{"efta_number": "EFTA02846045", "page_count": 30, "url": "https://epstein-data.com/EFTA02846045", "pdf_url": "https://epstein-data.com/pdf/EFTA02846045.pdf", "pages": [{"efta_number": "EFTA02846045", "page_number": 0, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 1 of 30\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\nCASE NO.: 1:19-cv-07625-AJN\n\nVE\nPlaintiff,\nvs.\n\nDARREN K. INDYKE AND\nRICHARD D. KAHN AS JOINT\nPERSONAL REPRESENTATIVES OF\nTHE ESTATE OF JEFFREY E. EPSTEIN,\nNINE EAST 71sT STREET, CORPORATION,\nFINANCIAL TRUST COMPANY, INC.,\nNES, LLC,\nDefendant.\n/\n\nFIRST AMENDED COMPLAINT\nPlaintiff, VE, by and through her undersigned counsel, for her claims against\nDefendants, alleges as follows:\n1.\n\nThe controversy in this cause of action exceeds the sum or value of\n\n$75,000, exclusive of interest and costs, and is between citizens of different States.\nTherefore, jurisdiction is proper under 28 U.S.C. section 1332.\n\n1\n\nEFTA02846045\n\n", "char_count": 752}, {"efta_number": "EFTA02846045", "page_number": 1, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\n2.\n\nDocument 3\n\nFiled 08/20/19\n\nPage 2 of 30\n\nPlaintiff files this Complaint under a pseudonym in order to protect her\n\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.\n3.\n\nPlaintiff is currently a resident of and domiciled in the state of Florida.\n\n4.\n\nAt all times material to this cause of action, Jeffrey Epstein travelled\n\nbetween and stayed regularly in multiple residences, including in New York, New\nYork (within the Southern District of New York) and the United States Virgin\nIslands. He was a citizen of the United States and a resident of the U.S. Virgin\nIslands.\n5.\n\nAt all times material to this cause of action Jeffrey Epstein was an adult\n\nmale born in 1953, who died on August 10, 2019.\n6.\n\nDefendant, Darren K. Indyke and Richard D. Kahn as Joint Personal\n\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.\n\nDivision, and is the legal entity responsible for intentional,\n\ncriminal, or tortious conduct committed by Jeffrey Epstein as described in this\nComplaint.\n7.\n\nAt all times material hereto, Defendant Nine East 71st Street,\n\nCorporation was a domestic business corporation conducting business in New York,\n\n2\n\nEFTA02846046\n\n", "char_count": 1427}, {"efta_number": "EFTA02846045", "page_number": 2, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 3 of 30\n\nwith its principal place of business located at 575 Lexington Avenue, Fourth Floor,\nNew York, NY 10022.\n8.\n\nAt all times material hereto, Defendant Financial Trust Company, Inc.\n\nwas a U.S. Virgin Islands corporation conducting business in New York.\n9.\n\nAt all times material hereto, Defendant NES, LLC, was and is a\n\ndomestic limited liability company registered in and conducting business in New\nYork.\n10.\n\nCorporate Defendants NES, LLC; Financial Trust Company, Inc; Nine\n\nEast 71st Street, referred to as \"Defendants,\" each performed substantial business in\nNew York.\n11.\n\nPlaintiff intends to amend this complaint to add or substitute additional\n\nparties as discovery reveals the identities of other negligent corporate or individual\nactors.\n12.\n\nJeffrey Epstein was an officer, director, or employee of many corporate\n\nentities registered in various states throughout the United States, any one of which\nmay also bear legal responsibility for the crimes he committed against young\nfemales, including minors such as Plaintiff.\n13.\n\nAdditionally, individuals who worked at the residences where he\n\ncommitted sexual violations, as well as others who assisted him in committing such\nviolations, were employed through, or worked for, numerous other corporate entities\n\n3\n\nEFTA02846047\n\n", "char_count": 1357}, {"efta_number": "EFTA02846045", "page_number": 3, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 4 of 30\n\nwhose negligence likely caused or contributed to the sexual violations that caused\nharm to Plaintiff.\n14.\n\nThe complete universe of those individuals and companies whose\n\nnegligence contributed to the crimes committed by Epstein are currently unknown.\n15.\n\nAs Plaintiff learns through discovery the identities of additional\n\nindividual or corporate entities and the manner in which those others caused or\ncontributed to causing harm to Plaintiff through negligence, Plaintiff intends to\namend to add those parties as well. Should discovery reveal that any of the currently\nnamed Defendants are not the proper identity of the Companies identified as current\nDefendants, substitution of parties shall be requested to ensure accuracy and\ncorrectness of pleading.\n16.\n\nA substantial part of the acts, events, and omissions giving rise to this\n\ncause of action occurred in the Southern District of New York; venue is proper in\nthis District. 28 U.S.C. section 1391(6)(2).\n17.