{"efta_number": "EFTA01249981", "page_count": 70, "url": "https://epstein-data.com/EFTA01249981", "pdf_url": "https://epstein-data.com/pdf/EFTA01249981.pdf", "pages": [{"efta_number": "EFTA01249981", "page_number": 0, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 3. of 52 \nUNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK \nCASE NO.: \nPRISCILLA DOE, \nPlaintiff, \nvs. \nDARREN K. INDYKE AND \nRICHARD D. KAHN AS JOINT \nPERSONAL REPRESENTATIVES OF \nTHE ESTATE OF JEFFREY E. EPSTEIN, \nNINE EAST 715T STREET, CORPORATION, \nFINANCIAL TRUST COMPANY, INC., \nNES, LLC, MAPLE, INC., LSJ, LLC, \nHBRK ASSOCIATES, INC., JEGE, INC., \nDefendants. \nCOMPLAINT \nPlaintiff, PRISCILLA DOE, by and through her undersigned counsel, for her \nclaims against Defendants, alleges as follows: \n1. \nThis action is brought pursuant to 18 U.S.C. §1591 - § 1595. Therefore, \njurisdiction is proper under 28 U.S.C. §1331. \n2. \nPlaintiff files this Complaint under a pseudonym in order to protect her \nidentity because this Complaint makes allegations of a sensitive sexual nature the \ndisclosure of which, in association with her name, would cause further harm to her. \n3501.484-002 \nPage 1 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095907 \nEFTA01249981\n", "char_count": 1062}, {"efta_number": "EFTA01249981", "page_number": 1, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 2 of 52 \n3. \nPlaintiff is currently a resident of and domiciled in the \n4. \nAt all times material, Jeffrey Epstein was a citizen of the United States \nand a resident of the U.S. Virgin Islands. Jeffrey Epstein was a man of extraordinary \nwealth who travelled between and stayed regularly in multiple residences, including \nin New York, New York (within the Southern District of New York) at 9 East 7P \nStreet, New York, NY 10021; in Palm Beach, Florida at 358 El Brillo Way, Palm \nBeach, Florida 33480; in New Mexico at 49 Zorro Ranch Road, Stanley, New \nMexico 87056, and in the United States Virgin Islands at Island Little St. James \nIsland No. 6B USVI 00802. \n5. \nAt all times material to this cause of action Jeffrey Epstein was an adult \nmale born in 1953, who died on August 10, 2019. \n6. \nDefendant, Darren K. Indyke and Richard D. Kahn as Joint Personal \nRepresentatives of the Estate of Jeffrey E. Epstein (\"Estate of Jeffrey E. Epstein\") \nthe Estate of Jeffrey E. Epstein was opened and domiciled in the United States Virgin \nIslands, St. Thomas Division, and is the legal entity responsible for intentional, \ncriminal, or tortious conduct committed by Jeffrey Epstein as described in this \nComplaint. \n7. \nAt all times material hereto, Defendant Nine East 71st Street, \nCorporation (\"Nine East\") was a domestic business corporation conducting business \n2 \n3501.484-002 \nPage 2 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095908 \nEFTA01249982\n", "char_count": 1546}, {"efta_number": "EFTA01249981", "page_number": 2, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 3 of 52 \nin New York, with its principal place of business located at 575 Lexington Avenue, \nFourth Floor, New York, NY 10022. \n8. \nAt all times material hereto, Defendant Financial Trust Company, Inc. \n(\"Financial Trust\"), was and is a U.S. Virgin Islands corporation conducting \nbusiness in multiple locations including New York. \n9. \nAt all times material hereto, Defendant NES, LLC, (\"NES\") was and is \na domestic limited liability company registered in and conducting business in \nmultiple locations including New York. \n10. \nAt all times material hereto, Defendant, Maple, Inc., (\"Maple\") is and \nwas a U.S. Virgin Islands corporation which conducted business in New York. \n11. \nAt all times material hereto, Defendant L.S.J., LLC, (\"LSJ\") was a \nDelaware corporation conducting business in the United States Virgin Islands with \na registered agent located at 1209 Orange Street, Wilmington, Delaware 19801. \n12. \nAt all times material hereto, Defendant HBRK Associates, Inc., \n(\"HBRK\") is and was a domestic business corporation registered in and conducting \nbusiness in multiple locations including New York with a Registered Agent located \nat 1365 York Avenue, Apartment 28, New York, New York 10021. \n13. \nAt all times material hereto, Defendant JEGE, Inc., (\"JEGE\") was a \nDelaware corporation conducting business throughout the United States of America, \nincluding but not limited to, Florida, New York, and the United States Virgin \n3 \n3501.484-002 \nPage 3 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095909 \nEFTA01249983\n", "char_count": 1627}, {"efta_number": "EFTA01249981", "page_number": 3, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 4 of 52 \nIslands, with a registered agent located at 1209 Orange Street, Wilmington, \nDelaware 19801. \n14. Corporate Defendants NES, LLC; Financial Trust Company, Inc; Nine East \n71 \" Street; Maple, Inc.; L.S.J., LLC; HBRK Associates, Inc.; and JEGE, Inc., \nreferred to as \"Corporate Defendants,\" each performed business, in whole or part, in \nNew York. \n15. \nPlaintiff intends to amend this complaint to add or substitute additional \nparties as discovery reveals the identities of other tortious corporate or individual \nactors. \n16. \nJeffrey Epstein, the leader of a complex commercial sex trafficking and \nabuse ring, was an officer, director, or employee of many corporate entities \nregistered in various states throughout the United States, one or more of which may \nalso be legally responsible for the crimes he committed against young females, \nincluding Plaintiff \n17. \nAdditionally, individuals who worked at the residences where sexual \ncriminal acts were committed, or friends or acquaintances who assisted Jeffrey \nEpstein in committing such violations or those of his wealthy, famous, or socially \npowerful friends with whom Jeffrey Epstein caused Plaintiff to be sexually abused \nby, or those who were employed through, or worked for, numerous other corporate \n4 \n3501.484-002 \nPage 4 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095910 \nEFTA01249984\n", "char_count": 1456}, {"efta_number": "EFTA01249981", "page_number": 4, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 5 of 52 \nentities whose participation caused or contributed to causing the sexual violations \nthat caused harm to Plaintiff, may additionally be added as defendants. \n18. \nA substantial part of the acts, events, and omissions giving rise to this \ncause of action occurred in the Southern District of New York; venue is proper in \nthis District. 28 U.S.C. section 1391(b)(2). \n19. \nAt all times material to this cause of action, Jeffrey Epstein (legally \nrepresented now through Darren K. Indyke and Richard D. Kahn as Joint Personal \nRepresentatives of the Estate of Jeffrey E. Epstein (and referred to herein as \"Estate \nof Jeffrey E. Epstein\") and Corporate Defendants owed a duty to Plaintiff to treat \nher in a non-negligent manner and not to commit, or conspire to commit, or cause to \nbe committed intentional, criminal, fraudulent, or tortious acts against Plaintiff, \nincluding any acts that would cause Plaintiff to be harmed through conduct \ncommitted against her in violation of Common law battery, New York Penal Law \nsection 130.20; or New York Penal Law 130.35; or New York Penal Law 130.50; or \nNew York Penal Law 130.52; or New York Penal Law 130.66; or any violation of \n18 U.S.C. §1591 - §1595. \nFACTUAL ALLEGATIONS \n20. \nAt all times material to this cause of action, Jeffrey Epstein was an adult \nmale over 45 years old. Epstein was a tremendously wealthy individual, widely \nrecognized as a billionaire, who used his wealth, power, resources, and connections \n5 \n3501.484-002 \nPage 5 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095911 \nEFTA01249985\n", "char_count": 1662}, {"efta_number": "EFTA01249981", "page_number": 5, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 6 of 52 \nto commit illegal sexual crimes in violation of federal and state laws and who \nemployed or conspired with other individuals and corporate entities to assist him in \ncommitting those crimes or torts or who facilitated or enabled those acts to occur. \n21. \nEpstein displayed his enormous wealth, power, and influence to his \nemployees; to the employees of the corporate or company entities who worked at his \ndirection; to the victims procured for sexual purposes; and to the public, in order to \nadvance, carry out and conceal his crimes and torts. \n22. \nAt all relevant times, Epstein had access to numerous mansions, as well \nas a fleet of airplanes, motor vehicles, boats and one or more helicopters. For \nexample, he regularly traveled by private jet aboard a Boeing aircraft (of make and \nmodel B-727-31H with tail number N908JE) or a Gulfstream aircraft (of make and \nmodel G-1159B with tail number N909JE). \n23. \nJeffrey Epstein also frequently inhabited and travelled between \nnumerous properties and homes, each of which he admitted to being owned or \ncontrolled by him, including a Manhattan townhotne located at 9 East 71' Street, \nNew York, NY 10021 valued conservatively by Jeffrey Epstein's own admission at \n$55,931,000.00; a ranch located at 49 Zorro Ranch Road, Stanley, New Mexico \n87056 valued conservatively by Jeffrey Epstein's own admission at $17,246,208.00; \na home located at 358 El Brillo Way, Palm Beach, Florida 33480 valued \nconservatively by Jeffrey Epstein's own admission at $12,380,209.00; an apartment \n6 \n3501.484-002 \nPage 6 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095912 \nEFTA01249986\n", "char_count": 1727}, {"efta_number": "EFTA01249981", "page_number": 6, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 7 of 52 \nlocated at 22 Avenue Foch, Paris, France 75116 valued conservatively by Jeffrey \nEpstein's own admission at $8,672,820.00; an Island located at Great St. James \nIsland No. 6A USVI 00802 (parcels A, B, C); and an Island Little St. James Island \nNo. 6B USVI 00802 (A, B, C). See Jeffrey Epstein \"Asset Summary — June 30, \n2019\" filed in Case 1:19-cr-00490-RMB on July 15, 2019 attached hereto as Exhibit \nA. \n24. \nJeffrey Epstein controlled or was otherwise affiliated with the \ncorporation or business entities that owned, managed, or maintained each of the real \nproperties listed in the preceding paragraph. \n25. \nThe allegations herein concern Jeffrey Epstein's tortious conduct \ncommitted against Plaintiff; while at the residence owned by Defendant Nine East \nand then Defendant Maple; or the residence located in the United States Virgin \nIslands owned by LSJ. Many such acts were facilitated by Defendant NES, or \nDefendant HBRK, or Defendant JEGE. \n26. \nEpstein had a compulsive sexual preference for young females, as \nyoung as 14 years old, and acted on that sexual preference for decades. \n27. \nEpstein enjoyed sexual contact with young females, including minor \nchildren, and also took pleasure corrupting vulnerable and innocent young females, \nincluding minor children, into engaging in sexual acts with him. \n7 \n3501.484-002 \nPage 7 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095913 \nEFTA01249987\n", "char_count": 1513}, {"efta_number": "EFTA01249981", "page_number": 7, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 3. Filed 08/20/19 Page 8 of 52 \n28. \nEpstein directed a complex system of individuals, including employees \nand associates of Defendant entities, to work in concert and at his direction, for the \npurpose of harming young females through sexual exploitation, abuse and \ntrafficking. \n29. \nIt was widely known among individuals regularly in Epstein's presence \nthat he obtained pleasure from corrupting and inducing vulnerable young females \ninto engaging in uncomfortable and unwanted sexual acts for his own gratification. \n30. \nEpstein's illegal sexual activities were investigated by law enforcement \non at least two occasions, once in 2005-2008 by the United States Attorney for the \nSouthern District of Florida, and more recently by the United States Attorney for the \nSouthern District of New York. \n31. \nOn July 2, 2019, the United States Attorney's Office for the Southern \nDistrict of New York filed a Sealed Two Count Indictment including One Count of \nSex Trafficking Conspiracy and One Count of Sex Trafficking for violations of 18 \nU.S.C. §1591, in part due to Epstein's criminal activities against children in the New \nYork Mansion located at 9 East 71s1 Street. \n32. \nOn July 8, 2019, Jeffrey Epstein was arrested pursuant to the \naforementioned Indictment, which is attached hereto as Exhibit B. \n33. \nThe Indictment stated in part, and Plaintiff herein adopts as true and \nrelevant to her Complaint, that \"Jeffrey Epstein, the defendant, enticed and recruited, \n8 \n3501.484-002 \nPage 8 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095914 \nEFTA01249988\n", "char_count": 1638}, {"efta_number": "EFTA01249981", "page_number": 8, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 9 of 52 \nand caused to be enticed and recruited, minor girls to visit his mansion in Manhattan, \nNew York (the \"New York Residence\") and his estate in Palm Beach, Florida (the \n\"Palm Beach Residence\") to engage in sex acts with him, after which the victims \nwere given hundreds of dollars in cash.