Document comparison by Workshare Compare on Monday, June 05, 2017 6:18:32 PM Document 1 ID ile://C:\Users\pparker\Desktop\01 Complaint.pdf 01 Complaint ile://C:\Users\pparker\Desktop\First Amended Document 2 ID omplaint. pdf First Amended Complaint teptoe - Standard Moved from Style change EFTA00296277

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page | of 31 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO.:.1:17-CV-00616 JANE DOE 43, J Ss R ¥ YY R } ~ L D E M o~ N dD E b Plaintiff 2 vs. JEFFREY EPSTEIN, GHISLAINE MAXWELL Defendants. ee FIRST AMENDED COMPLAINT Plaintiff JANE DOE 43, by and through her undersigned counsel, for her EFTA00296278

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 2 of 31 claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, i. EE HE and ER. alleges upon personal knowledge with respect to her own acts and status, and upon_personal knowledge, information and belief as to all other matters, as follows: 1. This cause of action arises under federal statutes and jurisdiction is proper under 28 U.S.C. $section 1331. 2. Plaintiff files this Complaint under a pseudonym in order to protect her identity because this Complaint makes allegations of a sensitive sexual nature andthe disclosure of Jame-publiclitwhich, in association with her name, would cause further harm to her. — 3. Atall times material to the events alleged in this cause of action the Plaintiff was a citizen of South Africa residing in New York, New York. + 4. At all times material to this cause of action Defendant Jeffrey Epstein had multiple residences, including in New York, New York (within the Southern District of New York) and the United States Virgin Islands. He is currently a citizen of the United States and claims to be a resident of New—-York-and the U.S. Virgin Islands. 5. Atall times material to this cause of action Defendant Jeffrey Epstein was an adult male born in 1953. EFTA00296279

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 3 of 31 6. Atall times material to this cause of action Defendant Ghislaine Maxwell was residing in in New York, New York and was a citizen of Great Britain and France. 7. Atall times material to this cause of action [J was_a United States citizen, residing in New York, New York-and—on-infermation-andbelefwas-a eitizen-of the United-States (within the Southern District of New York). 8. Atall times material to this cause of action [ij J was residinga United States_citizen, employed by New_York based company _and_regularly conducting business in New York, New York and-oninformation and belief vasa citizen of the United States(within the Southern District of New York). 9-At-all-materialtimes— i I as-residing-_in New-York_New 9. +04nchidinge-beeause-A substantial part of the acts, events, and omissions giving rise to this cause of action occurred in the Southern District of New York;: venue is proper in that District. 28 U.S.C. $section 1391(b)(2) Ne 10. +-At all times material to this cause of action, Defendants Jeffrey Epstein, Ghislaine Maxwell, i and GE GE <:: i owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire to commit intentional, criminal, fraudulent, or tortious #4egal-acts against her-, FACTUAL ALLEGATIONS EFTA00296280

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 4 of 31 11. 42.Atall times material to this cause of action, Defendant Jeffrey Epstein was an adult male over 50 years old. Defendant Epstein is knewnwidely recognized as a billionaire who uses his extraordinary wealth to commit illegal sexual crimes in violation of federal and state statutes and to employ and conspire with a group of numerous others, including each of the named Defendants, to censpire-ancd-assist in committing those crimes and additional torts as well as to preteetand-conceal histhe crimes and torts_of the Epstein sex trafficking group from being discovered. 12. 43-Defendant Epstein displays his enormous wealth, power and influence to his employees; to the victims procured for sexual purposes; and to the public in order to advance and carry out his crimes and torts. At all relevant times, Defendant Epstein owned and continues to own, directly or through nominee individuals used to conceal his interests, a fleet of airplanes, motor vehicles, boats and one or more helicopters. For example, he owned and-owns(directly or indirectly) a Boeing aircraft (of make and model B-727-31H with tail number N908JE) and a Gulfstream aircraft of make and model G-1159B with tail number N909JE). He also owned numerous properties and homes, including a 51,000-square-foot mansion in Manhattan; a $30 Million, 7,500-acre ranch in New Mexico; a 70-acre private island formerly known as Little St. James in or near St. Thomas, U.S. Virgin Islands-a EFTA00296281

