Case 9:08-cv-80380-KAM Document 157-1 Entered on FLSD Docket 05/06/2010 Page 1 of 8 Case 9:08-cv-80380-KAM Document 62 Entered on FLSD Docket 02/27/2009 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80380-MARRS JANE DOE NO. 4, Plaintiff, Ms. JEFFREY EPSTEIN, Defendant. SECOND AMENDED COMPLAINT Plaintiff, Jane Doe No. 4 ("Jane" or "Jane Doe"), brings this Amended Complaint against Jeffrey Epstein, as follows: Parties, Jurisdiction and Venue 1. Jane Doe No. 4 is a citizen and resident of the State of Florida, and is sui juris. 2. This Complaint is brought under a fictitious name to protect the identity of the Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs; and (ii) is between citizens of different states. 6. Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because Plaintiff alleges a claim under the laws of the United States. This Court has supplemental jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein, which form part of -1- EXHIBIT /4- 4 lb; EFTA02741407