\" Criminal Indictment at 1. \n34. \n\"Moreover, and in order to maintain and increase his supply of victims, \nEpstein also paid certain of his victims to recruit additional girls to be similarly \nabused by EPSTEIN. In this way, EPSTEIN created a vast network of underage \nvictims for him to sexually exploit in locations including New York and Palm \nBeach.\" Criminal Indictment at 1-2. \n35. \n\"The victims described herein were as young as 14 years old at the time \nthey were abused by Jeffrey Epstein, and were, for various reasons, often particularly \nvulnerable to exploitation. Epstein intentionally sought out minors and knew that \nmany of his victims were in fact under the age of 18, including because, in some \ninstances, minor victims expressly told him their age.\" Criminal Indictment at 2. \n36. \n\"In creating and maintaining this network of minor victims in multiple \nstates to sexually abuse and exploit, JEFFREY EPSTEIN ... worked and conspired \nwith others, including employees and associates who facilitated his conduct by, \namong other things, contacting victims and scheduling their sexual encounters with \nEPSTEIN at the New York Residence and at the Palm Beach Residence.\" Criminal \nIndictment at 2. \n9 \n3501.484-002 \nPage 9 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095915 \nEFTA01249989\n", "char_count": 1694}, {"efta_number": "EFTA01249981", "page_number": 9, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 10 of 52 \n37. \nThe indictment further explained, and Plaintiff adopts and alleges, that, \n\"[v]ictims were initially recruited to provide `massages' to Epstein, which would be \nperformed nude or partially nude, would become increasingly sexual in nature, and \nwould typically include one or more sex acts.\" Criminal Indictment at 3. \n38. \n\"Epstein abused numerous minor victims at the New York Residence \nby causing these victims to be recruited to engage in paid sex acts with him.\" \nCriminal Indictment at 3. \n39. \nIn addition to the allegations in the criminal indictment referenced \nabove, Epstein also utilized a similar, if not the same, scheme many years before the \ntime period that was charged and many years after, as well as in additional locations \nnationally and internationally. \n40. \nCorporate Defendants enabled Jeffrey Epstein to receive daily \nmassages from young females, often minors, who were not experienced in massage. \nRather than receive regular body massages, Epstein was predictably sexually \nabusing the young females, including Plaintiff, in violation of New York Penal Law \nSection 130. \n41. \nAdditionally, employees of the various Corporate Defendant performed \nactions or failed to perform actions that further placed victims, including Plaintiff, \nin danger of being sexually abused by Epstein, and assisted in the concealment of \nhis sexually abusive acts. \n10 \n3501.484-002 \nPage 10 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095916 \nEFTA01249990\n", "char_count": 1574}, {"efta_number": "EFTA01249981", "page_number": 10, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page u. of 52 \n42. \nDefendants employed many recruiters of young females, or directed \nemployees of his related companies, to recruit young females. In order to grow the \nenterprise and satisfy his insatiable sexual desire, Epstein and those working at his \ndirection enabled victims themselves to elevate their status within the enterprise to \nthat of a paid recruiter of other victims, an elevation only made possible through the \nassistance of Defendants. \n43. \nRecruiters were taught by Jeffrey Epstein or by employees of Corporate \nDefendants to inform targeted young female victims that Epstein possessed \nextraordinary wealth, power, resources, and influence; that he was a philanthropist \nwho would help female victims advance their education, careers, and lives; and that \nshe only needed to provide Epstein with body massages in order to avail herself of \nhis nearly unlimited assistance and influence. \n44. \nEpstein and Corporate Defendants and their many employees fulfilled \nEpstein's compulsive need for sex with young females by preying on their personal, \npsychological, financial, and related vulnerabilities. Epstein and Defendants' tactics \nincluded promising the victims money, shelter, transportation, gifts, employment, \nadmission into educational institutions, educational tuition, profession, licensure, \nprotection, healthcare, and other things of value. \n45. \nJeffrey Epstein's sexual attraction to young, often underage, females \ndated back to at least the mid-nineties and the number of victims increased \n11 \n3501.484-002 \nPage 11 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095917 \nEFTA01249991\n", "char_count": 1712}, {"efta_number": "EFTA01249981", "page_number": 11, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 12 of 52 \nsubstantially with the necessary assistance from Defendants and Defendants' \nemployees. \n46. \nDefendants, at the direction of Epstein or in furtherance of his demands, \nand with help from assistants, associates and underlings, and even other victims, \nrecruited or procured dozens if not hundreds of young females, including minors, \nfor the purpose of Epstein's sexual gratification. \n47. \nJeffrey Epstein, and employees of certain Corporate Defendants, \nincluding at least Defendant HBRK, specifically targeted underprivileged, \nemotionally vulnerable and/or economically disadvantaged young females to \nsexually molest and abuse. \n48. \nAdditionally, Jeffrey Epstein and Corporate Defendants, through \nemployees, informed young females, including Plaintiff, that Jeffrey Epstein was \nwealthy, well-connected, and had the power and ability to impact the life of any \nyoung female recruited or obtained to provide a massage. \n49. \nEach of the Corporate Defendants committed acts of negligence that \nallowed for Epstein to commit acts in violation of New York Penal Law section 130. \n50. \nEach of the Defendants committed acts against Plaintiff in violation of \n18 U.S.C. §I59 I - §1595. \n12 \n3501.484-002 \nPage 12 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095918 \nEFTA01249992\n", "char_count": 1381}, {"efta_number": "EFTA01249981", "page_number": 12, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 13 of 52 \nPRISCILLA DOE \n51. \nPlaintiff was twenty years old when she met Jeffrey Epstein in 2006, at \na time when Jeffrey Epstein was under federal criminal investigation by the United \nStates Attorney for the Southern District of Florida in relation to his commission of \nvarious federal crimes, including violations of 18 U.S.C. §1591, against more than \n30 identified minor females. \n52. \nPlaintiff was a_in \nNew York when she was recruited to meet \nJeffrey Epstein by another young female who had also fallen prey to Jeffrey \nEpstein's sex trafficking scheme. \n53. \nThe recruiter asked Plaintiff if she wanted a job giving massages to a \nvery wealthy man. \n54. \nPlaintiff agreed to meet Jeffrey Epstein, knowing that she would be \ngoing to a New York mansion to give a wealthy man a massage. \n55. \nThe first time to the Mansion at 9 East 71st Street, she was taken \nupstairs and Jeffrey Epstein paid her hundreds of dollars to give him a massage. This \nmassage was not sexual and Jeffrey Epstein used the time to ask Plaintiff about her \nlife, during which he learned that \n13 \n3501.484-002 \nPage 13 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095919 \nEFTA01249993\n", "char_count": 1262}, {"efta_number": "EFTA01249981", "page_number": 13, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 14 of 52 \n56. \nJeffrey Epstein paid Plaintiff for the massage, took her number and told \nher someone would call her to return. \n57. \nAssociate I called Plaintiff and told her to come back for a second time. \n58. \nAgain, on a second visit, Plaintiff was taken to the massage room in the \nMansion and Jeffrey Epstein spent much of the time asking questions about Plaintiff, \nlearning what she cared about, what professional plans she had, and what problems \nshe was experiencing. \n59. \nBy the third visit, in 2006, Jeffrey Epstein informed Plaintiff that he had \nresources that he would use to advance Plaintiff's \ncareer if she would do what \nhe wanted her to do. \n60. \nPlaintiff started visiting Jeffrey Epstein more regularly and he began \nmaking the massages more sexual, digitally penetrating Plaintiff, and using sexual \nobjects to insert in Plaintiff. \n61. \nJeffrey Epstein always reminded Plaintiff that because of the money he \nwas paying her for the commercial sex acts that he called \"massage,\" she was able, \nfor the first time, to pay for her mother's rent and for her own groceries. \n62. \nDuring her conversations with Jeffrey Epstein, \n14 \n3501.484-002 \nPage 14 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095920 \nEFTA01249994\n", "char_count": 1332}, {"efta_number": "EFTA01249981", "page_number": 14, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 15 of 52 \n63. \nDespite the fact that he had assured Plaintiff he would not try to have \nsexual intercourse with her, Jeffrey Epstein forced himself on Plaintiff \nagainst her will and wishes. \n64. \nIn 2006, Jeffrey Epstein told Plaintiff she was going on a trip with him \nto his island in the United States Virgin Islands. \n65. \nOn that trip was Jeffrey Epstein, Jean Luc Brunel, Ghislaine Maxwell, \nAssociate 2, Associate 8, and two other victims in addition to Plaintiff. \n66. \nIt was there that Ghislaine Maxwell taught Plaintiff the \"proper way to \ngive a blow job,\" describing to her the exact way that Jeffrey Epstein liked to he \nsexually serviced orally. \n67. \nGhislaine Maxwell explicitly told Plaintiff she needed to learn how to \nproperly sexually service Jeffrey Epstein in the exact way that he preferred. \n68. \nGhislaine Maxwell then taught Plaintiff step by step, using her own \nhands to demonstrate, how to pleasure Jeffrey Epstein manually so that Plaintiff \nwould know exactly how to make Jeffrey Epstein happy. \n69. \nThe instruction by Ghislaine Maxwell included training on the proper \npressure to apply, the location in which pressure should be applied, the location of \nthe various nerve endings that should be stimulated, and the areas of the penis that \nare the most sensitive for targeted stimulation. \n15 \n3501.484-002 \nPage 15 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095921 \nEFTA01249995\n", "char_count": 1510}, {"efta_number": "EFTA01249981", "page_number": 15, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 16 of 52 \n70. \nGhislaine Maxwell made it clear to Plaintiff that it was very important \nfor her to understand and take this instruction seriously. The message delivered to \nPlaintiff by Ghislaine Maxwell was conveyed in a serious manner that instilled \ngenuine fear in Plaintiff that her failure to comply would cause her serious harm. \n71. \nWhen Plaintiff was called in to \"massage\" Jeffrey Epstein on the Island \nafter Ghislaine Maxwell's instruction, he reiterated the same instruction that Plaintiff \nwas provided by Ghislaine Maxwell using a hands on approach. \n72. \nIn addition to providing sexual instruction, Ghislaine Maxwell further \nmade sure that Plaintiff and the other young females were constantly on call to \nsexually service Jeffrey Epstein. \n73. \nWhile on the Island, Associate 2 also made it clear to Plaintiff that when \nJeffrey Epstein asked her to engage in certain sexual behavior, she needed to comply. \n74. \nShortly thereafter, Jeffrey Epstein forced Plaintiff to engage in sexual \nactivity with Associate 2 in his presence for his own sexual gratification. The \nexperience between Plaintiff and Associate 2 was especially uncomfortable for \nPlaintiff. Jeffrey Epstein directed Associate 2 to use force on Plaintiff even after \nPlaintiff stated that she was uncomfortable and did not want to participate in the \nsexual acts then underway. At one point during the encounter, Jeffrey Epstein put \nhis hands around Plaintiff's neck, which caused her a great deal of fear and \n16 \n3501.484-002 \nPage 16 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095922 \nEFTA01249996\n", "char_count": 1681}, {"efta_number": "EFTA01249981", "page_number": 16, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 17 of 52 \ndiscomfort. Jeffrey Epstein then masturbated and instructed Plaintiff to leave the \nroom. \n75. \nKnowing that Jeffrey Epstein and his associates had confiscated her \npassport to prevent her from having the ability to leave the Island voluntarily, \nPlaintiff feared for her safety and felt forced into engaging in these sexual acts \nagainst her will. \n76. \nIt was clear by this trip that Jeffrey Epstein was extremely powerful and \ncould cause serious harm to Plaintiff if she disobeyed. \n77. \nJeffrey Epstein learned in 2007 that \n78. \nPlaintiff and Epstein talked numerous times about the fact that Plaintiff \nwould only introduce him to her relative if he promised not to engage in any sexual \nconduct with her, to