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 5 of 31 diansion-tLondon England: a home 3 in Paris, France; and a mansion in Palm Beach County, Florida. The allegations herein primarily concern the defendant’s conduct while at his townhouse in New York; on one or more of his private airplanes; and on his private island in the United States Virgin Islands. Epstein used all of the real and personal property ri in this paragraph to facilitate the illegal sex traffickin nture an enterprise described in this Complaint and in furtherance of that venture and enterprise. 13, +4-Defendant Epstein has a compulsive sexual preference for young females as young as 13 and as ““told“” as 25. Through information and belief Defendant had ith fomnales-virtuallyEpstel . ith thi range every day and assistedinthedevelopment-and—execution—ofdeveloped, through the employment of and conspiracy with the other Defendants, a sex trafficking schemeventure and enterprise designed to fulfill his sexual desires: Lth . f_th . i fi participants. As part of the venture and enterprise, Epstein also provided oung females for sexual purposes to his friends in order to secure social business, and other contacts as well as other things of value. 14. 45-Defendant Maxwell was for decades the highest-ranking employee of the Defendants’ sex trafficking venture and enterprise. She herself recruited young, including underage, females; oversaw and trained other recruiters on how best to recruit girls for sex; developed and executed schemes designed to recruit young females; and ensured that all participants of the Defendants’ sex trafficking scheme EFTA00296282

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 6 of 31 acted in certain specific ways in order to advance the purposes of the scheme-and eoenceaHt, including providing young females to Epstein for sexual purposes on a daily basis, and concealing these activities from law enforcement. 15, 4+6-Defendant | | recruited young females_for Epstein for sexual venture and enterprise, and maintained [J sex schedule in order to ensure that he was not without the-sexualfavers-ef young females for any extended period of time. Defendant [J also handled travel arrangements for the-various females being exploited for sexual purposes. 4 Defendant i i enterprise and reported directly up the line of authority to DefendantDefendants Maxwell_and Epstein. 16. ++Defendant Epstein employed many recruiters of young females. The nature of the Defendants’ sex trafficking sehemeyventure and enterprise enabled victims themselves;sueh-asDefendant EE to elevate their status to that of a paid recruiter of other victims. Recruiters were taught by Defendants Epstein-and, Maxwell_and {ij to inform targeted victims that Epstein possessed extraordinary wealth, power, resources and influence; that he was a philanthropist who would help female victims advance their EFTA00296283

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 7 of 31 careers and lives; and that the recruits needed only to provide Epstein with body massages in order to avail themselves of his financial assistance and influence. In fact, however, these representations were fraudulent. The yast—majerity—of giztsyoung females were_actually required to perform intimate sexual acts at the Defendants’ direction and the Defendants did not help ernor intend to help advance the victims’ careers._Victims were also paid to bring Epstein other young those young females who brought other females would further benefit from bringi id 17. +8-Defendant was _an integral part of the illegal venture an enterprise. if coordinated schedules between Defendant Epstein and the various young females used for sex; made travel arrangements for the gitlsyoung females; tended to theirthe living needs-and-communicated vith them in-_orderto-maiitain their_of those females; communicated and coordinated with Defendants Epstein, Maxwell and to assist in facilitating young females bein available in locations where the other Defendants were traveling; and she carried messages to the young females from the other Defendants including false representations in order to maintain the young females' compliance with the rules of behaviersexual compliance imposed upen-them-by this structured lien EFTA00296284

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 8 of 31 the enterpriseactivities of the venture and enterprise, including the fraudulent representations and other coercion that was being applied to secure the females’ compliance with demands of sex. 18, 4+9:The Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled Epstein'?s compulsive need for sex with young females by preying on their personal, psychological, financial, and related vulnerabilities. The Defendants’ tactics included promising the victims money, shelter, transportation, gifts, employment, admission into educational institutions, educational tuition, protection, and other things of value in exchange for sex.. Defendants also took possession of the victims’ passports to coerce compliance with their demands. rar Defendants also trafficked young females to Epstein’s friends and_ acquaintances in order to secure financial and other benefits as well as social, 19. 20:Defendants’ sex trafficking venture and enterprise operated in a hierarchal structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top-and volume of young females recruited for sex and in insulating the enterprise from Defendant Epstein and Maxwell since_at_least_2002_and_continues_to_work for Defendant Epstein today. and enterprise as early as 2001 and her role in their venture and enterprise was EFTA00296285