\n\nAt all times material to this cause of action, Jeffrey Epstein (legally\n\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,\n\n4\n\nEFTA02846048\n\n", "char_count": 1550}, {"efta_number": "EFTA02846045", "page_number": 4, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 5 of 30\n\nincluding any acts that would cause Plaintiff to be harmed through conduct\ncommitted against her in violation of New York Penal Law section 214-G, New\nYork Penal Law section 130.20; or New York Penal Law 130.35; or New York Penal\nLaw 130.52; or New York Penal Law 130.66; or New York Penal Law 130.67.\n\nFACTUAL ALLEGATIONS\n18.\n\nAt all times material to this cause of action, Jeffrey Epstein was an adult\n\nmale over 45 years old. Epstein was tremendously wealthy, widely recognized as a\nbillionaire, who used his wealth, power, resources, and connections to commit illegal\nsexual crimes in violation of federal and state statutes and to employ and conspire\nwith other individuals and corporate entities to assist him in committing those crimes\nor torts or to facilitate or enable those acts to occur.\n19.\n\nEpstein displayed his enormous wealth, power, and influence to his\n\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 and carry out and conceal his crimes and torts.\n20.\n\nAt all relevant times, Epstein had access to numerous mansions, a fleet\n\nof airplanes, motor vehicles, boats and one or more helicopters. For example, he\nregularly traveled by private jet aboard a Boeing aircraft (of make and model B-727-\n\n5\n\nEFTA02846049\n\n", "char_count": 1431}, {"efta_number": "EFTA02846045", "page_number": 5, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 6 of 30\n\n31H with tail number N908JE) or a Gulfstream aircraft (of make and model G1159B with tail number N909JE).\n21.\n\nJeffrey Epstein also travelled between and frequently inhabited and\n\ntravelled between numerous properties and homes, including a Manhattan\ntownhome located at 9 East 71S' Street, New York, NY 10021 valued conservatively\nby Jeffrey Epstein's own admission at $55,931,000.00; a ranch located at 49 Zorro\nRanch Road, Stanley, New Mexico 87056 valued conservatively by Jeffrey\nEpstein's own admission at $17,246,208.00; a home located at 358 El Brillo Way,\nPalm Beach, Florida 33480 valued conservatively by Jeffrey Epstein's own\nadmission at $12,380,209.00; an apartment located at 22 Avenue Foch, Paris, France\n75116 valued conservatively by Jeffrey Epstein's own admission at $8,672,820.00;\nan Island located at Great St. James Island No. 6A USVI 00802 (parcels A, B, C);\nand an Island Little St. James Island No. 6B USVI 00802 (A, B, C). See Jeffrey\nEpstein \"Asset Summary — June 30, 2019\" filed in Case 1:19-cr-00490-RMB on July\n15, 2019 attached hereto as Exhibit A.\n22.\n\nJeffrey Epstein was otherwise affiliated with the corporations that\n\nowned or controlled each of the real property listed in the preceding paragraph.\n23.\n\nThe allegations herein primarily concern Jeffrey Epstein's conduct\n\nwhile at his townhouse in New York and concern the various corporate entities\n\n6\n\nEFTA02846050\n\n", "char_count": 1475}, {"efta_number": "EFTA02846045", "page_number": 6, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 7 of 30\n\nwhich provided the opportunity for his illicit conduct to occur and remain concealed\nfor years.\n24.\n\nEpstein had a compulsive sexual preference for young females as young\n\nas 14 years old.\n25.\n\nEpstein enjoyed sexual contact with young females, including minor\n\nchildren, and took pleasure corrupting vulnerable young females, including minor\nchildren, into engaging in sexual acts with him.\n26.\n\nEpstein directed a complex system of individuals, including employees\n\nand associates of Defendant entities, to work in concert and at his direction, for the\npurpose of harming teenage girls through sexual exploitation.\n27.\n\nIt was widely known among individuals regularly in Epstein's presence\n\nthat he got pleasure out of corrupting vulnerable young females into engaging in\nuncomfortable and unwanted sexual acts for his own gratification.\n28.\n\nOn July 2, 2019, the United States Attorney's Office for the Southern\n\nDistrict of New York filed a Sealed Two Count Indictment inclusive of One Count\nof Sex Trafficking Conspiracy and One Count of Sex Trafficking, in part due to\nEpstein's criminal activities against children in the New York Mansion located at 9\nEast 71' Street.\n29.\n\nOn July 8, 2019, Jeffrey Epstein was arrested pursuant to the\n\naforementioned Indictment, which is attached hereto as Exhibit B.\n\n7\n\nEFTA02846051\n\n", "char_count": 1398}, {"efta_number": "EFTA02846045", "page_number": 7, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\n30.\n\nDocument 3\n\nFiled 08/20/19\n\nPage 8 of 30\n\nThe Indictment stated in part, and Plaintiff herein adopts as true, that\n\n\"from at least in or about 2002, up to and including at least in or about 2005, Jeffrey\nEpstein, the defendant, enticed and recruited, and caused to be enticed and recruited,\nminor girls to visit his mansion in Manhattan, New York (the \"New York\nResidence\") and his estate in Palm Beach, Florida (the \"Palm Beach Residence\") to\nengage in sex acts with him. after which the victims ere gi en hundreds of dollars\nin cash.