which Jeffrey Epstein agreed. \n79. \nJeffrey Epstein constantly reminded Plaintiff that he was going to help \nas a way to force Plaintiff to engage in commercial \nsex acts. \n80. \nWhile Plaintiff was giving sexual massages, Jeffrey Epstein would \nalways answer the phone if someone called. Important Business Person I, Important \nBusiness Person 2, Important Business Person 3, and Important Business Person 4 \n17 \n3501.484-002 \nPage 17 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095923 \nEFTA01249997\n", "char_count": 1318}, {"efta_number": "EFTA01249981", "page_number": 17, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/3.9 Page 18 of 52 \nwere regular callers and people with whom Jeffrey Epstein would have telephone \ncalls during sexual massages. Plaintiff does not want to reveal the identities of these \nindividuals out of fear of retaliation. \n81. \nThere were also times when Jeffrey Epstein, during sexual massages, \nwould be on the verge of ejaculating and would stop in order to make a phone call, \nat times saying that nearing sexual climax evoked certain important thoughts in \nJeffrey Epstein's mind. Jeffrey Epstein would then take or initiate up to four \nbusiness calls during any particular sexual massage. \n82. \nDuring these phone calls, Jeffrey Epstein would seem to be advising \nthe individuals he called in a very stern, authoritative voice. \n83. \nOn numerous calls, Plaintiff heard Jeffrey Epstein using a very angry \nand threatening tone and voice, making it known to the other party, and to Plaintiff, \nthat he had the ability to cause serious harm to powerful people and anyone who did \nnot cooperate with him. \n84. \nThe reasonable impression that Plaintiff had from overhearing his \nphone calls and listening to what he told her was that Jeffrey Epstein controlled very \npowerful and influential people and that disobeying him would cause serious \nrepercussions for the disobedient party. \n85. \nPlaintiff spent considerable time with Jeffrey Epstein and overheard \nmany conversation. In most, Jeffrey Epstein seemed to be advising other powerful \n18 \n3501.484-002 \nPage 18 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095924 \nEFTA01249998\n", "char_count": 1625}, {"efta_number": "EFTA01249981", "page_number": 18, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 19 of 52 \nindividuals in a business context. However, Important Business Person 1 was \nsomeone Jeffrey Epstein spoke to frequently, not only about business matters but \nalso about what appeared to be intimate personal matters. \nBased on the \nconversations she heard, and the manner and style of voice Epstein used, Plaintiff \nbelieved for many months that this person was a female. \n86. \nAs Jeffrey Epstein realized Plaintiff's vulnerabilities, he began \ncontrolling her even more to a point where she felt she had no choice but to engage \nin commercial sex acts without putting herself in serious danger. \n87. \nJeffrey Epstein would demand that Plaintiff massage him and if he went \nto sleep she was told she had to continue to massage him knowing that he would \nbecome very angry if he stopped. \n88. \nFrom 2006, when Jeffrey Epstein first forced himself on her \n, until 2012, he forced her to engage in commercial sex with him—sex \nfor money—including intercourse, regularly and consistently. At no time did he \ngive her a choice not to cooperate. \n89. \nDuring that time, Jeffrey Epstein controlled nearly every aspect of \nPlaintiff's life from the clothing and jewelry she was permitted to wear to the career \npath she was permitted to followed, to the food she was allowed to consumed. \n90. \nWhen Jeffrey Epstein went to jail for sex offenses in Florida, he \nmaintained contact with Plaintiff. He and employees of Defendant HBRK and \n19 \n3501.484-002 \nPage 19 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095925 \nEFTA01249999\n", "char_count": 1621}, {"efta_number": "EFTA01249981", "page_number": 19, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 20 of 52 \nDefendant NES and Defendant JEGE caused Plaintiff to be transported to Florida in \norder to engage in commercial sex with Jeffrey Epstein in his Florida residence while \non so-called \"work release\" from jail, while he was still wearing his ankle monitor. \n91. \nAfter Jeffrey Epstein was no longer in \"jail\" or on \"work release\" and \ncame back to New York, Plaintiff attempted to discontinue seeing Jeffrey Epstein. \nThis attempt angered Jeffrey Epstein. \n92. \nThere came a time when Plaintiff, on her own, took a trip to Montreal \nand Jeffrey Epstein immediately knew that she was gone from New York and \nsummoned her back to his New York Mansion. He told her she was not permitted \nto leave New York without his permission and that she was required at all time to \nremain in New York, on call to service his needs when told.. \n93. \nThis \"disciplining\" of Plaintiff in connection with her Montreal trip \ncaused Plaintiff great fear that if she failed to engage in commercial sex on the terms \nand conditions set by Epstein, he or the Corporate Defendants would cause her \nserious hann. \n94. \nJeffrey Epstein told Plaintiff to move into an apartment in a building he \nowned or controlled at 301 East 66 Street, which Plaintiff did. \n95. \nThere it became obvious to her that she was under constant \nsurveillance; that Jeffrey Epstein was able to monitor and know what she was doing \n20 \n3501.484-002 \nPage 20 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095926 \nEFTA01250000\n", "char_count": 1574}, {"efta_number": "EFTA01249981", "page_number": 20, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 21 of 52 \nin the apartment at all times, and that he was able to know and monitor where she \nwas going outside the apartment. \n96. \nPlaintiff, between 2006 and 2012, was trafficked to Jeffrey Epstein's \nIsland on Little Saint James on more than twenty occasions. On each occasion she \nwas forced to engage in commercial sex. \n97. \nOn one occasion on the Island, Plaintiff posted a publicly readable \nsocial media post indicating that she was on the island. The next morning, Jeffrey \nEpstein woke her while holding her wrists tightly. He was in a state of great anger. \nHis laptop computer was open. He began questioning her, stating, \"Why did you \nmake this post? Who has read it? What have you told them?\" At the end of the \nangry conversation, Jeffrey Epstein threatened Plaintiff and commanded her never \nto tell anyone about the commercial sex acts in which he was making Plaintiff \nengage, and never to tell her mother of her activities with Jeffrey Epstein. As \npunishment for the post she had made, Jeffrey Epstein did not speak with Plaintiff \nfor a month. \n98. \nJeffrey Epstein sent Plaintiff back to New York without paying her for \nany of the commercial sex acts she had engaged in with him on the island on a daily \nbasis over the course of approximately one week. \n99. \nPlaintiff, from that point forward in 2007, was in fear for her safety and \nher life and knew that strict compliance with the dictates of this very powerful man \n21 \n3501.484-002 \nPage 21 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095927 \nEFTA01250001\n", "char_count": 1629}, {"efta_number": "EFTA01249981", "page_number": 21, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 22 of 52 \nwas required as a condition of her maintaining her safety and her life. Epstein, in a \nshow of his anger and power, kicked Plaintiff out of her living quarters, essentially \nrendering her homeless overnight. At the same time, Epstein informed Plaintiff that \nshe was forbidden to tell anyone about him or the sexual activities he was engaging \nin with her. \n100. \nIn order to cause Plaintiff to continue to engage in commercial sexual \nactivity, Jeffrey Epstein made it known that he was close friends with other powerful \nand influential people. \n101. \nJeffrey Epstein commonly bragged to Plaintiff that Bill Clinton, Donald \nTrump, Prince Andrew, and the Sultan of Dubai were among his closest friends. \n102. \nPlaintiff overhead Jeffrey Epstein talking with the Sultan of Dubai and \non one occasion met him in person, supporting Jeffrey Epstein's statements that he \nwas closely associated with this and other powerful friends. \n103. \nPlaintiff observed photographs of Jeffrey Epstein and Bill Clinton \ntogether and heard Jeffrey Epstein talk about times when Clinton was on his private \nisland in Little Saint James. Plaintiff never saw Bill Clinton on the island. \n104. \nAs Plaintiff was trying to distance herself from Jeffrey Epstein, he \ncalled her into his massage room and warned her not to lie to him or there would be \nserious repercussions. He threatened her with these repercussions in order to cause \nher to continue to engage in commercial sex. Epstein worked with the people and \n22 \n3501.484-002 \nPage 22 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095928 \nEFTA01250002\n", "char_count": 1689}, {"efta_number": "EFTA01249981", "page_number": 22, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 23 of 52 \nresources of his vast enterprise, including Corporate Defendants, to ensure that \nPlaintiff would comply. \n105. \nOn one occasion, Jeffrey Epstein forced Plaintiff to serve hors \nd'oeuvres at Epstein's private party with Woody Allen. This server's role was \nforced upon Plaintiff in order to demean her, frighten her, and impress upon her the \nneed for her to conceal the commercial sex trafficking enterprise he was running. \n106. \nJeffrey Epstein constantly told Plaintiff that her opportunities were \nendless as long as she complied with his dictates but that he could take it all away \nfrom her if she did not. \n107. \nThere came a time when Jeffrey Epstein forced Plaintiff to give other \npowerful friends massages. During some of these massages she was sexually \nabused, by force, against her will, by the friends whom she had been required to \nmassage. \n108. \nPlaintiff, trying desperately to leave the proximity and influence of \nJeffrey Epstein, failed to show up for multiple appointments at his mansion. \nAssociate 1 contacted Plaintiff on behalf of Epstein and told her that Jeffrey Epstein \nwas very upset with Plaintiff's behavior. This warning caused Plaintiff to experience \nextreme fear and anxiety for her safety and her life. This fear and anxiety ultimately \nhad its intended effect and Plaintiff returned to Jefferey Epstein's mansion to \ncontinue to engage in commercial sex acts. \n23 \n3501.484-002 \nPage 23 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095929 \nEFTA01250003\n", "char_count": 1595}, {"efta_number": "EFTA01249981", "page_number": 23, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 24 of 52 \n109. \nJeffrey Epstein informed Plaintiff again that her career opportunities \nwere endless as long as she complied with his demands. \n110. \nJeffrey Epstein instructed Plaintiff in 2011 that he was putting her \nthrough massage school and she had no choice but to attend. \n111. \nWhile she was in massage school, Jeffrey Epstein constantly asked \nPlaintiff to recruit other young females from the massage school and became angry \nand threatening when she refused to do so. \n112. \nJeffrey Epstein forced Plaintiff to wear certain color panties, remove \ncertain body piercings, and undergo surgery by Jeffrey Epstein's doctors to remove \nbody moles. Plaintiff complied with these demands with the understanding, \nconveyed to her by Epstein, that she had no other choice. . \n113. \nFrom 2006 through 2012, Jeffrey Epstein and his associates and \nemployees recruited, enticed, harbored, transported, provided, obtained, maintained, \nand solicited Plaintiff knowing that force, threat of force, fraud or coercion would \nbe used to compel Plaintiff to engage in commercial sex acts. \n114. \nThe commercial sex acts included intercourse, the use of sex toys \ninserted inside Plaintiff, digital penetration, forcible touching and many other sexual \nacts. \n115. \nPlaintiff was made to engage in commercial sex acts in New York every \nyear from 2006 to 2012 (except for a brief period of time in late 2008 through 2009 \n24 \n3501.484-002 \nPage 24 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095930 \nEFTA01250004\n", "char_count": 1598}, {"efta_number": "EFTA01249981", "page_number": 24, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 25 of 52 \nduring which time Jeffrey Epstein was technically in jail in Florida); in the United \nStates Virgin Islands from 2006 to 2012 (except, again, during a brief period of time \nduring which Jeffrey Epstein was technically in jail in Florida); in Florida from 2007 \nto 2012 (including, as noted, sexual activity while Jeffrey Epstein wore his ankle \nbracelet); and in in New Mexico between 2007 and 2010. \n116. \nThere were sexual acts in addition to those described above which \nacts are too graphic and perverted to detail in the complaint. Each and all of such \nacts were required by Jeffrey Epstein and his Corporate Defendants, all of whom \nworked together to cause Plaintiff to engage in such acts, including Defendants' \ninforming her that if she refused to engage