6
Shared Docs
6
Same-Page
6 / 11
Mentions
A. 09/12/2019 - 2 - 71 1ge 1 CONFIDENTIAL vAwthermanlaw.com Agency to Agency Requet: 19-411 SDNY_GM_00330201 EFTA_00202927 EFTA02728831 Community College student from Loxahatchee, Florida. She recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansio
2728833 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 reckle
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 Doe, Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiffs Jane D
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 Doc. 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 Stepmoth
homas. 12. An integral player in Epstein's Florida scheme was -a Palm Beach HERMAN & MERMELSTEIN, P. A. - 2 - www.hermanlaw.com EFTA00214197 Community College student from She recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's p
0214199 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 reckle
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 Doe, Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiffs Jane D
Thomas. 12. An integral player in Epstein's Florida scheme was a Palm Beach HERMAN & MERMELSTEIN, P. A. - 2 - www.hermanlaw.com 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 mansio
0257047 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 reckle
N & MERMELSTEIN, P. A. www.hermanlaw.com - 4 - EFTA00257056 t 24. As a direct and proximate result of Epstein's intentional or reckless con ct, Jane Doe, has suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiff Jane Doe No. 2 demands judgment against Defendant Jef
omas. 12. An integral player in Epstein's Florida scheme was , a Palm Beach HERMAN S MERMELSTEIN, P. A. - 2 - www.hermanlaw.com EFTA00257478 Community College student from Loxahatchee, Florida. She recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansio
0257480 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 reckle
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 Doe, Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiffs Jane D
New York and on his private island, known as Little St. James, in St. Thomas. 10. An integral player in Epstein's Florida scheme was a Palm Beach Community College student from Loxahatchee, Florida. She recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansio
tted willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 26. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
d on his private island, known as Little St. James, in St. Thomas. 10. An integral player in Epstein’s Florida scheme was Haley Robson, a Palm Beach 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
012635 TAB 32 HOUSE_OVERSIGHT_012636 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 20069 " JANE DOE NO. 1, by and through JANE DOE’s FATHER as parent and natural guardian, and JANE DOR’s FATHER, and . . JANE DOE’s STEPMOTHER, individually, ciV-MA RRA Plaintiffs, MAGISTRATE JUDGH
Entities connected to both Community College and Jane Doe

Jeffrey Epstein
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSON
George W. Bush
PERSON
Adam D. Horowitz
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON
Prince Andrew
PERSONStuart S. Mermelstein
PERSON
Sarah Kellen
PERSONMartin Weinberg
PERSON
Palm Beach County
LOCATION
Palm Beach
LOCATION
Jeffrey Marc Herman
PERSONJANE DOE NO
PERSON