\" Criminal Indictment at I .\n31.\n\n\"Moreover, and in order to maintain and increase his supply of victims,\n\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.\n32.\n\n\"The victims described herein were as young as 14 years old at the time\n\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.\n33.\n\n\"In creating and maintaining this network of minor victims in multiple\n\nstates to sexually abuse and exploit, JEFFREY EPSTEIN, ... worked and conspired\nwith others, including employees and associates who facilitated his conduct by,\n\n8\n\nEFTA02846052\n\n", "char_count": 1613}, {"efta_number": "EFTA02846045", "page_number": 8, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 9 of 30\n\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.\n34.\n\nThe indictment further explained, and Plaintiff adopts and alleges, that,\n\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.\n35.\n\n\"Between at least in or about 2002 and in or about 2005, Epstein abused\n\nnumerous minor victims at the New York Residence by causing these victims to be\nrecruited to engage in paid sex acts with him.\" Criminal Indictment at 3.\n36.\n\nDefendants enabled Jeffrey Epstein to receive near daily massages from\n\nyoung females, often minors, who were not experienced in massage. Rather than\nreceive regular body massages, Epstein was predictably sexually abusing the young\nfemales in violation of New York Penal Law Section 130.\n37.\n\nAdditionally, employees of the various Defendant corporations\n\nperformed actions or inactions that further placed victims, including Plaintiff, in\ndanger of being sexually abused by Epstein, and assisted in the concealment of his\nsexually abusive acts.\n38.\n\nDefendants employed many recruiters of young females. The nature of\n\nthe Jeffrey Epstein's sex trafficking venture and enterprise enabled victims\n\n9\n\nEFTA02846053\n\n", "char_count": 1519}, {"efta_number": "EFTA02846045", "page_number": 9, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 10 of 30\n\nthemselves to elevate their status to that of a paid recruiter of other victims, an\nelevation only made possible through the negligence of Defendants.\n39.\n\nRecruiters were taught by employees of Defendants to inform targeted\n\nvictims that Epstein possessed extraordinary wealth, power, resources, and\ninfluence; that he was a philanthropist who would help female victims advance their\ncareers and lives; and that she only needed to provide Epstein with body massages\nin order to avail receive his assistance and influence.\n40.\n\nThe collaboration from Defendants and the many employees fulfilled\n\nEpstein's compulsive need for sex with young females by preying on their personal,\npsychological, financial, and related vulnerabilities. Defendants' tactics included\npromising the victims money, shelter, transportation, gifts, employment, admission\ninto educational institutions, educational tuition, protection, and other things of\nvalue in exchange for sex and concealment of Jeffrey Epstein's actions.\n41.\n\nJeffrey Epstein's sexual attraction to young, often underage, females,\n\ndated back to at least the mid-nineties and the number of victims increased\nsubstantially with the necessary assistance from Defendants and Defendants'\nemployees.\n42.\n\nDefendants, at the direction of Epstein or in furtherance of his demands,\n\nand with help from assistants, associates and underlings, and even other victims,\n\n10\n\nEFTA02846054\n\n", "char_count": 1494}, {"efta_number": "EFTA02846045", "page_number": 10, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 11 of 30\n\nrecruited or procured dozens if not hundreds of young females, including minors,\nfor the purpose of Epstein's sexual gratification.\n43.\n\nJeffrey Epstein, and consequently Defendants, specifically targeted\n\nunderprivileged, emotionally vulnerable and/or economically disadvantaged young\nfemales to sexually molest and abuse.\n44.\n\nAdditionally, Defendants through employees, informed young females\n\nthat Jeffrey Epstein was wealthy, well-connected, and could either advance or\ndestroy the career or education of any young female brought to provide Jeffrey\nEpstein a massage, depending on her degree of cooperation.\nVE\n45.\n\nMinor victim VE was subjected to the types of illegal sexual acts\n\ndetailed in the Criminal Indictment filed against Jeffrey Epstein by the Southern\nDistrict of New York.\n46.\n\nJeffrey Epstein committed abhorrent acts of sexual abuse against\n\nPlaintiff in 2001 when she was only sixteen years old.\n47.\n\nIn or about 2001, Plaintiff was recruited by another minor child to go\n\nto Jeffrey Epstein's mansion in Manhattan, New York to provide him with a\n\"massage.