in such acts she would suffer serious \nharm. \n117. \nIn order to maintain Plaintiff's compliance, Defendant Jeffrey Epstein \nalso informed Plaintiff that he would use his vast resources to get Plaintiff's relative \nthe serious medical care she needed, further enticing Plaintiff through fraud to \nengage in commercial sex acts. \n118. \nMultiple associates, employees, and corporate entities assisted \nDefendants in causing Plaintiff to engage in commercial sex acts knowing fraud \nwould be used to cause her to continue to engage in such acts. This assistance \nincluded making promises, scheduling medical appointments or promising to \nschedule medical appointments, promising medical care to Plaintiff's close relative, \n25 \n3501.484-002 \nPage 25 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095931 \nEFTA01250005\n", "char_count": 1679}, {"efta_number": "EFTA01249981", "page_number": 25, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 26 of 52 \nand otherwise making representations about Epstein's ability to secure medical \ntreatment for Plaintiff all while knowing that these representations were false and \nfraudulent and designed to entice and induce Plaintiff to commit commercial sex \nacts for Jeffrey Epstein. \n119. \nIn order to cause Plaintiff to engage in each commercial sex act, Epstein \nand his co-conspirators, associates, employees and related corporate entities, \nincluding Corporate Defendants, used coercion, and knew that coercion would be \nused, in order to cause Plaintiff to engage in such acts. \n120. \nEpstein and various associates, employees, and related corporations and \nemployees, including Corporate Defendants, worked in concert together as an \nenterprise with extraordinary power, wealth, and resources capable of affecting \nPlaintiff's life in positive or negative ways depending on her level of cooperation, \nall while knowingly conveying these promises and threats to Plaintiff. \n121. \nEpstein and others associated with Epstein, including employees of \nDefendant HBRK, bragged about Epstein's unusual political and powerful \nconnections and his ability to obtain education, housing, or medical needs for young \nfemales who cooperated with Epstein's sexual demands. \n122. \nIn addition to being explicitly reminded by Epstein, or one of his \nassociates, of his extraordinary power to reward and punish Plaintiff, his power to \ndo so was apparent to Plaintiff, inasmuch as: (I) she visited Epstein many times at \n26 \n3501.484-002 \nPage 26 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095932 \nEFTA01250006\n", "char_count": 1692}, {"efta_number": "EFTA01249981", "page_number": 26, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 27 of 52 \nhis New York mansion, located at 9 East 71 Street, New York, New York, where \nshe knew that Jeffrey Epstein when in New York (The mansion was owned by \nDefendant, Nine East 71st Street, Corporation, from 1989 to 2011 until it was deeded \nto Defendant, Maple, Inc., on December 23, 2011, the entity that maintains lawful \npossession today); (2) she flew on the Boeing 747 jet owned by Defendant, JEGE, \nInc., and controlled by Jeffrey Epstein and related companies; (3) she visited his \nFlorida Mansion located at 358 Brillo Way, Palm Beach, Florida owned by Jeffrey \nE. Epstein from 1990 through December 23, 2011; and (4) she visited his private \nIsland in the United States Virgin Islands, located at No. 6B Red Hook Quarter, U.S. \nVirgin Islands, previously owned by Defendant L.S.J., LLC prior to its having been \ndeeded to Nautilus, Inc., a United States Virgin Islands corporation, on December \n23, 2011. \n123. \nUnder Epstein's control were numerous companies with many \nemployees and obvious resources, each of whom worked for the Epstein enterprise. \nWhile the individuals were employees of various Epstein related companies, \nincluding Defendant Corporations, it was clear through explicit words, actions and \nappearances that all such employees acted at Epstein's direction and for his \nprotection. \nThis team of individuals included chefs, butlers, receptionists, \nschedulers, secretaries, flight attendants, pilots, housekeepers, maids, sex recruiters, \ndrivers and other staff members. \n27 \n3501.484-002 \nPage 27 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095933 \nEFTA01250007\n", "char_count": 1693}, {"efta_number": "EFTA01249981", "page_number": 27, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 28 of 52 \n124. \nEach of the employees and associates were paid through companies \nbelieved to have been funded by Jeffrey Epstein and, regardless of such funding, \nwere disciples of Jeffrey Epstein, constantly informing Plaintiff and other victims of \nJeffrey Epstein's power and ability to improve or destroy a victim's life depending \non her level of cooperation. \n125. \nThe main and in many instances only function of each of the associates \nwho acted at the instruction or direction of Epstein was to recruit, entice, harbor, \ntransport, provide, obtain, maintain, or solicit young females, knowing that fraud or \ncoercion would be used to cause each female, including Plaintiff, to engage in a \ncommercial sex act. \n126. \nEach such associate described above was also employed to perform \nfunctions in order to avoid detection of the illegality of Epstein's commercial sex \ntrafficking and to forever conceal the enterprise. \n127. \nOne significant element of the sex trafficking scheme—a scheme used \nto compel commercial sex acts of young females, including Plaintiff—was its design \nand effort to avoid detection. This concealment was furthered by the enterprise's \ndesign, actions, and patterns of behavior which caused Plaintiff and others similarly \nsituated to believe that failure to perform acts required by the scheme would result \nin serious psychological, financial, or reputational harm. \n28 \n3501.484-002 \nPage 28 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095934 \nEFTA01250008\n", "char_count": 1588}, {"efta_number": "EFTA01249981", "page_number": 28, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 29 of 52 \n128. \nThe scheme included frequent statements to Plaintiff and other victims \nby Jeffrey Epstein and his associates, including employees of Defendant HBRK, \nthat: (1) Jeffery Epstein was of extraordinary wealth, power and influence; (2) \nJeffrey Epstein's business and political friends, including world leaders, included \nsome of the most powerful people in the world; (3) the scheme or plan was designed \nto constantly grow the number of victims through the recruitment of other victims; \n(4) Jeffrey Epstein had the ability to advance or destroy nearly anyone financially, \nreputationally, or otherwise; (5) medical and normal life necessities would be denied \nvictims if they, including Plaintiff, failed to perform commercial sex acts for Epstein; \nand (6) Epstein could take away Plaintiff's and other victims' life needs such as \nshelter or housing if she or they failed to perform those acts. \n129. \nJeffrey Epstein bragged about knowing some of the world's most \npowerful people; introduced some of them to Plaintiff; and required Plaintiff to \nperform sexual massages on some of them. These circumstances caused Plaintiff to \nbelieve that Jeffrey Epstein and his organization was powerful enough to cause her \nserious harm if she did not strictly follow his and their demands. \nCOUNT I \nBATTERY AGAINST DARREN K. INDYKE AND RICHARD D. KAHN AS \nJOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY \nE. EPSTEIN \n130. \nThe Plaintiff adopts and realleges paragraphs 1 through 129 above. \n29 \n3501.484-002 \nPage 29 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095935 \nEFTA01250009\n", "char_count": 1690}, {"efta_number": "EFTA01249981", "page_number": 29, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 30 of 52 \n131. \nJeffrey Epstein committed a harmful or offensive touching against \nPlaintiff. \n132. \nAs a direct and proximate result of Jeffrey Epstein's battery, the \nPlaintiff has in the past suffered and in the future will continue to suffer physical \ninjury, pain, emotional distress, psychological trauma, mental anguish, humiliation, \nembarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and a \nloss of her capacity to enjoy life, as well as other damages. Plaintiff incurred medical \nand psychological expenses and Plaintiff will in the future suffer additional medical \nand psychological expenses. These injuries are permanent in nature and Plaintiff \nwill continue to suffer these losses in the future. \nWHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. \nEpstein for compensatory and general damages, attorney's fees, punitive damages \nand such other and further relief as this Court deems just and proper. Plaintiff hereby \ndemands trial by jury on all issues triable as of right by a jury. \nCOUNT II \nBATTERY/VIOLATION OF SECTION 130 \nAGAINST DARREN K. INDYICE AND RICHARD D. KAHN AS JOINT \nPERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E. \nEPSTEIN \n133. \nThe Plaimiff adopts and realleges paragraphs 1 through I29 above. \n30 \n3501.484-002 \nPage 30 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095936 \nEFTA01250010\n", "char_count": 1467}, {"efta_number": "EFTA01249981", "page_number": 30, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 31 of 52 \n134. \nThe intentional acts of Jeffrey Epstein against Plaintiff constitute a \nsexual offense as defined in New York Penal Law § 130, including but not limited \nto the following: \na. Sexual misconduct as defined in §130.20 inasmuch as Jeffrey Epstein \nengaged in sexual intercourse with Plaintiff without Plaintiff's consent; \nb. Rape in the first degree as defined in §130.35 inasmuch as Jeffrey \nEpstein engaged in sexual intercourse with Plaintiff by forcible \ncompulsion; \nc. Criminal sexual act in the first degree as defined in §130.50 inasmuch \nas Jeffrey Epstein engaged in oral sexual conduct with Plaintiff by \nforcible compulsion; \nd. Forcible touching as defined in §130.52 inasmuch as Jeffrey Epstein, \nintentionally and for no legitimate purpose, engaged the forcible sexual \ntouching of Plaintiff for the purpose of degrading or abusing her or for \nthe purpose of gratifying his own sexual desire; and \ne. Sexual abuse in the third degree as defined in §130.66 inasmuch as \nJeffrey Epstein inserted a foreign object in the vagina of Plaintiff by \nforcible compulsion. \n135. \nAs a direct and proximate result of Jeffrey Epstein's violation of New \nYork Penal Law § 130, the Plaintiff has in the past suffered and in the future will \ncontinue to suffer physical injury, pain, emotional distress, psychological trauma, \nmental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, \ninvasion of her privacy and a loss of her capacity to enjoy life, as well as other \ndamages. Plaintiff incurred medical and psychological expenses and Plaintiff will \n31 \n3501.484-002 \nPage 31 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095937 \nEFTA01250011\n", "char_count": 1774}, {"efta_number": "EFTA01249981", "page_number": 31, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 32 of 52 \nin the future suffer additional medical and psychological expenses. These injuries \nare permanent in nature and Plaintiff will continue to suffer these losses in the future. \nWHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. \nEpstein for compensatory and general damages, attorney's fees, punitive damages \nand such other and further relief as this Court deems just and proper. Plaintiff hereby \ndemands trial by jury on all issues triable as of right by a jury. \nCOUNT III \nCAUSE OF ACTION AGAINST DARREN K. 