Epstein Secrets

12008 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80069-CIV-MARRA/JOHNSON JANE DOE NO. I, by and through JANE DOE's FATHER as parent and natural guardian, and JANE DOE's FATHER, and JANE DOE's STEPMOTHER, individually, Plaintiffs, vs. JEFFREY EPSTEIN, Defenda

-1 Entered on FLSD Docket 02/13/2008 Page 4 of 5 Doe's Father, as the custodial parent, is the natural guardian, and the only natural guardian, of Jane Doe. As the natural guardian, Jane Doe's Father may sue on behalf of Jane Doe. See Fed.R.Civ.P. 17(b) (providing that capacity to sue or be sued shall b

The names of Jane Doe and Jane Doe's Father are redacted from Exhibit "A" hereto to protect the Minor Plaintiff's anonymity. (See Complaint I 4). HERMAN S. MERMELSTEIN, P. A. www.hermanlaw.com - 3 - EFTA00234047 Case 9:08-cv-80069-KAM Document 7-1 Entered on FLSD Docket 02/13/2008 Page 4 of 5 Doe's Father,

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

d 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 S. MERMELSTEIN, P. A. - I - www.hermanlaw.com EFTA00257483 0 part of the events or omissions giving rise to the claim occurred in this District. Factual Alle

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. 26. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had

Emotional Distress 22. Plaintiff Jane Doe repeats and realleges paragraphs 1 though 15 above. 23. Epstein's conduct was intentional or reckless. HERMAN S. MERMELSTEIN, P. A. - 4 - www.hermanlaw.corn EFTA00175906 Case 9:08-cv-b...-93-DTKH Doctil ....Int 1 Entereo FLSD Docket 09) /2008 Page 5 of 7 24. Eps

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. 26. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had

om HERMAN & MERMELSTEIN, P.A. Attorneys for Plaintff 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 HERMAN S. MERMELSTEIN, P. A. www.hermanlaw.com - 6 - EFTA00221177 ° 8-qY;§(aHMAgYA4°PilfringritVilL CgAigificIWKID Docket 09/10/2008 Page 7 ocfDi t ye µA The JS-44

us conduct would cause emotional trauma and damage to Jane Doe. 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 Jef

om 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. HERMAN S. MERMELSTEIN, P. A. www.hermanlaw.com - 3 - EFTA00222317 Case 9:08-cv-80119-KAM Document 1 Entered on FLSD Docket 02/06/2008 Page 4 of 6 14. As a result

FREY M. HERMAN STATE OF FLORIDA ) SS: COUNTY OF MIAMI-DADE Jeffrey M. Herman, deposes and states as follows: 1. I am the attorney of record for Jane Doe No. 2, and have knowledge of the status and history of this case. 2. The Complaint filed in this action alleges that Defendant Epstein is a financ

the press, since 2006. The filing of Jane Doe No. 2's case received extensive press coverage, as did a prior related case filed on January EXHIBIT HERMAN S. MERMELSTEIN, P. A. A www.hermanlaw.com EFTA00222595 Case 9:08-cv-80119-KAM Document 9-2 Entered on FLSD Docket 06/11/2008 Page 2 of 5 24, 2008 making si

OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defend

ibed before me thisa, day of May, 2008. My Commission expires: is.9;:k% Lisa Rivera #DD417062 Expires: APR. 11, 2009 '%OP,, WWWAARoNNorearrom HERMAN S. MERMELSTEIN, P. A. Notary Public, State of Florida PLAINTIFF'S EXHIBIT a www.hermanlaw.com EFTA00222582