\"\n48.\n\nThe minor child who recruited Plaintiff (\"Plaintiff's friend\") informed\n\nPlaintiff that she would be paid $300 to provide a massage to a man in Manhattan.\n\nII\n\nEFTA02846055\n\n", "char_count": 1330}, {"efta_number": "EFTA02846045", "page_number": 11, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 12 of 30\n\n49.\n\nPlaintiff was a minor female with no experience or training in massage.\n\n50.\n\nShe was recruited under the false pretense that she would be providing\n\na legitimate body massage at the mansion owned or controlled by Defendant, Nine\nEast.\n51.\n\nIn or about the Fall of 2001, Plaintiff's friend brought Plaintiff to\n\nJeffrey Epstein's home to provide him with a massage.\n52.\n\nUpon arrival to the mansion, the two minor children were escorted\n\ninside by an employee of Defendant NES, LLC and taken to Jeffrey Epstein's\nmassage room.\n53.\n\nPlaintiff's friend entered the massage room and left Plaintiff outside the\n\ndoor.\n54.\n\nMoments later, Plaintiff's friend exited the room and instructed\n\nPlaintiff to enter the room alone.\n55.\n\nPlaintiff walked into the dark room which contained a massage table,\n\nvarious massage oils, and numerous photographs of nude girls.\n56.\n\nUnsure of what to expect, Plaintiff waited for the man to arrive for his\n\nmassage.\n57.\n\nJeffrey Epstein entered the room and immediately removed his clothing\n\nbefore positioning himself on the massage table.\n\n12\n\nEFTA02846056\n\n", "char_count": 1165}, {"efta_number": "EFTA02846045", "page_number": 12, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\n58.\n\nDocument 3\n\nFiled 08/20/19\n\nPage 13 of 30\n\nJeffrey Epstein then provided Plaintiff with instruction on how to\n\nmassage his body.\n59.\n\nJeffrey Epstein quickly turned the massage into a sexual encounter with\n\nthe then sixteen-year-old Plaintiff.\n60.\n\nDuring the sexual encounter, Plaintiff told Jeffrey Epstein that she did\n\nnot feel comfortable. Jeffrey Epstein ignored her and continued to engage in the\nimproper and illegal sexual contact until he was finished.\n61.\n\nThe sexual encounter ended when Jeffrey Epstein masturbated to\n\nclimax.\n62.\n\nPlaintiff was paid $300 cash before being escorted out of his mansion,\n\nall with assistance from Defendants; this payment was made to induce Plaintiff to\nconceal the activities of Epstein and to entice her to return.\n63.\n\nPlaintiff observed the opulence of the mansion owned by Defendant,\n\nNine East, and the organization of Defendant, NES, Inc., which collectively\nfacilitated her further cooperation with Jeffrey Epstein, culminating in New York\nPenal Law Section 130 crimes being committed against her by Jeffrey Epstein.\n64.\n\nWithin days, Plaintiff returned to Jeffrey Epstein's mansion wherein\n\nshe endured yet another sexual assault, this time more severe.\n65.\n\nPlaintiff was taken by elevator to the floor where Jeffrey Epstein's\n\nmassage room was located.\n\n13\n\nEFTA02846057\n\n", "char_count": 1361}, {"efta_number": "EFTA02846045", "page_number": 13, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\n66.\n\nDocument 3\n\nFiled 08/20/19\n\nPage 14 of 30\n\nSimilar to the first time, Jeffrey Epstein appeared wearing only a towel\n\nand laid face down on the massage table. Within minutes, he again turned the\nmassage into a sexual encounter against the 16-year-old plaintiff. He instructed her\nto take her clothes off this time.\n67.\n\nDuring the second encounter, in addition to harmful, forcible, physical\n\ntouching and sexual exploitation of Plaintiff, Jeffrey Epstein forcibly used a sex toy\n\non Plaintiff, forcibly pressing it onto and in Plaintiff's vagina.\n68.\n\nJeffrey Epstein then commanded Plaintiff to straddle him. Knowing\n\nthat she had no way out of the Mansion, she complied with Jeffrey Epstein's orders.\n69.\n\nJeffrey Epstein moved plaintiff's panties aside and attempted to insert\n\nhis penis into her vagina, briefly penetrating her, while Plaintiff was resisting.\n70.\n\nDuring this encounter, Epstein digitally penetrated Plaintiff. The\n\nencounter ended with Jeffrey Epstein masturbating to climax.\n71.\n\nThroughout the duration of the sexual encounter, Plaintiff found herself\n\ntrapped in Jeffrey Epstein's large mansion under the impression that there was no\nfeasible or safe means of escape.\n72.\n\nAll sexual acts were performed by Jeffrey Epstein intentionally and for\n\nno legitimate purpose and for his own gratification when Plaintiff was a minor child\nless than seventeen years of age.\n\n14\n\nEFTA02846058\n\n", "char_count": 1442}, {"efta_number": "EFTA02846045", "page_number": 14, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\n73.\n\nDocument 3\n\nFiled 08/20/19\n\nPage 15 of 30\n\nThe intentional acts of Jeffrey Epstein against Plaintiff constitute a\n\nsexual offense as defined in New York Penal Law § 130.\n74.\n\nPursuant to New York Penal Law § 130.05, a person is deemed\n\nincapable of consent when she is less than seventeen years old.