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page Y of 31 well-defined_and_ primarily consisted of conspiring in the commission and cover-up of sex crimes. Underlings included the other named Defendants as well as unnamed co- conspirators such as various housekeepers and butlers; an airplane pilot; and various employees, assistants and associates. Wittingly and unwittingly, such underlings performed their respective roles with the purpose and effect of insuring that the enterprise supplied young females to Defendant Epstein and others for sexual purposes. At all times materials to this complaint, the venture and enterprise was a group of two or more individuals associated in fact and deed. 20. 24.Defendants Epstein and Maxwell, with help from assistants, associates and underlings, recruited and procured hundreds of girls over the decades of the operation of their scheme. Such recruitment and procurement included fraud, coercion, threats, intimidation, fear, the threat of coercion, and a combination of these and similar tactics. Following the Defendants’ recruitment and procurement of the_young females to join Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent 6 promises, coercion, and threats of coercion in order to entice youngand coerce the females into sex and, once sexual activities ensued, to cause them to remain in the enterprise. The Defendants also transported females in interstate and foreign commerce and in ways that affected interstate and foreign commerce._The sex acts were commercial in nature, because the Defendants promised to provide financial and other compensation to the females in EFTA00296286

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 1U of 31 exchange for providing sex acts to Epstein. 21, 22-Defendants specifically targeted underprivileged, emotionally vulnerable and/or economically disadvantaged young females to jei—the—Defendants- It is unknown exactly how long Defendant—Epstein—and—Maxwells aferementionedthe Defendants’ criminal and illegal_venture and enterprise operated, although it was at least continuously and actively in operation from the mid-1990’s through and including the calendar year 2007. 23. 24-Defendant Epstein has continued the yenture and enterprise and eenspiraey-up to the present time_in_some form or another and with additional . . i a 24, 25-In 2005, Defendant Epstein and numerous co-conspirators within the venture and enterprise were the subjects of a Palm Beach, Florida Police Department criminal investigation which revealed that Defendant Epstein had engaged in sexual activities with dozens of young teenage school children. Each child identified in that particular investigation was lured into Defendant Epstein’s Palm EFTA00296287

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 10 of 31 Beach mansion with a promise that she would receive money for providing him with a body massage, although once there, each childyoung female was made to engage in a-sex-aetsexual acts in order to receive the promised compensation. 7 Several were also made to engage in sex with another of Defendant Epstein's female sexualtraveling-companionstraveling sex companions who Epstein. referred to as his lesbian sex slave and bragged about purchasing her from 25, 26-In 2006, the Palm Beach Police Department investigation was turned over to the FBI and the United States Attorney's Office for the Southern District of Florida. The United States Attorney's Office investigated Defendant Epstein and his co-conspirators for their violations of numerous federal statutes, including 18 U.S.C. $Section 1591, one of the statutory bases for this complaint. 26. 27.The United States Attorney'’s investigation continued from 2006 through September 2007, at which time a Non-Prosecution Agreement was signed between Jeffrey Epstein and the United States Attorney's Office deferring federal prosecution of Defendant Epstein and his numerous co-conspirators, including Defendants and each named by the Federal Government as co- conspirators. for identified federal sex crimes against more than 30 minors. 27. 28:From late 2006 through September 2007, Epstein's team of lawyers negotiated with the federal government in an effort to avoid the-filing of thea fifty- three-page draftFederal felony indictment offrom being filed against Epstein. During these Is EFTA00296288

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 11 of 31 negotiations, Defendant Epstein decamped from Palm Beach to New York and the U.S. Virgin Islands in order to convey an image to prosecutors that he and his co- conspirators had stopped committing sex crimes. 28. 29:Remarkably, however—as this case will highlight—Defendant Epstein and his co-Defendants, including the other defendants named herein, did 8 not abandon their sex trafficking venture and enterprise even while they were under state and federal investigation for crimes committed in violation of 18 U.S.C. $section 1591, among other laws, and even as Defendants and their attorneys were busy arguing Epstein'’s innocence and publicly defaming his victims as liars. Rather, Defendants merely changed their st}4elocation. Instead of targeting local Palm Beach Florida high-school girls, the Defendants transported young females from other places in the U.S. (including the Southern District of New York) and abroad and brought them to Defendant Epstein’s mansion in New York_City and his private island in the Virgin Islands. 29. 30.In June of 2008, Epstein pleaded guilty to Florida state felony sex offenses for procuring a minor for prostitution and soliciting prostitution by minors_and registered as a Sex Offender for Life. 30. 34-Defendants Epstein and Maxwell developed and implemented a sophisticated system designed to insulate them from criminal and civil liability by protecting them from potential testimony of knowledgeable subordinates. u Defendants and adapted to the system and also carried it out for ars _in_exchan for_ significant pay, benefits, an rotection from EFTA00296289

