- Firtuy Ricu TERS underage girls. (Upon information and belief, the young girl . who brought Jane Doe to Epstein was herself a minor victim to settle out of court with his of Epstein, and will therefore not be named in this Com- | plaint.) Under Epstein’s plan, underage girls were recruited a woman who went by the alias | ostensibly to give a wealthy man a massage for monetary sadeSlae lawsuit against Epstein. | compensation in his Palm Beach mansion. The recruiter te claimed, Epstein was fifty-two ¥ would be contacted when Epstein was planning to be at his and her complaint, which was . ; Palm Beach residence or soon after he had arrived there. world an early glimpse of what 4 Epstein or someone on his behalf would direct the recruiter t world, looked like 7 q to bring one or more underage girls to the residence. The ob bis Sears . recruiter, upon information and belief, generally sought out loney manager with a secret cli- 4 q economically disadvantaged underaged girls from western llionaires,” the lawsuit alleged. 4 y Palm Beach County who would be enticed by the money ’ sdous wealth, power and influ- a 4 being offered—generally $200 to $300 per “massage” “ hohe in ‘New You anda lm a 1 session —and who were perceived as less likely to complain o, St. Thomas and Palm Beach, a b to authorities or have credibility if allegations of improper - Epstein’s conduct while at his oa 4 conduct were made. This was an important element of e complaint continued: a ’ Epstein’s plan. | i 4 Epstein’s plan reflected a particular pattern and method. in has a sexual preference 4 4 _ Upon arrival at Epstein’s mansion, the underaged victim Ep an a dinaplad a 4 would be introduced to Sarah Kellen, Epstein’s assistant, who inor girls. He ne an i i gathered the girl’s personal information, including her name ‘ ae "is ‘ite sexually ; : and telephone number. Ms. Kellen would then bring the girl one A; r about j ‘ up a flight of stairs to a bedroom that contained a massage 1) gave ea ml ie