\n75.\n\nJeffrey Epstein committed sexual misconduct against Plaintiff as\n\ndefined in §130.20 of the New York Penal Law, inasmuch as Jeffrey Epstein\nengaged in sexual intercourse with Plaintiff without Plaintiff's consent.\n76.\n\nJeffrey Epstein committed rape in the first degree as defined in §130.35\n\ninasmuch as Jeffrey Epstein engaged in sexual intercourse with Plaintiff by forcible\ncompulsion;\n77.\n\nJeffrey Epstein committed a forcible touching against Plaintiff as\n\ndefined in *130.52 of the New York Penal Law, inasmuch as Jeffrey Epstein,\nintentionally and for no legitimate purpose, engaged the forcible sexual touching of\nPlaintiff for the purpose of degrading or abusing her or for the purpose of gratifying\nhis sexual desire.\n78.\n\nJeffrey Epstein committed an aggravated sexual abuse in the third\n\ndegree against her as defined in §130.66 of the New York Penal Law, inasmuch as\nJeffrey Epstein inserted a foreign object into the vagina of Plaintiff by forcible\ncompulsion.\n\n15\n\nEFTA02846059\n\n", "char_count": 1333}, {"efta_number": "EFTA02846045", "page_number": 15, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\n79.\n\nDocument 3\n\nFiled 08/20/19\n\nPage 16 of 30\n\nJeffrey Epstein committed an aggravated sexual abuse in the second\n\ndegree against her as defined in §130.67 of the New York Penal Law, inasmuch as\nJeffrey Epstein caused physical injury to Plaintiff when he inserted a finger into the\nvagina of Plaintiff by forcible compulsion.\nCOUNT I\nBATTERY AGAINST DARREN K. INDYKE AND RICHARD D. KAHN AS\nJOINT PERSONA!, REPRESENTATIVES OF THE EST ATE OF JEFFREY\nE EPSTEIN\n80.\n\nThe Plaintiff adopts and realleges paragraphs 1 through 79 above.\n\n81.\n\nJeffrey Epstein committed a harmful or offensive touching against\n\nPlaintiff.\n82.\n\nAs a direct and proximate result of Jeffrey Epstein's battery, the\n\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\n\n16\n\nEFTA02846060\n\n", "char_count": 1447}, {"efta_number": "EFTA02846045", "page_number": 16, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 17 of 30\n\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.\n\nCOUNT II\nBATTERY/VIOLATION OF SECTION 130\nAGAINST DARREN K. INDYKE AND RICHARD D. KAHN AS JOINT\nPERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E.\nEPSTEIN\n\n83.\n\nThe Plaintiff adopts and realleges paragraphs 1 through 79 above.\n\n84.\n\nThe intentional acts of Jeffrey Epstein against Plaintiff constitute a\n\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. 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\nd. 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.\ne. Aggravated sexual abuse in the second degree as defined in §130.67\ninasmuch as Jeffrey Epstein caused physical injury to Plaintiff when he\ninserted a finger into the vagina of Plaintiff by forcible compulsion.\n17\n\nEFTA02846061\n\n", "char_count": 1590}, {"efta_number": "EFTA02846045", "page_number": 17, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\n85.\n\nDocument 3\n\nFiled 08/20/19\n\nPage 18 of 30\n\nAs a direct and proximate result of Jeffrey Epstein's violations of New\n\nYork Penal Law § 130, 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\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\nNEGLIGENT SECURITY AGAINST\nNINE EAST 71st STREET, CORPORATION\n\n86.\n\nThe Plaintiff adopts and realleges paragraphs 1 through 79 above.\n\n87.\n\nAt all times material hereto, Defendant, Nine East 7151 Street,\n\nCorporation (hereinafter \"Nine East\"), was the lawful owner of the property located\nat 9 East 71St Street, New York, New York, 10021.\n\nI8\n\nEFTA02846062\n\n", "char_count": 1407}, {"efta_number": "EFTA02846045", "page_number": 18, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\n88.\n\nDocument 3\n\nFiled 08/20/19\n\nPage 19 of 30\n\nDefendant, Nine East, acquired title to the property on September 6,\n\n1989 and retained such title until the property was transferred to Maple, Inc. on\nDecember 11, 2011.\n89.\n\nAt all such times, Defendant Nine East maintained legal control over\n\nthe subject premises.\n90.\n\nJeffrey Epstein was a regular habitant of Defendant Nine East and in\n\nfact resided at the premises when he was present in New York.\n91.\n\nDefendant knew or should have known when Defendant was in the\n\nhome owned by Defendant Nine East when Epstein had young females, including\nminor females such as Plaintiff.\n92.\n\nWhen Plaintiff was sexually abused by Jeffrey Epstein in 2001,\n\nDefendant, Nine East, as the owner of the property where all of the sexual abuse\noccurred, had a non-delegable duty to maintain the premises in a reasonably safe\ncondition.\n93.\n\nDefendant's non-delegable duty additionally included the duty to take\n\nprecautions to protect guests, visitors, or invitees from foreseeable harm, including\nforeseeable criminal conduct.\n94.