Epstein Secrets

1308065 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 rcallege paragraphs 1 through 16 above. 22. Epstein's conduct was intentional or reckle

ww.hermanlaw.com SDNY_GM_00328643 EFTA_00201395 EFTA01308071 24. As a direct and proximate result of Epstein's intentional or reckless conduct. Jane Doc, has suffered and will continue to suffer severe mental anguish and pain. WHEREFORE. Plaintiff Jane Doe No. 2 demands judgment against Defendant Jef

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

as suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. WHEREFORE, PlaintiffJane Doe, by and through her Father, as parent and natural guardian, demands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive da

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

as suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. WHEREFORE, PlaintiffJane Doe, by and through her Father, as parent and natural guardian, demands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive da

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

as suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. WHEREFORE, PlaintiffJane Doe, by and through her Father, as parent and natural guardian, deniands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive d

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

act, and Jane Doe was thereby put in such imminent apprehension. 17. Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane Poe, creating a reasonable fear of imminent peril. 18. Epstein intentionally inflicted harmful or offensive contact on the person &Jane Doe, with the

h County (Case nos. 2008-cf- 00938 1 AXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and scheme as alleged herein. 31. As to PlaintiffJane Doe, Epstein could have been charged with criminal violations of - 5 - EFTA00175863 'Case 9:08-cv-( 31-KAM Document 60 Enterer FLSD Docket 02/2

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

ach County (Case nos. 2008-cf- 009381AXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and scheme as alleged herein. 32. As to PlaintiffJane Doe, Epstein could have been charged with criminal violations of Florida Statute §796.07(2) (including subsections (I), (d), (e), (f), (g), and (h) ther

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 Doc. Epstein knew or had

ach County (Case nos. 2008-cf- 009381AXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and scheme as alleged herein. 31. As to PlaintiffJane Doe, Epstein could have been charged with criminal violations of - 5 - EFTA00175622 Case 9:08-cv-80 KAM Document 56 Entered I LSD Docket 02, 20