'NOVICE AND RICHARD D. \nKAHN AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF \nJEFFREY E. EPSTEIN PURSUANT TO 18 U.S.C. 1595 \n136. \nPlaintiff adopts and realleges paragraphs 1 through 129 above. \n137. \nJeffrey Epstein, within the special maritime and territorial jurisdiction \nof the United States, in interstate and foreign commerce, and/or affecting interstate \nand foreign commerce, knowingly recruited, enticed, harbored, transported, \nprovided, obtained, maintained, patronized, solicited, threatened, forced, or coerced \nPlaintiff to engage in commercial sex acts. \n138. \nSuch actions were undertaken knowing that his use of force, threats of \nforce, fraud, coercion, and/or combinations of such means would be used, and were \nin fact used, in order to cause Plaintiff to engage in commercial sex acts. In doing \nso, Jeffrey Epstein violated 18 U.S.C. *1591. \n139. \nFurthermore, Jeffrey Epstein attempted to violate 18 U.S.C. § 1591. In \nso doing, violated 18 U.S.C. § 1594(a). \n32 \n3501.484-002 \nPage 32 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095938 \nEFTA01250012\n", "char_count": 1710}, {"efta_number": "EFTA01249981", "page_number": 32, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 3. Filed 08/20/19 Page 33 of 52 \n140. \nJeffrey Epstein conspired with each member of the enterprise, and with \nother persons known and unknown, to violate 18 U.S.C. § 1591. In so doing, \nviolated 18 U.S.C. § 1594(c). \n141. \nAdditionally, Defendants conspired with each other, and with other \npersons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants \nviolated 18 U.S.C. § 1594(b). \n142. \nBy virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, \n1593A, and 1594, Defendant Darren K. Indyke and Richard D. Kahn as Joint \nPersonal Representatives of the Estate of Jeffrey E. Epstein is subject to civil causes \nof action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of the violations. \n143. \nCertain property of Epstein's was essential to the commission of the \nfederal crimes and torts described herein, including the use of multiple private \naircraft including a Boeing aircraft (of make and model B-727-31H with tail number \nN908JE) and a Gulfstream aircraft (of make and model G-1159B with tail number \nN909JE). Such aircraft, along with other of Jeffrey Epstein's property, were used \nas means and instruments of Jeffrey Epstein's tortious and criminal offenses and, as \nsuch, are subject to forfeiture. \n144. \nAdditionally, Jeffrey Epstein's New York mansion, located at 9 East \n71st Street, New York, New York, in the Southern District of New York, and his \nprivate island located in the United States Virgin Islands, were used as means and \n33 \n3501.484-002 \nPage 33 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095939 \nEFTA01250013\n", "char_count": 1651}, {"efta_number": "EFTA01249981", "page_number": 33, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 34 of 52 \ninstruments of Jeffrey Epstein's tortious and criminal offenses and, as such, are \nsubject to forfeiture. \n145. \nAs a direct and proximate result of Jeffrey Epstein's commission of the \naforementioned criminal offenses enumerated in 18 U.S.C. § 1591, 1593A, and \n1594, and the associated civil remedies provided in § 1595, Plaintiff has in the past \nsuffered and will continue to suffer injury and pain; emotional distress; \npsychological and psychiatric trauma; mental anguish; humiliation; confusion; \nembarrassment; loss of self-esteem; loss of dignity; loss of enjoyment of life; \ninvasion of privacy; and other damages associated with' actions. Plaintiff will incur \nfurther medical and psychological expenses. These injuries are permanent in nature \nand Plaintiff will continue to suffer from them in the future. In addition to these \nlosses, Plaintiff has incurred attorneys' fees and will be required do so in the future. \nWHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. \nEpstein for compensatory and general damages, attorney's fees, punitive damages \nand such other and further relief as this Court deems just and proper. Plaintiff hereby \ndemands trial by jury on all issues triable as of right by a jury. \nCOUNT IV \nCAUSE OF ACTION AGAINST \nNINE EAST 71ST STREET. CORPROATION \nPURSUANT TO 18 U.S.C. § 1595 \n146. \nPlaintiff adopts and realleges paragraphs 1 through 129 above. \n34 \n3501.484-002 \nPage 34 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095940 \nEFTA01250014\n", "char_count": 1605}, {"efta_number": "EFTA01249981", "page_number": 34, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 35 of 52 \n147. \nDefendant, by and through its management and personnel, within the \nspecial maritime and territorial jurisdiction of the United States, in interstate and \nforeign commerce, and/or affecting interstate and foreign commerce, knowingly \nrecruited, enticed, harbored, transported, provided, obtained, maintained, \npatronized, solicited by any means Plaintiff from 2006 through 2011. \n148. \nDefendant, by and through its management and personnel, knew that \nmeans of fraud or coercion, and/or combinations of such means, would be used, and \nwere in fact used, in order to cause Plaintiff to engage in commercial sex acts. In \ndoing so, Defendant corporation violated 18 U.S.C. §1591. \n149. \nFurthermore, Defendant corporation attempted to violate 18 U.S.C. § \n1591. In so doing, violated 18 U.S.C. § 1594(a). \n150. \nDefendant, by and through its management and personnel, conspired \nwith other members of the enterprise, and with other persons and companies, known \nand unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 \nU.S.C. § 1594(c). \n151. \nAdditionally, Defendants conspired with each other, and with other \npersons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants \nviolated 18 U.S.C. § 1594(b). \n35 \n3501.484-002 \nPage 35 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095941 \nEFTA01250015\n", "char_count": 1443}, {"efta_number": "EFTA01249981", "page_number": 35, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 36 of 52 \n152. \nBy virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, \n1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. § \n1595 by Plaintiff, who is a victim of the violations. \n153. \nDefendant, by and through its management and personnel, participated \nin a venture with Jeffrey Epstein's enterprise by knowingly recruiting, transporting, \nsoliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would \nbe used to cause Plaintiff to commit a commercial sex act. \n154. \nAs a direct and proximate result of Defendant corporation's \ncommission of the aforementioned criminal offenses enumerated in 18 U.S.C. § \n1591, 1593A, and 1594, and the associated civil remedies provided in § 1595, \nPlaintiff has in the past suffered and will continue to suffer injury and pain; \nemotional distress; psychological and psychiatric trauma; mental anguish; \nhumiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of \nenjoyment of life; invasion of privacy; and other damages associated with' actions. \nPlaintiff will incur further medical and psychological expenses. These injuries are \npermanent in nature and Plaintiff will continue to suffer from them in the future. In \naddition to these losses, Plaintiff has incurred attorneys' fees and will be required do \nso in the future. \nWHEREFORE, Plaintiff demands judgment against Nine East 71st Street, \nCorporation for compensatory and general damages, attorney's fees, punitive \n36 \n3501.484-002 \nPage 36 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095942 \nEFTA01250016\n", "char_count": 1696}, {"efta_number": "EFTA01249981", "page_number": 36, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 37 of 52 \ndamages and such other and further relief as this Court deems just and proper. \nPlaintiff hereby demands trial by jury on all issues triable as of right by a jury. \nCOUNT V \nCAUSE OF ACTION AGAINST MAPLE, INC. \nPURSUANT TO 18 U.S.C. & 1595 \n155. \nPlaintiff adopts and realleges paragraphs 1 through 129 above. \n156. \nDefendant, by and through its management and personnel, within the \nspecial maritime and territorial jurisdiction of the United States, in interstate and \nforeign commerce, and/or affecting interstate and foreign commerce, knowingly \nrecruited, enticed, harbored, transported, provided, obtained, maintained, \npatronized, solicited by any means Plaintiff beginning in 2011. \n157. \nDefendant, by and through its management and personnel, knew that \nmeans of fraud or coercion, and/or combinations of such means, would be used, and \nwere in fact used, in order to cause Plaintiff to engage in commercial sex acts. In \ndoing so, Defendant corporation violated 18 U.S.C. §1591. \n158. \nDefendant, by and through its management and personnel knowingly \nbenefitted, financially and by receiving things of value, from participating in a \nventure (the Epstein sex trafficking venture enterprise) which had engaged in acts in \nviolation of 18 U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in \nsuch violations. In so doing, Defendant corporation violated 18 U.S.C. § 1593A. \n37 \n3501.484-002 \nPage 37 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095943 \nEFTA01250017\n", "char_count": 1592}, {"efta_number": "EFTA01249981", "page_number": 37, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 38 of 52 \n159. \nFurthermore, Defendant corporation attempted to violate 18 U.S.C. § \n1591. In so doing, violated 18 U.S.C. § 1594(a). \n160. \nDefendant, by and through its management and personnel, conspired \nwith other members of the enterprise, and with other persons and companies, known \nand unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 \nU.S.C. § 1594(c). \n161. \nAdditionally, Defendants conspired with each other, and with other \npersons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants \nviolated 18 U.S.C. § 1594(b). \n162. \nBy virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, \n1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. § \n1595 by Plaintiff, who is a victim of the violations. \n163. \nDefendant, by and through its management and personnel, participated \nin a venture with Jeffrey Epstein's enterprise by knowingly recruiting, transporting, \nsoliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would \nbe used to cause Plaintiff to commit a commercial sex act. \n164. \nAs a direct and proximate result of Defendant corporation's \ncommission of the aforementioned criminal offenses enumerated in 18 U.S.C. § \n1591, 1593A, and 1594, and the associated civil remedies provided in § 1595, \nPlaintiff has in the past suffered and will continue to suffer injury and pain; \n38 \n3501.484-002 \nPage 38 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095944 \nEFTA01250018\n", "char_count": 1586}, {"efta_number": "EFTA01249981", "page_number": 38, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 39 of 52 \nemotional distress; psychological and psychiatric trauma; mental anguish; \nhumiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of \nenjoyment of life; invasion of privacy; and other damages associated with ' actions. \nPlaintiff will incur further medical and psychological expenses. These injuries are \npermanent in nature and Plaintiff will continue to suffer from them in the future. In \naddition to these losses, Plaintiff has incurred attorneys' fees and will be required do \nso in the future. \nWHEREFORE, Plaintiff demands judgment against Defendant, MAPLE, \nINC., for compensatory and general damages, attorney's fees, punitive damages and \nsuch other and further relief as this Court deems just and proper. Plaintiff hereby \ndemands trial by jury on all issues triable as of right by a jury. \nCOUNT VI \nCAUSE OF ACTION AGAINST L.S.J., LLC \nPURSUANT TO 18 U.S.C. § 1595 \n165. \nPlaintiff adopts and realleges paragraphs 1 through 129 above. \n166. \nDefendant, by and through its management and personnel, within the \nspecial maritime and territorial jurisdiction of the United States, in interstate and \nforeign commerce, and/or affecting interstate and foreign commerce, knowingly \nrecruited, enticed, harbored, transported, provided, obtained, maintained, \npatronized, solicited by any means Plaintiff. \n39 \n3501.484-002 \nPage 39 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095945 \nEFTA01250019\n", "char_count": 1532}, {"efta_number": "EFTA01249981", "page_number": 39, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 40 of 52 \n167. \nDefendant, by and through its management and personnel, knew that \nmeans of fraud or coercion, and/or combinations of such means, would be used, and \nwere in fact used, in order to cause Plaintiff to engage in commercial sex acts. In \ndoing so, Defendant corporation violated 18 U.S.C. §1591. \n168. \nDefendant, by and through its management and personnel knowingly \nbenefitted, financially and by receiving things of value, from participating in a \nventure (the Epstein sex trafficking venture enterprise) which had engaged in acts in \nviolation of 18 U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in \nsuch violations. In so doing, Defendant corporation violated 18 U.S.C. § 1593A. \n169. \nFurthermore, Defendant corporation attempted to violate 18 U.S.C. § \n1591. In so doing, violated 18 U.S.C. § 1594(a). \n170. \nDefendant, by and through its management and personnel, conspired \nwith other members of the enterprise, and with other persons and companies, known \nand unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 \nU.S.C. § 1594(c). \n171. \nAdditionally, Defendants conspired with each other, and with other \npersons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants \nviolated 18 U.S.C. § 1594(b). \n40 \n3501.484-002 \nPage 40 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095946 \nEFTA01250020\n", "char_count": 1464}, {"efta_number": "EFTA01249981", "page_number": 40, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 41 of 52 \n172. \nBy virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, \n1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. § \n1595 by Plaintiff, who is a victim of the violations. \n173. \nDefendant, by and through its management and personnel, participated \nin a venture with Jeffrey Epstein's enterprise by knowingly recruiting, transporting, \nsoliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would \nbe used to cause Plaintiff to commit a commercial sex act. \n174. \nAs a direct and proximate result of Defendant corporation's \ncommission of the aforementioned criminal offenses enumerated in 18 U.S.C. § \n1591, 1593A, and 1594, and the associated civil remedies provided in § 1595, \nPlaintiff