\n\nDefendant's non-delegable duty further included the duty to take\n\nreasonable precautionary measures to minimize the risk of criminal acts upon\nvisitors.\n\n19\n\nEFTA02846063\n\n", "char_count": 1269}, {"efta_number": "EFTA02846045", "page_number": 19, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\n95.\n\nDocument 3\n\nFiled 08/20/19\n\nPage 20 of 30\n\nMost important, Defendant had a duty to take protective measures when\n\nit could be shown that the company possessing, owning, or controlling the property,\nknew or had reason to know from past experience that there was a likelihood of\nconduct that would endanger a visitor.\n96.\n\nTo establish foreseeability, the criminal conduct at issue must be\n\nreasonably predictable based on the prior occurrence of the same or similar criminal\nactivity at a location sufficiently proximate to the subject location.\n97.\n\nNo conduct becomes more foreseeable or predictable than the criminal\n\nconduct of Jeffrey Epstein, in which he engaged regularly, if not daily, when he was\nin Defendant's property.\n98.\n\nNearly every day that Jeffery Epstein was on or in the property of\n\nDefendant Nine East, he was engaging in criminal sexual behavior in violation of\nNew York Penal Code Section 130.\n99.\n\nDefendant knew or should have known of Jeffrey Epstein's propensity\n\nfor sexually abusing minor children, including regularly on the premises.\n100.\n\nDefendant knew of should have known from past experience that there\n\nwas a high likelihood that Jeffrey Epstein would engage in foreseeable criminal\nconduct that was likely to seriously endanger or injure a visitor, including Plaintiff.\n\n20\n\nEFTA02846064\n\n", "char_count": 1360}, {"efta_number": "EFTA02846045", "page_number": 20, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\n101.\n\nDocument 3\n\nFiled 08/20/19\n\nPage 21 of 30\n\nDefendant breached its duty to Plaintiff by failing to take even minimal\n\nsafety precautions to protect against the predictable criminal acts of Jeffrey Epstein,\nwhich were reasonably predictable and foreseeable to occur on the property.\n102.\n\nDefendant's negligence was a proximate cause of the sexual offenses\n\ncommitted against Plaintiff in violation of Article 130 of the NY Penal Law.\n103.\n\nAs a direct and proximate result of Defendant's breach, the Plaintiff has\n\nin the past suffered and ill the future will continue to suffer physical injury, pain,\nemotional\n\ndistress,\n\npsychological\n\ntrauma,\n\nmental\n\nanguish,\n\nhumiliation,\n\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 Nine East 71' Street,\nCorporation 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 IV\nNEGLIGENCE AGAINST\nFINANCIAL TRUST COMPANY, INCORPORATED\n\n104.\n\nThe Plaintiff adopts and realleges paragraphs 1 through 79 above.\n21\n\nEFTA02846065\n\n", "char_count": 1568}, {"efta_number": "EFTA02846045", "page_number": 21, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\n105.\n\nDocument 3\n\nFiled 08/20/19\n\nPage 22 of 30\n\nAt all times material hereto, Financial Trust Company, Inc. (hereinafter\n\n\"Financial Trust\") was a U.S. Virgin Islands corporation conducting business in\nNew York.\n106.\n\nAt all times material hereto, Defendant, Financial Trust, employed\n\nJeffrey Epstein.\n107.\n\nDefendant, Financial Trust, had a duty to exercise reasonable care to\n\nrefrain from retaining in its employ a person with known dangerous propensities in\na position that would present a foreseeable risk of harm to others.\n108.\n\nDefendant Financial Trust operated in part to satisfy the personal needs\n\nof Jeffrey Epstein, which included daily massages which Epstein requires to be\nsexual in nature.\n109.\n\nJeffrey Epstein's requirement that he receive regular massages from\n\nuntrained young females caused Defendant and its employees to knowingly turn a\nblind eye to the dangerous sexual addictive propensities of Jeffrey Epstein, despite\nknowledge that he would cause harm to many young females including Plaintiff, in\norder to retain its most valuable employee—Jeffrey Epstein.\n110.\n\nDefendant Financial Trust operated in part to further Jeffrey Epstein's\n\ngoal to obtain, recruit, and procure young females for the purposes of providing\nsexually explicit massages to Jeffrey Epstein.\n\n22\n\nEFTA02846066\n\n", "char_count": 1343}, {"efta_number": "EFTA02846045", "page_number": 22, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\n111.\n\nDocument 3\n\nFiled 08/20/19\n\nPage 23 of 30\n\nDuring the course and scope of his employment for Defendant, Jeffrey\n\nEpstein did fulfill the corporate objective of receiving sexual massages procured for\nhim by employees of Defendant.\n112.\n\nJeffrey Epstein was notorious for converting each massage into a\n\nsexually exploitive activity in violation of New York Penal Law Section 130, a fact\nwhich was known or should have been known in the exercise of reasonable care by\nDefendant.\n113.