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 12 of 31 prosecution. The system included requiring subordinates to sign confidentiality agreements covering ei+++-andbarring disclosure of criminal activity; maintaining records of underage females who were abused by Epstein; requiring subordinates and victims to refrain from speaking with law enforcement officials; requiring them to notify Defendant Epstein’s lawyers in the event they (subordinates and victims) were contacted by law enforcement officials; requiring them to accept the representation of attorneys paid for by Defendant Epstein; requiring them to invoke the Fifth Amendment in 9 response to questions they might be asked by investigators and prosecutors; requiring them to invoke the Fifth Amendment in order to refuse to turn over incriminating and non-incriminating evidence to law enforcement officers; requiring them to destroy evidence or refuse to reveal knowledge of destroyed evidence; and requiring them generally to refuse all cooperation with law enforcement officials or investigations. 31, 32-In 2005, Defendant Epstein and other co-conspirators, aware that law enforcement officials were preparing imminently to execute a search warrant effor his home, removed computer systems that logged information about Epstein and his co-conspirators’ illegal and criminal conduct; the identities of witnesses; nude ls photographs of young females; scheduling books; message pads; tangible items such as vibrators and toys; and other incriminating matter. well-defined role and improved in his/her role over time, with practice and EFTA00296290

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 13 of 31 experience. By the time _Plaintiff_was recruited into victimization, each Defendant _had_vyears of experience_perfecting methods of coercion, understanding Epstein's requirements, and becoming more loyal to the continuance and survival of the venture and enterprise. All of the Fd knew about the activities of the venture and enterprise and worked in concert for the goals of the venture and knowingly benefitted, financially and by receiving things of value, from their participation in the venture and enterprise. . A typical way the Defendants procured young females for sex with Defendant Epstein was to make false promises of a modeling opportunity, offer life, off f f Led . ff consideration. 34, [CommencingBeginning in approximately October 2006 and continuing through April 2007, Defendants recruited Plaintiff into their sexual enterprise by fraudulently 7 promising to use their connections and resources to secure her admission to an institution of higher education at the expense of Defendant Epstein. 35, 34-Defendant--was—working—as—One of the enterprise’s many recruiters-of, I EE. was working to recruit young females_for Epstein for sex when she approached and recruited Plaintiff. EFTA00296291

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 14 of 31 40 es) 36. 35-Defendant {J informed Plaintiff that she would introduce Plaintiff to Defendant Epstein, whom she described as a wealthy philanthropist who regularly used his wealth, influence and connections to help financially poor females like Plaintiff achieve their personal and professional goals and aspirations. 37. 36-Defendant {J reported to her superiors, Defendants QR. HE and Maxwell, and was paid for her recruitment of young females, including-the reeruitmentef Plaintiff. 37.Defendant- {J introduced Plaintiff to Defendant Epstein, who confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff oo ee admitted into The Fashion Institute of Technology; (known as “F.I.T.”;) in New York City; or into a similar institute of higher learning offering a curriculum of fashion industry training. Between October 2006 and May 2007, Defendants Maxwell, J. and If each also_confirmed_and reiterated this promise to Plaintiff many times-, each telling Plaintiff that Epstein would use his wealth and connections to advance Plaintiff's education. More specifically, each of the Defendants _last_verified this information that Epstein was using _his connections to ensure Plaintiff was admitted 14 into F.1.T. in exchange for Plaintiff's continued sexual cooperation with Epstein in March or April of 2007. 39, 38-Defendant Maxwell told Plaintiff she would need to provide Defendant EFTA00296292

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 15 of 31 Epstein with body massages in order to reap the benefits of his and connections. 40. All Defendants, including Maxwell, Epstein and knew that Plaintiff was actually being recruited for sexual purposes, and each knowingly and deliberately made false representations to ensure that Plaintiff would cooperate in fulfilling Epstein’s sexual desires. These false _and fraudulent . included Defend > telling Plaintiff that E in would his connections to have her admitted into F.LT. or a similar institute, college, business, financial, social, and educational influence and connections. Epstein and _ the other Defendants represented to Plaintiff_in manners that were persuasive, credible, and reasonable to Plaintiff, as they would have been to any other person similarly situated, that they had the political, business, financial, social, educational, and other influence and is connections sufficient to arrange for and insure her admission into F.LT. or a similar school of higher learning. 41. Maxwell and Epstein also threatened Plaintiff that, while they had the ability EFTA00296293

