Epstein Secrets

is a citizen and resident of the Commonwealth of Virginia. and is sui juris. 2. This Complaint is brough

disadvantaged underage girls from western Palm Beach County who would be enticed by the money being offered - generally $200 to $300 per HERMAN b, MERMELSTEIN, P. A. vAwthennanlawoom SONY_GM_00328641 EFTA_0020 1393 EFTA01308069 "massage" session - and who were perceived as less likely to complain to a

is a citizen and resident of the Commonwealth of Virginia, and is sui juris. 2. This Complaint is brough

d 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. - 3 - www.hermanlaw.com EFTA00257046 removed his towel, and laid down naked on the massage table. He demanded that Jane remove her cloth

vard Suite 2218 60 Fax: Counsel for Plaintiff Jane Doe #3 Jack Alan Goldberger Atterbury Goldberger & Wei

e was thereby put in such imminent apprehension. 17. Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane HERMAN a, MERMELSTEIN, P. A. - 3 - EFTA00175769 Case 9:08-cv-8La-KAM Document 37 Enterecli,.., FLSD Docket 0‘,..2/2008 Page 4 of 8 Doe, creating a reasonable fear

omplaint against Jeffrey Epstein, as follows: Parties, Jurisdiction and Venue 1. Jane Doe No. 2 is a citizen and resident of th e 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 sen

dence. The recruiter, upon information and belief, generally sought out economically disadvantaged underage girls from western Palm Beach HERMAN 6i MERMELSTEIN, P. A. www.hermanlaw.com - 2 - EFTA00175712 :Case 9:08-cv-80119-KAM Document 1 Entered on . ..SD Dv,..Ket I/Leo/2008 Page 3 of 6 County who