\n\nEven though Defendant, Financial Trust, knew of Jeffrey Epstein's\n\npropensity for the sort of behavior that caused Plaintiff's harm and Jeffrey Epstein's\nconstant engagement in this type of criminal behavior during the course and scope\nof his employment, Defendant retained Jeffrey Epstein and failed to properly\nsupervise him.\n114.\n\nJeffrey Epstein did not have a set work schedule or office but instead\n\nconducted business on behalf of the corporation from various locations all over the\nworld.\n115.\n\nWhile conducting said business, Jeffrey Epstein was frequently using\n\ncorporate finances in furtherance of his sexually explicit behavior.\n116.\n\nUpon information and belief, at times other employees of the Defendant\n\ncorporation were coordinating these sexually explicit massages for Epstein to engage\n\n23\n\nEFTA02846067\n\n", "char_count": 1341}, {"efta_number": "EFTA02846045", "page_number": 23, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 24 of 30\n\nin during business hours, while he was within the course and scope of his\nemployment for Defendant.\n117.\n\nIn fact, while Jeffrey Epstein was conducting business telephone calls\n\nor authorizing company actions on behalf of Defendant, Financial Trust, he would\nfrequently be receiving a sexually explicit massage.\n118.\n\nIn certain circumstances, sexually explicit massages provided by young\n\nwomen, oftentimes minor children, who were untrained in the art of massage, were\ncoordinated by another employee of Defendant who knew or should have known\nthat the massage was being conducted by an underage girl for the exclusive purpose\nof committing sexual crimes against her.\n119.\n\nJeffrey Epstein engaged in this type of sexually abusive behavior on a\n\ndaily basis to the extent that engaging in sexual massages became the most regular\nactivity that he engaged in while in the course and scope of his employment.\n120.\n\nJeffrey Epstein's habitual routine of recruiting and engaging in sexually\n\nexplicit massages began many years before the formation of Defendant and was not\na lifestyle unknown to Defendant, Financial Trust.\n121.\n\nDefendant, Financial Trust, knew or in the exercise of reasonable care\n\nshould have known that Jeffrey Epstein was potentially dangerous, had engaged in\na pattern of criminal sexual behavior against young females, including minors, for\n\n24\n\nEFTA02846068\n\n", "char_count": 1453}, {"efta_number": "EFTA02846045", "page_number": 24, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 25 of 30\n\nyears prior to the formation of Defendant Financial Trust, and that he was not going\nto cease committing criminal sexual acts.\n122.\n\nJeffrey Epstein was retained with knowledge of the propensity of this\n\nsort of behavior.\n123.\n\nDefendant, Financial Trust, retained Jeffrey Epstein with knowledge\n\nthat he would in fact injure others, such as Plaintiff, during the course and scope of\nhis employment.\n124.\n\nDespite such knowledge, Financial Trust knowingly placed Jeffrey\n\nEpstein in a position to cause foreseeable harm, which could have been prevented\nhad Defendant taken reasonable care in making decisions regarding the retention and\nsupervision of Jeffrey Epstein.\n125.\n\nDefendant's negligence was a proximate cause of the sexual offenses\n\ncommitted against Plaintiff in violation of Article 130 of the NY Penal Law.\n126.\n\nAs a direct and proximate result of Defendant's negligence, the Plaintiff\n\nhas in the past suffered and in the future will continue to suffer physical injury, pain,\nemotional\n\ndistress,\n\npsychological\n\ntrauma,\n\nmental\n\nanguish,\n\nhumiliation,\n\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\n\n25\n\nEFTA02846069\n\n", "char_count": 1418}, {"efta_number": "EFTA02846045", "page_number": 25, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 26 of 30\n\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 Financial Trust\nCompany, 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.\n\nCOUNT V\nNEGLIGENCE AGAINST NES, LLC\n127.\n\nThe Plaintiff adopts and realleges paragraphs 1 through 79 above.\n\n128.\n\nIt is believed that each employee of Defendant, NES, operated at the\n\ndirection of Jeffrey Epstein.\n129.\n\nUpon information and belief, the primary responsibility of each\n\nemployee of Defendant, NES, LLC (\"NES\") was to fulfill the needs or requests of\nJeffrey Epstein; more particularly, his daily massage schedule.\n130.\n\nUpon information and belief, the employees of Defendant, NES, were\n\ncompensated to primarily, if not exclusively, procure or maintain each young female\nmasseuse, or to assist, knowingly or unknowingly, in the concealment of any\nmisconduct committed against each masseuse.\n131.