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Case 9:10-cv-81111-WPD Document 1 Entered on FLSD Docket 09/17/2010 Page 1 of 29
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.:
M.J.,
Plaintiff,
vs.
JEFFREY EPSTEIN and
SARAH KELLEN,
Defendants.
- - - - - - - - - - - - - -I
COMPLAINT
Plaintiff, M.J., by and through her undersigned counsel, sues the Defendants, Jeffrey
Epstein and Sarah Kellen, and alleges:
1. This is an action in an amount in excess of $15,000.00, exclusive of interest and costs and
is within the jurisdictional limits of this Court.
2. This Complaint is brought under a fictitious name in order to protect the identity of the
Plaintiff because this Complaint makes allegations of sensitive nature of offenses against a then
minor child.
3. At all times material to this cause of action, the Plaintiff, M.J. (hereinafter referred to as
"Plaintiff'), was a resident of Palm Beach County, Florida.
4. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence
located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida.
5. Defendant, Jeffrey Epstein, is currently a citizen of the United States Virgin Islands.
Case 9:10-cv-81111-WPD Document 1 Entered on FLSD Docket 09/17/2010 Page 2 of 29
6. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult
male born in 1953.
7. Defendant, Sarah Kellen, is currently a citizen of New York, where she currently resides.
8. At all times material, the Defendants Jeffrey Epstein and Sarah Kellen both owed a duty
unto Plaintiff to treat her in a non-negligent manner and to not commit or conspire to commit
intentional or tortious i
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