has in the past suffered and will continue to suffer injury and pain; \nemotional distress; psychological and psychiatric trauma; mental anguish; \nhumiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of \nenjoyment of life; invasion of privacy; and other damages associated with ' actions. \nPlaintiff will incur further medical and psychological expenses. These injuries are \npermanent in nature and Plaintiff will continue to suffer from them in the future. In \naddition to these losses, Plaintiff has incurred attorneys' fees and will be required do \nso in the future. \nWHEREFORE, Plaintiff demands judgment against Defendant, Maple, Inc., \nfor compensatory and general damages, attorney's fees, punitive damages and such \n41 \n3501.484-002 \nPage 41 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095947 \nEFTA01250021\n", "char_count": 1703}, {"efta_number": "EFTA01249981", "page_number": 41, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 42 of 52 \nother and further relief as this Court deems just and proper. Plaintiff hereby demands \ntrial by jury on all issues triable as of right by a jury. \nCOUNT VII \nCAUSE OF ACTION AGAINST \nFINANCIAL TRUST COMPANY. INC. \nPURSUANT TO 18 U.S.C. & 1595 \n175. \nPlaintiff adopts and realleges paragraphs 1 through 129 above. \n176. \nDefendant, by and through its management and personnel, within the \nspecial maritime and territorial jurisdiction of the United States, in interstate and \nforeign commerce, and/or affecting interstate and foreign commerce, knowingly \nrecruited, enticed, harbored, transported, provided, obtained, maintained, \npatronized, solicited by any means Plaintiff. \n177. \nDefendant, by and through its management and personnel, knew that \nmeans of fraud or coercion, and/or combinations of such means, would be used, and \nwere in fact used, in order to cause Plaintiff to engage in commercial sex acts. In \ndoing so, Defendant corporation violated 18 U.S.C. §1591. \n178. \nDefendant, by and through its management and personnel knowingly \nbenefitted, financially and by receiving things of value, from participating in a \nventure (the Epstein sex trafficking venture enterprise) which had engaged in acts in \nviolation of 18 U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in \nsuch violations. In so doing, Defendant corporation violated 18 U.S.C. § 1593A. \n42 \n3501.484-002 \nPage 42 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095948 \nEFTA01250022\n", "char_count": 1578}, {"efta_number": "EFTA01249981", "page_number": 42, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 43 of 52 \n179. \nFurthermore, Defendant corporation attempted to violate 18 U.S.C. § \n1591. In so doing, violated 18 U.S.C. § 1594(a). \n180. \nDefendant, by and through its management and personnel, conspired \nwith other members of the enterprise, and with other persons and companies, known \nand unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 \nU.S.C. § 1594(c). \n181. \nAdditionally, Defendants conspired with each other, and with other \npersons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants \nviolated 18 U.S.C. § 1594(b). \n182. \nBy virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, \n1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. § \n1595 by Plaintiff, who is a victim of the violations. \n183. \nDefendant, by and through its management and personnel, participated \nin a venture with Jeffrey Epstein's enterprise by knowingly recruiting, transporting, \nsoliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would \nbe used to cause Plaintiff to commit a commercial sex act. \n184. \nAs a direct and proximate result of Defendant corporation's \ncommission of the aforementioned criminal offenses enumerated in 18 U.S.C. § \n1591, 1593A, and 1594, and the associated civil remedies provided in § 1595, \nPlaintiff has in the past suffered and will continue to suffer injury and pain; \n43 \n3501.484-002 \nPage 43 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095949 \nEFTA01250023\n", "char_count": 1586}, {"efta_number": "EFTA01249981", "page_number": 43, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 44 of 52 \nemotional distress; psychological and psychiatric trauma; mental anguish; \nhumiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of \nenjoyment of life; invasion of privacy; and other damages associated with ' actions. \nPlaintiff will incur further medical and psychological expenses. These injuries are \npermanent in nature and Plaintiff will continue to suffer from them in the future. In \naddition to these losses, Plaintiff has incurred attorneys' fees and will be required do \nso in the future. \nWHEREFORE, Plaintiff demands judgment against Defendant, Financial \nTrust Company, Inc., For compensatory and general damages, attorney's fees, \npunitive damages and such other and further relief as this Court deems just and \nproper. Plaintiff hereby demands trial by jury on all issues triable as of right by a \nju►'y \nCOUNT VIII \nCAUSE OF ACTION AGAINST NES. LLC \nPURSUANT TO 18 U.S.C. 6 1595 \n185. \nPlaintiff adopts and realleges paragraphs I through 129 above. \n186. \nDefendant, by and through its management and personnel, within the \nspecial maritime and territorial jurisdiction of the United States, in interstate and \nforeign commerce, and/or affecting interstate and foreign commerce, knowingly \nrecruited, enticed, harbored, transported, provided, obtained, maintained, \npatronized, solicited by any means Plaintiff. \n44 \n3501.484-002 \nPage 44 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095950 \nEFTA01250024\n", "char_count": 1550}, {"efta_number": "EFTA01249981", "page_number": 44, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 45 of 52 \n187. \nDefendant, by and through its management and personnel, knew that \nmeans of fraud or coercion, and/or combinations of such means, would be used, and \nwere in fact used, in order to cause Plaintiff to engage in commercial sex acts. In \ndoing so, Defendant corporation violated 18 U.S.C. §1591. \n188. \nFurthermore, Defendant corporation attempted to violate 18 U.S.C. § \n1591. In so doing, violated 18 U.S.C. § 1594(a). \n189. \nDefendant, by and through its management and personnel, conspired \nwith other members of the enterprise, and with other persons and companies, known \nand unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 \nU.S.C. § 1594(c). \n190. \nAdditionally, Defendants conspired with each other, and with other \npersons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants \nviolated 18 U.S.C. § I 594(b). \n191. \nBy virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, \n1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. § \n1595 by Plaintiff, who is a victim of the violations. \n192. \nDefendant, by and through its management and personnel, participated \nin a venture with Jeffrey Epstein's enterprise by knowingly recruiting, transporting, \nsoliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would \nbe used to cause Plaintiff to commit a commercial sex act. \n45 \n3501.484-002 \nPage 45 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095951 \nEFTA01250025\n", "char_count": 1583}, {"efta_number": "EFTA01249981", "page_number": 45, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 46 of 52 \n193. \nAs a direct and proximate result of Defendant corporation's \ncommission of the aforementioned criminal offenses enumerated in 18 U.S.C. § \n1591, 1593A, and 1594, and the associated civil remedies provided in § 1595, \nPlaintiff has in the past suffered and will continue to suffer injury and pain; \nemotional distress; psychological and psychiatric trauma; mental anguish; \nhumiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of \nenjoyment of life; invasion of privacy; and other damages associated with' actions. \nPlaintiff will incur further medical and psychological expenses. These injuries are \npermanent in nature and Plaintiff will continue to suffer from them in the future. In \naddition to these losses, Plaintiff has incurred attorneys' fees and will be required do \nso in the future. \nWHEREFORE, Plaintiff demands judgment against Defendant, NES, Inc., for \ncompensatory and general damages, attorney's fees, punitive damages and such \nother and further relief as this Court deems just and proper. Plaintiff hereby demands \ntrial by jury on all issues triable as of right by a jury. \nCOUNT IX \nCAUSE OF ACTION AGAINST \nHBRK ASSOCIATES. INC. PURSUANT TO 18 U.S.C. & 1595 \n194. \nPlaintiff adopts and realleges paragraphs 1 through 129 above. \n195. \nDefendant, by and through its management and personnel, within the \nspecial maritime and territorial jurisdiction of the United States, in interstate and \n46 \n3501.484-002 \nPage 46 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095952 \nEFTA01250026\n", "char_count": 1641}, {"efta_number": "EFTA01249981", "page_number": 46, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 47 of 52 \nforeign commerce, and/or affecting interstate and foreign commerce, knowingly \nrecruited, enticed, harbored, transported, provided, obtained, maintained, \npatronized, solicited by any means Plaintiff. \n196. \nDefendant, by and through its management and personnel, knew that \nmeans of fraud or coercion, and/or combinations of such means, would be used, and \nwere in fact used, in order to cause Plaintiff to engage in commercial sex acts. In \ndoing so, Defendant corporation violated 18 U.S.C. §1591. \n197. \nDefendant, by and through its management and personnel knowingly \nbenefitted, financially and by receiving things of value, from participating in a \nventure (the Epstein sex trafficking venture enterprise) which had engaged in acts in \nviolation of 18 U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in \nsuch violations. In so doing, Defendant corporation violated 18 U.S.C. § 1593A. \n198. \nFurthermore, Defendant corporation attempted to violate 18 U.S.C. § \n1591. In so doing, violated 18 U.S.C. § 1594(a). \n199. \nDefendant, by and through its management and personnel, conspired \nwith other members of the enterprise, and with other persons and companies, known \nand unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 \nU.S.C. § 1594(c). \n47 \n3501.484-002 \nPage 47 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095953 \nEFTA01250027\n", "char_count": 1480}, {"efta_number": "EFTA01249981", "page_number": 47, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 48 of 52 \n200. \nAdditionally, Defendants conspired with each other, and with other \npersons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants \nviolated 18 U.S.C. § 1594(b). \n201. \nBy virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, \n1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. § \n1595 by Plaintiff, who is a victim of the violations. \n202. \nDefendant, by and through its management and personnel, participated \nin a venture with Jeffrey Epstein's enterprise by knowingly recruiting, transporting, \nsoliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would \nbe used to cause Plaintiff to commit a commercial sex act. \n203. \nAs a direct and proximate result of Defendant corporation's \ncommission of the aforementioned criminal offenses enumerated in 18 U.S.C. § \n1591, 1593A, and 1594, and the associated civil remedies provided in § 1595, \nPlaintiff has in the past suffered and will continue to suffer injury and pain; \nemotional distress; psychological and psychiatric trauma; mental anguish; \nhumiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of \nenjoyment of life; invasion of privacy; and other damages associated with ' actions. \nPlaintiff will incur further medical and psychological expenses. These injuries are \npermanent in nature and Plaintiff will continue to suffer from them in the future. In \n48 \n3501.484-002 \nPage 48 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095954 \nEFTA01250028\n", "char_count": 1627}, {"efta_number": "EFTA01249981", "page_number": 48, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 49 of 52 \naddition to these losses, Plaintiff has incurred attorneys' fees and will be required do \nso in the future. \nWHEREFORE, Plaintiff demands judgment against Defendant, HBRK \nAssociates, Inc., for compensatory and general damages, attorney's fees, punitive \ndamages and such other and further relief as this Court deems just and proper. \nPlaintiff hereby demands trial by jury on all issues triable as of right by a jury. \nCOUNT X \nCAUSE OF ACTION AGAINST JEGE. INC. \nPURSUANT TO 18 U.S.C. & 1595 \n204. \nPlaintiff adopts and realleges paragraphs I through 129 above. \n205. \nDefendant, by and through its management and personnel, within the \nspecial maritime and territorial jurisdiction of the United States, in interstate and \nforeign commerce, and/or affecting interstate and foreign commerce, knowingly \nrecruited, enticed, harbored, transported, provided, \npatronized, solicited by any means Plaintiff. \n206. \nDefendant, by and through its management and personnel, knew that \nmeans of fraud or coercion, and/or combinations of such means, would be used, and \nwere in fact used, in order to cause Plaintiff