Case 1:19-cv-07625-AJN-DCF Document 1 Filed 08/14/19 Page 1 of 26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO.: VE Plaintiff, VS. NINE EAST 71ST STREET, CORPORATION, FINANCIAL TRUST COMPANY, INC., NES, LLC, Defendant. / COMPLAINT Plaintiff, VE, by and through her undersigned counsel, for her claims against Defendants, alleges as follows: 1. The controversy in this cause of action exceeds the sum or value of $75,000, exclusive of interest and costs, and is between citizens of different States. Therefore, jurisdiction is proper under 28 U.S.C. section 1332. 2. Plaintiff files this Complaint under a pseudonym in order to protect her identity because this Complaint makes allegations of a sensitive sexual nature the disclosure of which, in association with her name, would cause further harm to her. 3. Plaintiff is currently a resident of and domiciled in the state of Florida. 4. At all times material to this cause of action, Jeffrey Epstein travelled between and stayed regularly in multiple residences, including in New York, New York (within the Southern District of New York) and the United States Virgin 1 EFTA02845999