EFTA00013650.pdf

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Source set: data-set-8

Extracted text

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.:
JANE DOE NO. 1, by and through
08
JANE DOE's FATHER as parent and natural
guardian, and JANE DOE's FATHER, and
JANE DOE's STEPMOTHER, individually,
Plaintiffs,
vs.
JEFFREY EPSTEIN,
Defendant.
80Q69
CIV-MARRA
WaLSTRATE 111116B
IONNSON
FILED by
INTAKE
JAN 24 2008
SSC.LEM0RIC
CIIr
a:•14DIR
ASDT.721b.
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 & MERMELSTEIN, P. A.
- 1 -
www.hermanlaw.com
EFTA00013650

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"…

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