to engage in commercial sex acts. In \ndoing so, Defendant corporation violated 18 U.S.C. §1591. \n207. \nDefendant, by and through its management and personnel knowingly \nbenefitted, financially and by receiving things of value, from participating in a \n49 \nobtained, maintained, \n3501.484-002 \nPage 49 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095955 \nEFTA01250029\n", "char_count": 1577}, {"efta_number": "EFTA01249981", "page_number": 49, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 50 of 52 \nventure (the Epstein sex trafficking venture enterprise) which had engaged in acts in \nviolation of 18 U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in \nsuch violations. In so doing, Defendant corporation violated 18 U.S.C. § 1593A. \n208. \nFurthermore, Defendant corporation attempted to violate 18 U.S.C. § \n1591. In so doing, violated 18 U.S.C. § 1594(a). \n209. \nDefendant, by and through its management and personnel, conspired \nwith other members of the enterprise, and with other persons and companies, known \nand unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 \nU.S.C. § 1594(c). \n210. \nAdditionally, Defendants conspired with each other, and with other \npersons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants \nviolated 18 U.S.C. § 1594(b). \n211. \nBy virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, \n1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. § \n1595 by Plaintiff, who is a victim of the violations. \n212. \nDefendant, by and through its management and personnel, participated \nin a venture with Jeffrey Epstein's enterprise by knowingly recruiting, transporting, \nsoliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would \nbe used to cause Plaintiff to commit a commercial sex act. \n50 \n3501.484-002 \nPage 50 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095956 \nEFTA01250030\n", "char_count": 1534}, {"efta_number": "EFTA01249981", "page_number": 50, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 51 of 52 \n213. \nAs a direct and proximate result of Defendant corporation's \ncommission of the aforementioned criminal offenses enumerated in 18 U.S.C. § \n1591, 1593A, and 1594, and the associated civil remedies provided in § 1595, \nPlaintiff has in the past suffered and will continue to suffer injury and pain; \nemotional distress; psychological and psychiatric trauma; mental anguish; \nhumiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of \nenjoyment of life; invasion of privacy; and other damages associated with' actions. \nPlaintiff will incur further medical and psychological expenses. These injuries are \npermanent in nature and Plaintiff will continue to suffer from them in the future. In \naddition to these losses, Plaintiff has incurred attorneys' fees and will be required do \nso in the future. \nWHEREFORE, Plaintiff demands judgment against Defendant, JEGE, Inc., \nfor compensatory and general damages, attorney's fees, punitive damages and such \nother and further relief as this Court deems just and proper. Plaintiff hereby demands \ntrial by jury on all issues triable as of right by a jury. \n51 \n3501.484-002 \nPage 51 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095957 \nEFTA01250031\n", "char_count": 1324}, {"efta_number": "EFTA01249981", "page_number": 51, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 52 of 52 \nDated: August 20, 2019. \nRespectfully Submitted, \n(SEEKING ADMISSION PRO HAC VICE) \n52 \n3501.484002 \nPage 52 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095958 \nEFTA01250032\n", "char_count": 276}, {"efta_number": "EFTA01249981", "page_number": 52, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-1 Filed 08/20/19 Page 1 of 3 \nEXHIBIT A \n3501.484-002 \nPage 53 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA 00095959 \nEFTA01250033\n", "char_count": 200}, {"efta_number": "EFTA01249981", "page_number": 53, "text_content": "Caassit 1191S0NIE961),IFOABOD0Dortomebt \nUNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK \n••••••••••••••••••••••• \nUNITED STATES OF AMERICA. \nx \nUSDC SDNY \nDOCUMENT \n.LECTRONICALLY FILED \nL\nD±TE FILED: \nGovernment, \n19 CR. 490 (RMB) \n- against - \nORDER \nJEFFREY EPSTEIN, \nDefendant. \n-3C \nThe Clerk is respectful') requested to docket the enclosed documents which were \ndiscussed at today's bail hearing. \nDated: New York, New York \nJuly 15, 2019 \n?Kg \nRICHARD M. BERMAN \n3501.484-002 \nPage 54 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095960 \nEFTA01250034\n", "char_count": 605}, {"efta_number": "EFTA01249981", "page_number": 54, "text_content": "CEDase:19.4lko0004S3CARMOCPodiximemodAt 41141444614144.4a4658183\n(IS v Jeffrey Epuein, I9-cr-490 (RMR) \nASSET SUMMARY - JUNE 30, 2019 \n_, \n6/30/19 \nAsset \nValue \nCash \n$ \n56,547,773 \n• \nFixed Income \n$ \n14,304,679 \n• \nEquities \n$ \n112,679,138 \n• \nHedge Funds & Private Equity \n$ \n194,986,301 \nI Properties \n\"*\" \n9 East 71st Street, New York, NY 10021 \n$ \n55.931,000 \n49 Zorro Ranch Road, Stanley New Mexico 87056 \n$ \n17.246,208 \n358 El Brillo Way, Palm Beach, FL 33480 \n$ \n12,380,209 \n22 Avenue Foch,Paris France 75116 \n$ \n8,672&823 \n$ \n22,498,600 \n$ \n63,874,223 1\nGreat St James Island No. 6A USVI 00802 (parcels A,B,C) \n—I\" \nLittle St James Island No. 6B USVI 00802 (parcels A,B,C) \nTotal Assets \n$ \n559,120,954 \n' \nValues reflect gross numbers that are not net of tax \n** All properties are valued at assessed values as per the most recent \nproperty tax bills \nn• Note the United States Attorney's office for the Southern District of New York \nhas stated that the value of this home is $77,000,000 as compared to the \nmarket value shown above per the June 1, 2019 property tax bill \n\"\" Note this property is valued at cost basis, however the assessment on \nthe most recent tax bill is $4,857,500 \nI \n3501.484-002 \nPage 55 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA 00095961 \nEFTA01250035\n", "char_count": 1324}, {"efta_number": "EFTA01249981", "page_number": 55, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 1 of 15 \nEXHIBIT B \n3501.484-002 \nPage 56 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095962 \nEFTA01250036\n", "char_count": 201}, {"efta_number": "EFTA01249981", "page_number": 56, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 2 of 15 \nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK \n \n \nx \nUNITED. STATES OF AMERICA \nJEFFREY EPSTEIN, \nDefendant. \nx \nSEALED \nINDICTMENT \n19 Cr. \n19 CRIM 490 \nCOUNT ONE \n(Sex Trafficking Conspiracy) \nThe Grand Jury charges: \nOVERVIEW \n1. \nAs set forth herein, over the course of many \nyears, JEFFREY EPSTEIN, the defendant, sexually exploited and \nabused dozens of minor girls at his homes in Manhattan, New \nYork, and Palm Beach, Florida, among other locations. \n2. \nIn particular, from at least in or about 2002, up \nto and including at least in or about 2005, JEFFREY EPSTEIN, the \ndefendant, enticed and recruited, and caused to be enticed and \nrecruited, minor girls to visit his mansion in Manhattan, New \nYork (the \"New York Residence\") and his estate in Palm Beach, \nFlorida (the \"Palm Beach Residence\") to engage in sex acts with \nhim, after which he would give the victims hundreds of dollars \nin cash. Moreover, and in order to maintain and increase his \nsupply of victims, EPSTEIN also paid certain of his victims to \nrecruit additional girls to be similarly abused by EPSTEIN. In \n3501.484-002 \nPage 57 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA 00095963 \nEFTA01250037\n", "char_count": 1293}, {"efta_number": "EFTA01249981", "page_number": 57, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 3 of 15 \nthis way, EPSTEIN created a vast network of underage victims for \nhim to sexually exploit in locations including New York and \nPalm Beach. \n3. \nThe victims described herein were as young as 14 \nyears old at the time they were abused by JEFFREY EPSTEIN, the \ndefendant, and were, for various reasons, often particularly \nvulnerable to exploitation. EPSTEIN intentionally sought out \nminors and knew that many of his victims were in fact under the \nage of 18, including because, in some instances, minor victims \nexpressly told him their age. \n4. \nIn creating and maintaining this network of minor \nvictims in multiple states to sexually abuse and exploit, \nJEFFREY EPSTEIN, the defendant, worked and conspired with \nothers, including employees and associates who facilitated his \nconduct by, among other things, contacting victims and \nscheduling their sexual encounters with EPSTEIN at the New York \nResidence and at the Palm Beach Residence. \nFACTUAL BACKGROUND \n5. \nDuring all time periods charged in this \nIndictment, JEFFREY EPSTEIN, the defendant, was a financier with \nmultiple residences in the continental United States, including \nthe New York Residence and the Palm Beach Residence. \n6. \nBeginning in at least 2002, JEFFREY EPSTEIN, the \ndefendant, enticed and recruited, and caused to be enticed and \n2 \n3501.484-002 \nPage 58 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095964 \nEFTA01250038\n", "char_count": 1505}, {"efta_number": "EFTA01249981", "page_number": 58, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 4 of 15 \nrecruited, dozens of minor girls to engage in sex acts with him, \nafter which EPSTEIN paid the victims hundreds of dollars in \ncash, at the New York Residence and the Palm Beach Residence. \n7. \nIn both New York and Florida, JEFFREY EPSTEIN, \nthe defendant, perpetuated this abuse in similar ways. Victims \nwere initially recruited to provide \"massages\" to EPSTEIN, which \nwould be performed nude or partially nude, would become \nincreasingly sexual in nature, and would typically include one \nor more sex acts. EPSTEIN paid his victims hundreds of dollars \nin cash for each encounter. Moreover, EPSTEIN actively \nencouraged certain of his victims to recruit additional girls to \nbe similarly sexually abused. EPSTEIN incentivized his victims \nto become recruiters by paying these victim-recruiters hundreds \nof dollars for each girl that they brought to EPSTEIN. In so \ndoing, EPSTEIN maintained a steady supply of new victims to \nexploit. \nThe New York Residence \n8. \nAt all times relevant to this Indictment, JEFFREY \nEPSTEIN, the defendant, possessed and controlled a multi-story \nprivate residence on the Upper East Side of Manhattan, New York, \ni.e., the New York Residence. Between at least in or about 2002 \nand in or about 2005, EPSTEIN abused numerous minor victims at \nthe New York Residence by causing these victims to be recruited \nto engage in paid sex acts with him. \n3 \n3501.484-002 \nPage 59 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095965 \nEFTA01250039\n", "char_count": 1575}, {"efta_number": "EFTA01249981", "page_number": 59, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 5 of 15 \n9. \nWhen a victim arrived at the New York Residence, \nshe typically would be escorted to a room with a massage table, \nwhere she would perform a massage on JEFFREY EPSTEIN, the \ndefendant. The victims, who were as young as 14 years of age, \nwere told by EPSTEIN or other individuals to partially or fully \nundress before beginning the \"massage.