» Case 9:08-cv-80232-KAM Document 1 Entered on FLSD Docket 03/05/2008 Page 4 of 6
17. Epstein’s plan and scheme in which he committed such acts upon Jane Doe were done willfully and maliciously.
18. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which ~ recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane.
19, Asadirect and proximate result of Epstein’s assault on Jane, she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. .
WHEREFORE, Plaintiff Jane Doe, demands jiiement against Defendant Jeffrey Epstein for
compensatory damages, punitive damages, costs, and such other and further relief as this Court
deems just and proper.
COUNT I Intentional Infliction of Emotional Distress
intentional Iniliction Of Fmouonal LIStess
20. Plaintiffs Jane Doe repeats and realleges paragraphs 1 through 14 above.
21. Epstein’s conduct was intentional or reckless.
22. Epstein's conduct was outrageous, going beyond all bounds of decency. |
23. Epstein’s conduct caused severe emotional distress to Jane Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe. |
24. Asadirect 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 demands judgment against Defendant Jeffrey Epstein for
compensatory damages, costs, punitive damages, and such other and further relief as this Court
HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com
40f6
HOUSE_OVERSIGHT_012647