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' - 24. As a direct and proximate result of Defendants’ civil conspiracy, Jane Doe has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and émotional damages. WHEREFORE, Piaintif¥ Jane Doe, by and through her Mother, as parent and natural guardian, demands judgment against Defendants Jeffrey Epstein, Haley Robson, and Sarah Kellen for compensatory damages, costs, altomey’s fees, and such other and further relief as this Court deems just and proper. Further, Plaintiff reserves the right to amend this Complaint to add aclaun for punitive damages pussuant to Florida Law. COUNT Ill Initendonal Inflictioa of Emotional Distress eguinst Defendant Epstein 25. PiainaitY Jane Doe, by and through her Mother, a3 paren! and natural guardian, repeats” and reaileges paragraphs | throvgh 16 above. 2?. Epstein's conduct was outrageous, going beyond ati bounds of decency. 28. Epstein's conduct caused severe emotional distress not only to Jane Doe. Epstein knew of had reason 10 know that his intentional and outrageous conduct would cause emotional trauma ' and damage to Jane Dos and her mother. 29. As a ditect and proximate result of Epstein's intentional or reckless conduct, Jane Doe will continue to suffer severe mental anguish and paia. WHEREFORE, Ptaintiff Jane Doe, by and through her Mother as parent and natural guardian, demands, and Jane Doe's Mother, individually, demand judgment against Defendants Jeffrey Epstein, Hajey Robson, and Sarah Kellen for compensatory damages, costs, attomey’s fees, and such ofher and further relief as this Court deems just and proper Further, Plaintiff Page 6 of 9 lie @, Fret tine: } 07/26/17 Page 79 of 131 Public Records Request No.: 17-295 DOJ-OGR-00030546