/CI P I':47:40 05-12-06 View 05-12-06 05-12-06I ID Original None l6:26:08 Historical Driver License Activity j Vehicle Insurance [ Previous Vehicles Photo Array L Signature Array New Search Main Menu https://www.hsmv.flcjn.net/servlet!DLSummary 2/20/2008 EFTA00257085 • .! UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. COMPLAINT Plaintiff, Jane Doe No. 2 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey Epstein, as follows: Parties, Jurisdiction and Venue 1. Jane Doe No. 2 is a citizen and resident of the Commonwealth of Virginia, and is sui juris. 2. 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. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. 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. • 6. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial HERMAN 5. MERMELSTEIN, P. A. www.hermanlaw.com -1- EFTA00257086 part of the events or omissions giving rise to the claim occurred in this District. Factual Allegations • 7. 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. 8. 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 2004-2005, Jane Doe, then approximately 16 years old, fell into Epstein's trap and became one of his victims. 9. 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. 10. Epstein's scheme involved the use of young girls to recruit underage girls. (Upon information and belief, the young girl who brought Jane Doe to Epstein was herself a minor victim of Epstein, and will therefore not be named in this Complaint). Under Epstein's plan, underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. The recruiter would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or someone on his behalf would direct the recruiter to bring one or more underage girls to the residence. The recruiter, upon information and belief, generally sought out economically disadvantaged underage girls from western Palm Beach County who would be enticed by the money being offered - generally $200 to $300 per HERMAN & MERMELSTEIN, P. A. MAY. hermanlaw.com -2- EFTA00257087 "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. 11. Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at Epstein's mansion, the underage victim would be introduced to-Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. al would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. There were photographs of nude women lining the stairway hall and in the bedroom. 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 and touching the girl's vagina. 12. Consistent with the foregoing plan and scheme, Jane Doe was recruited to give Epstein a massage for monetary compensation. Jane was brought to Epstein's mansion in Palm Beach. Once at the mansion, Jane was introduced toa who led her up the flight of stairs to the room with the massage table. In this room, Epstein told Jane to take offher clothes and give him a massage. Jane kept her panties and bra on and complied with Epstein's instructions. Epstein wore only a towel around his waste. After a short period oftime, Epstein removed the towel and rolled over exposing his penis. Epstein began to masturbate and he sexually assaulted Jane. 13. After Epstein had completed the assault, Jane was then able to get dressed, leave the room and go back down the stairs. Jane was paid $200 by Epstein. The young girl who recruited Jane was paid $100 by Epstein for bringing Jane to him. 14. As a result of this encounter with Epstein, Jane experienced confusion, shame, HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com - 3- EFTA00257088 humiliation and embarrassment, and has suffered severe psychological and emotional injuries. COUNT I Sexual Assault 15. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 16. Epstein tortiously assaulted Jane Doe sexually. Epstein's acts were intentional, unlawful, offensive and harmful. 17. Epstein's plan and scheme in which he committed such acts upon Jane Doe were done willfully and maliciously. 18. 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. 19. Asa 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. 2 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 20. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 21. Epstein's conduct was intentional or reckless. 22. Epstein's conduct was outrageous, going beyond all bounds of decency. 23. 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 trauma and damage to Jane Doe. HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com -4- EFTA00257089 41. ne* • /14. Ki 24. 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. 2 demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further reliefas this Court deerns just and proper. JURY TRIAL BEMAND Plaintiffs demand a jury trial in this action. Dated: February , 2008 Respectfully submitted, HERMAN & MERMELSTEIN, P.A. Anorneys for Plaintiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 By: Jeffrey M. Herman Florida Bar No. 521647 Stuart S. Mermelstein Adam D. Horowitz Florida Bar No. 376980 • HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com -5- EFTA00257090