\" During the encounter, \nEPSTEIN would escalate the nature and scope of physical contact \nwith his victim to include, among other things, sex acts such as \ngroping and direct and indirect contact with the victim's \ngenitals. EPSTEIN typically would also masturbate during these \nsexualized encounters, ask victims to touch him while he \nmasturbated, and touch victims' genitals with his hands or with \nsex toys. \n10. In connection with each sexual encounter, JEFFREY \nEPSTEIN, the defendant, or one of his employees or associates, \npaid the victim in cash. Victims typically were paid hundreds \nof dollars in cash for each encounter. \n11. JEFFREY EPSTEIN, the defendant, knew that many of \nhis New York victims were underage, including because certain \nvictims told him their age. Further, once these minor victims \nwere recruited, many were abused by EPSTEIN on multiple \nsubsequent occasions' at the New York Residence. EPSTEIN \nsometimes personally contacted victims to schedule appointments \nat the New York Residence. In other instances, EPSTEIN directed \n4 \n3501.484-002 \nPage 60 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA 00095966 \nEFTA01250040\n", "char_count": 1598}, {"efta_number": "EFTA01249981", "page_number": 60, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 6 of 15 \nemployees and associates, including a New York-based employee \n(\"Employee-1\"), to communicate with victims via phone to arrange \nfor these victims to return to the New York Residence for \nadditional sexual encounters with EPSTEIN. \n12. Additionally, and to further facilitate his \nability to abuse minor girls in New York, JEFFREY EPSTEIN, the \ndefendant, asked and enticed certain of his victims to recruit \nadditional girls to perform \"massages\" and similarly engage in \nsex acts with EPSTEIN. When a victim would recruit another girl \nfor EPSTEIN, he paid both the victim-recruiter and the new \nvictim hundreds of dollars in cash. Through these victim-\nrecruiters, EPSTEIN gained access to and was able to abuse \ndozens of additional minor girls. \n13. In particular, certain recruiters brought dozens \nof additional minor girls to the New York Residence to give \nmassages to and engage in sex acts with JEFFREY EPSTEIN, the \ndefendant. EPSTEIN encouraged victims to recruit additional \ngirls by offering to pay these victim-recruiters for every \nadditional girl they brought to EPSTEIN. When a victim-\nrecruiter accompanied a new minor victim to the New York \nResidence, both the victim-recruiter and the new minor victim \nwere paid hundreds of dollars by EPSTEIN for each encounter. In \naddition, certain victim-recruiters routinely scheduled these \n5 \n3501.484-002 \nPage 61 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA 00095967 \nEFTA01250041\n", "char_count": 1547}, {"efta_number": "EFTA01249981", "page_number": 61, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 7 of 15 \nencounters through Employee-1, who sometimes asked the \nrecruiters to bring a specific minor girl for EPSTEIN. \nThe Palm Beach Residence \n14. In addition to recruiting and abusing minor girls \nin New York, JEFFREY EPSTEIN, the defendant, created a similar \nnetwork of minor girls to victimize in Palm Beach, Florida, \nwhere EPSTEIN owned, possessed and controlled another large \nresidence, i.e., the Palm Beach Residence. EPSTEIN frequently \ntraveled from New York to Palm Beach by private jet, before \nwhich an employee or associate would ensure that minor victims \nwere available for encounters upon his arrival in Florida. \n15. At the Palm Beach Residence, JEFFREY EPSTEIN, the \ndefendant, engaged in a similar course of abusive conduct. \nWhen a victim initially arrived at the Palm Beach Residence, she \nwould be escorted to a room, sometimes by an employee of \nEPSTEIN's, including, at times, two assistants (\"Employee-2\" and \n\"Employee-3\") who, as described herein, were also responsible \nfor scheduling sexual encounters with minor victims. Once \ninside, the victim would provide a nude or semi-nude massage for \nEPSTEIN, who would himself typically be naked. During these \nencounters, EPSTEIN would escalate the nature and scope of the \nphysical contact to include sex acts such as groping and direct \nand indirect contact with the victim's genitals. EPSTEIN would \nalso typically masturbate during these encounters, ask victims \n6 \n3501.484-002 \nPage 62 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095968 \nEFTA01250042\n", "char_count": 1631}, {"efta_number": "EFTA01249981", "page_number": 62, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 8 of 15 \nto touch him while he masturbated, and touch victims' genitals \nwith his hands or with sex toys. \n16. In connection with each sexual encounter, JEFFREY \nEPSTEIN, the defendant, or one of his employees or associates, \npaid the victim in cash. Victims typically were paid hundreds \nof dollars for each encounter. \n17. JEFFREY EPSTEIN, the defendant, knew that certain \nof his victims were underage, including because certain victims \ntold him their age. In addition, as with New York-based \nvictims, many Florida victims, once recruited, were abused by \nJEFFREY EPSTEIN, the defendant, on multiple additional \noccasions. \n18. JEFFREY EPSTEIN, the defendant, who during the \nrelevant time period was frequently in New York, would arrange \nfor Employee-2 or other employees to contact victims by phone in \nadvance of EPSTEIN's travel to Florida to ensure appointments \nwere scheduled *for when he arrived. In particular, in certain \ninstances, Employee-2 placed phone calls to minor victims in \nFlorida to schedule encounters at the Palm Beach Residence. At \nthe time of certain of those phone calls, EPSTEIN and Employee-2 \nwere in New York, New York. Additionally, certain of the \nindividuals victimized at the Palm Beach Residence were \ncontacted by phone by Employee-3 to schedule these encounters. \n7 \n3501.484-002 \nPage 63 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095969 \nEFTA01250043\n", "char_count": 1493}, {"efta_number": "EFTA01249981", "page_number": 63, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 9 of 15 \n19. Moreover, as in New York, to ensure a steady \nstream of minor victims, JEFFREY EPSTEIN, the defendant, asked \nand enticed certain victims in Florida to recruit other girls to \nengage in sex acts. EPSTEIN paid hundreds of dollars to victim-\nrecruiters for each additional girl they brought to the Palm \nBeach Residence. \nSTATUTORY ALLEGATIONS \n20. From at least in or about 2002, up to and \nincluding in or about 2005, in the Southern District of New York \nand elsewhere, JEFFREY EPSTEIN, the defendant, and others known \nand unknown, willfully and knowingly did combine, conspire, \nconfederate, and agree together and with each other to commit an \noffense against the United States, to wit, sex trafficking of \nminors, in violation of Title 18, United States Code, Section.\n1591(a) and (D). \n21. It was a part and object of the conspiracy that \nJEFFREY EPSTEIN, the defendant, and others known and unknown, \nwould and did, in and affecting interstate and foreign commerce, \nrecruit, entice, harbor, transport, provide, and obtain, by any \nmeans a person, and to benefit, financially and by receiving \nanything of value, from participation in a venture which has \nengaged in any such act, knowing that the person had not \nattained the age of 18 years and would be caused to engage in a \n8 \n3501.484-002 \nPage 64 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095970 \nEFTA01250044\n", "char_count": 1483}, {"efta_number": "EFTA01249981", "page_number": 64, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 10 of 15 \ncommercial sex act, in violation of Title 18, United States \nCode, Sections 1591(a) and (b)(2). \nOvert Acts \n22. In furtherance of the conspiracy and to effect \nthe illegal object thereof, the following overt acts, among \nothers, were committed in the Southern District of New York and \nelsewhere: \na. \nIn or about 2004, JEFFREY EPSTEIN, the \ndefendant, enticed and recruited multiple minor victims, \nincluding minor victims identified herein as Minor Victim-1, \nMinor Victim-2, and Minor Victim-3, to engage in sex acts with \nEPSTEIN at his residences in Manhattan, New York, and Palm \nBeach, Florida, after which he provided them with hundreds of \ndollars in cash for each encounter. \nb. \nIn or about 2002, Minor Victim-1 was \nrecruited to engage in sex acts with EPSTEIN and was repeatedly \nsexually abused by EPSTEIN at the New York Residence over a \nperiod of years and was paid hundreds of dollars for each \nencounter. EPSTEIN also encouraged and enticed Minor Victim-1 \nto recruit other girls to engage in paid sex acts, which she \ndid. EPSTEIN asked Minor Victim-1 how old she was, and Minor \nVictim-1 answered truthfully. \nc. \nIn or about 2004, Employee-1, located in the \nSouthern District of New York, and on behalf of EPSTEIN, placed \n9 \n3501.484-002 \nPage 65 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA 00095971 \nEFTA01250045\n", "char_count": 1441}, {"efta_number": "EFTA01249981", "page_number": 65, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 11 of 15 \na telephone call to Minor Victim-1 in order to schedule an \nappointment for Minor Victim-1 to engage in paid sex acts with \nEPSTEIN. \nd. \nIn or about 2004, Minor Victim-2 was \nrecruited to engage in sex acts with EPSTEIN and was repeatedly \nsexually abused by EPSTEIN at the Palm Beach Residence over a \nperiod of years and was paid hundreds of dollars after each \nencounter. EPSTEIN also encouraged and enticed Minor Victim-2 \nto recruit other girls to engage in paid sex acts, which she \ndid. \ne. \nIn or about 2005, Employee-2, located in the \nSouthern District of New York, and on behalf of EPSTEIN, placed \na telephone call to Minor Victim-2 in order to schedule an \nappointment for Minor Victim-2 to engage in paid sex acts with \nEPSTEIN. \nf. \nIn or about 2005, Minor Victim-3 was \nrecruited to engage in sex acts with EPSTEIN and was repeatedly \nsexually abused by EPSTEIN at the Palm Beach Residence over a \nperiod of years and was paid hundreds of dollars for each \nencounter. EPSTEIN also encouraged and enticed Minor Victim-3 \nto recruit other girls to engage in paid sex acts, which she \ndid. EPSTEIN asked Minor Victim-3 how old she was, and Minor \nVictim-3 answered truthfully. \n10 \n3501.484-002 \nPage 66 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095972 \nEFTA01250046\n", "char_count": 1387}, {"efta_number": "EFTA01249981", "page_number": 66, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 12 of 15 \ng. \nIn or about 2005, Employee-2, located in the \nSouthern District of New York, and on behalf of EPSTEIN, placed \na telephone call to Minor Victim-3 in Florida in order to \nschedule an appointment for Minor Victim-3 to engage in paid sex \nacts with EPSTEIN. \nh. \nIn or about 2004, Employee-3 placed a \ntelephone call to Minor Victim-3 in order to schedule an \nappointment for Minor Victim-3 to engage in paid sex acts with \nEPSTEIN. \n(Title 18, United States Code, Section 371.) \nCOUNT TWO \n(Sex Trafficking) \nThe Grand Jury further charges: \n23. The allegations contained in paragraphs 1 \nthrough 19 and 22 of this Indictment are repeated and realleged \nas if fully set forth within. \n24. From at least in or about 2002, up to and \nincluding in or about 2005, in the Southern District of New \nYork, JEFFREY EPSTEIN, the defendant, willfully and knowingly, \nin and affecting interstate and foreign commerce, did recruit, \nentice, harbor, transport, provide, and obtain by any means a \nperson, knowing that the person had not attained the age of 18 \nyears and would be caused to engage in a commercial sex act, and \ndid aid and abet the same, to wit, EPSTEIN recruited, enticed, \nharbored, transported, provided, and obtained numerous \n11 \n3501.484-002 \nPage 67 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095973 \nEFTA01250047\n", "char_count": 1431}, {"efta_number": "EFTA01249981", "page_number": 67, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 13 of 15 \nindividuals-who were less than 18 years old, including but not \nlimited to Minor Victim-1, as described above, and who were then \ncaused to engage in at least one commercial sex act in \nManhattan, New York. \n(Title 18, United States Code, Sections 1591(a), \n(b)(2), and 2.) \nFORFEITURE ALLEGATIONS \n25. As a result of committing the offense alleged in \nCount Two of this Indictment, JEFFREY EPSTEIN, the defendant, \nshall forfeit to the United States, pursuant to Title 18, United \nStates Code, Section 1594(c)(1), any property, real and \npersonal, that was used or intended to be used to commit or to \nfacilitate the commission of the offense alleged in Count Two, \nand any property, real or personal, constituting or derived from \nany proceeds obtained, directly or indirectly, as a result of \nthe offense alleged in Count Two, or any property traceable to \nsuch property, and the following specific property: \na. \nThe lot or parcel of land, together with its \nbuildings, appurtenances, improvements, fixtures, attachments \nand easements, located at 9 East 71st Street, New York, New \nYork, with block number 1386 and lot number 10, owned by \nMaple, Inc. \n12 \n3501.484-002 \nPage 68 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095974 \nEFTA01250048\n", "char_count": 1353}, {"efta_number": "EFTA01249981", "page_number": 68, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 14 of 15 \nSubstitute Asset Provision \n26. If any of the above-described forfeitable \nproperty, as a result of any act or omission of the defendant: \n(a) cannot be located upon the exercise of due diligence; \n(b) has been transferred or sold to, or deposited with, a \nthird person; \n(c) has been placed beyond the jurisdiction of the Court; \n(d) has been substantially diminished in value; or \n(e) has been commingled with other property which cannot \nbe subdivided without difficulty; \nit is the intent of the United States, pursuant to 21 U.S.C. \n§ 853(p) and 28 U.S.C. § 2461(c), to seek forfeiture of any \nother property of the defendant up to the value of the above \nforfeitable property. \n(Title 18, United States Code, Section 1594; Title 21, \nUnited States Code, Section 853(p); and \nTitle 28, United States Code, Section 2461.) \n13 \nGE2E4 11(1. \nBERMAN \nUnited States Attorney \n3501.484-002 \nPage 69 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095975 \nEFTA01250049\n", "char_count": 1067}, {"efta_number": "EFTA01249981", "page_number": 69, "text_content": "Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 15 of 15 \nForm No. USA-33s-274 (Ed. 9-25-58) \nUNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK \nUNITED STATES OF AMERICA \nv. \nJEFFREY EPSTEIN, \nDefendant. \nINDICTMENT\n(18 U.S.C. SS 371, 1591(a), (b)(2), \nand 2) \nGEOFFREY S. BERMAN \nUnited States Attorney \nWWL01-00....4an \n14 \n3501.484-002 \nPage 70 of 70 \nSUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 \nEFTA_00095976 \nEFTA01250050\n", "char_count": 469}]}