\n\nUpon information and belief, the employment responsibilities of the\n\nvarious employees of Defendant, NES, included but were not limited to: 1) recruiting\n\n26\n\nEFTA02846070\n\n", "char_count": 1395}, {"efta_number": "EFTA02846045", "page_number": 26, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 27 of 30\n\nyoung females, including minor children such as Plaintiff, to provide massages, 2)\ncreating Jeffrey Epstein's massage schedule, 3) maintaining Jeffrey Epstein's\nmassage schedule, 4) escorting various young females into the massage room at the\nNew York mansion owned by Defendant Nine East, 5) maintaining contact with the\nvarious young females who were recruited to the New York mansion for the\npurposes of providing Jeffrey Epstein with a massage, 6) providing compensation to\neach young masseuse upon the completion of her engagement with Jeffrey Epstein,\n7) providing meals and food and other services to the young females in order to\nprovide an air of legitimacy to the functions of the corporation, 8) providing\n\nhospitality services to the young females in order to provide an air of legitimacy to\nthe functions of the corporation, 9) providing educational services, 10) providing\nmedical services, 11) providing transportation services, 12) providing housing\nservices, 13) providing various other enticements to ensure the continued\ncooperation of the various young female masseuse with Defendant NES's corporate\nobjective, 14) encouraging individuals, including the females who were recruited to\nthe house to provide a massage to recruit other young females to engage in the same\nactivity for Jeffrey Epstein, and 15) coordinating together and with Jeffrey Epstein\nto convey a powerful and legitimate enterprise system capable of gaining\ncooperation from young females recruited for massage, often minors such as\nPlaintiff.\n\n27\n\nEFTA02846071\n\n", "char_count": 1622}, {"efta_number": "EFTA02846045", "page_number": 27, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\n132.\n\nDocument 3\n\nFiled 08/20/19\n\nPage 28 of 30\n\nIn fulfilling their employment responsibilities, each employee\n\nvoluntarily assumed a duty with respect to each young female recruited to massage\nJeffrey Epstein, including Plaintiff.\n133.\n\nTo fulfill said duty, each employee was required to perform their\n\nassumed duty carefully without omitting to do what an ordinarily prudent person\nwould do in accomplishing the task.\n134.\n\nThe young females being recruited to engage in massages for Jeffrey\n\nEpstein were inexperienced in the art of massage, a fact that was known or should\nhave been known to Defendant NES and its employees in the exercise of reasonable\ncare.\n135.\n\nPlaintiff relied on Defendant NES's voluntary assumption of a duty as\n\nwell as the voluntary assumption of each individual employee to act with reasonable\ncare towards her.\n136.\n\nIn the exercise of reasonable care, Defendant and its employees further\n\nknew or should have known of the dangerous propensities of Jeffrey Epstein and the\nproximate harm that would be caused by his likely sexual misconduct and various\nviolations of New York Penal Law Section 130.\n137.\n\nThe failure of Defendant NES and each of its respective employees to\n\nact in the same manner as an ordinarily prudent person, placed Plaintiff in a more\n\n28\n\nEFTA02846072\n\n", "char_count": 1339}, {"efta_number": "EFTA02846045", "page_number": 28, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 29 of 30\n\nvulnerable position than if Defendant and its employees had not assumed the\nobligation to treat her with reasonable care.\n138.\n\nIn breaching its Duty, NES launched a force or instrument of harm\n\ndirected toward Plaintiff. In doing so, Defendant, NES, enhanced the risk Plaintiff\nfaced and caused her to forego any opportunity she may otherwise have had to avoid\nthe risk inherent with being in a room alone with Jeffrey Epstein to pet form a\nmassage as an untrained minor child.\n139.\n\nDefendant's negligence was a proximate cause of the sexual offenses\n\ncommitted against Plaintiff in violation of Article 130 of the NY Penal Law.\n140.\n\nAs a direct and proximate result of Defendant's negligence, the Plaintiff\n\nhas in the past suffered and in the future will continue to suffer physical injury, pain,\nemotional\n\ndistress,\n\npsychological\n\ntrauma,\n\nmental\n\nanguish,\n\nhumiliation,\n\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 NES, Inc, for\ncompensatory and general damages, attorney's fees, punitive damages and such\n\n29\n\nEFTA02846073\n\n", "char_count": 1498}, {"efta_number": "EFTA02846045", "page_number": 29, "text_content": "Case 1:19-cv-07625-AJN-DCF\n\nDocument 3\n\nFiled 08/20/19\n\nPage 30 of 30\n\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.\n\nDated: August 20, 2019.\n\nRes ectful I Submitted,\nPOTT1NGER, LLC\nBy: /s/J. Stanley Pottinger\nJ. Stanley Pottinger\n1930 Broadway, Suite 12 B\nNew York, NY 10023\n(917)-446-4641\nFax: (954)-524-2822\nEmail: ecf@eplIc.com\nJ.\nBrittany N.\n425 N. Andrews Ave., Suite 2\nFort Lauderdale, FL 33301\n(954)-524-2820\nFax: (954)-524-2822\nEmail: bradaepllc.com\nbrittany@epllc.com\n(SEEKING ADMISSION PRO HAC VICE)\n\n30\n\nEFTA02846074\n\n", "char_count": 630}]}