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 16 of 31 to advance her education and career, they also had the ability to make sure that shePlaintiff would not obtain ne-formal education or modeling agency contracts if she failed to provide the sexual favors desired by Defendant Epstein or abide by the instructions given her by Defendants Epstein, I. EJ and Maxwell. H 42. 39-Plaintiff reasonably believed that her compliance with Defendants’ demands was crucial to her physical, psychological, financial, and reputational well-being and survival. 43. 40:Defendant Maxwell instructed Plaintiff how to massage Epstein using the techniques that heMaxwell knew that Epstein preferred. During Plaintiffs first massage, Defendant Epstein converted it into a sexual act and made it known to Plaintiff that further sex would be required in order for her to obtain the assistance he promised her and to avoid Defendants’ threatened retaliation against her if Plaintiff did not perform as demanded. 44, 41-Defendants—Maxwell and Epstein informed Plaintiff that other young females in Defendant-Epstein’s company were there not-onlyto-provide-massages, but-also to_ perform sexual acts: for Epstein and his friends. ij and helped to secure the presence of the other young females for these purposes, le 45. 42-Plaintiff was instructed dozens of times to provide body massages to Defendant Epstein, both at his townhouse in New York and on his private island in the U.S. Virgin Islands. Each time she was so instructed she was also required to EFTA00296294

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 17 of 31 perform a sexual act with-Defendant Epstein. The Defendants all participated in arranging for Plaintiff_to be transported—PJaintiff in interstate and foreign commerce, and affecting interstate and foreign commerce, for these sexual purposes. The Defendants Epstein, Maxwell, and used possession and control of Plaintiff’s passport to induce and coerce Plaintiff into performing sexual acts with Epstein and others. 46, 43-During many sexual encounters, Defendant Epstein gave Plaintiff no option, opportunity, or choice not to participate in the prescribed sexual acts. 42 7. 44-Defendant Maxwell frequently controlled the assignment, or “rotation,” of Plaintiff and the other young females concerning the time, place and manner of the sex acts they were told to provide to Defendant Epstein. Defendant Maxwell also gave instructions on how to perform certain sexual techniques on Epstein. Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with other females. 48. 45-Defendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance. These Defendants threatened Plaintiff with serious harm, as well as serious IS psychological, financial, and reputational harm, withthe-purpese-and-effect-of EFTA00296295

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 18 of 31 compelling Plaintiff to perform and continue performing the demanded-commercial sexual activity demanded by Defendants. 49. 46-On one occasion, after suffering verbal abuse and threats by Defendants Epstein, Maxwell, and Qj. Plaintiff attempted to escape from Defendant Epstein’s private island. A search party led by DefendantDefendants Epstein_and Maxwell located her and physically returned her to the main house on the island. Through these and other actions, the Defendants intended to cause, and did cause, Plaintiff to believe that failure to perform the actions they requested would result in physical restraint and potential harm to her person, as well as harm to her reputation, employability, and stable state of mind. Defendants further used possession and Lof Plaintiff jithout lawful hority . Plaintiff's lil I thereby force} id Epstei B 50. 47.Defendant Epstein’s wealth, influence, power and connections were used by Defendants Maxwell, SM. and MM. both as an inducement to provide sex (in exchange for promises of support_to_ Plaintiff); and as a means of threatening punishment (shev/din the event Plaintiff sefuserefused to comply with Defendants’ instructions to provide sex to Epstein and others). 1. 48.In addition to Plaintiff's being trafficked on Defendant-Epstein'’s private planeairplane, Defendants JP Maxwell and [with the knowledge of and instruction by Defendant Epstein, arranged Plaintiff's living accommodations, private car travel, EFTA00296296

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 19 of 31 18 and commercial air travel on numerous occasions for the purpose of causing Plaintiff to commit commercial sex acts._These Defendants worked in concert with one another to recruit, procure, entice, and otherwise cause many other females to engage in commercial sex acts, through their use of threats, fraud, and coercion. Among these means of coercion were the Defendant’s possession and control of the females’ passports and other immigration documents. This coercion was most salient, and especially effective, while the females, including Plaintiff, were on Epstein’s island. 52. 49-In furtherance of their venture and enterprise, Defendants provided living quarters for Plaintiff at 301 East 66th Street, New York, in the Southern District of New York; a car service for Plaintiff to use as needed; a cell phone; and other valuable consideration in order to maintain Plaintiff's sexual compliance. Each of the Defendants told Plaintiff she would obtain the benefits of a place to live and phone and transportation as long as she remained compliant with their demands that she service Epstein sexually. Each of the Defendants also told her that if she was not compliant, these benefits would be taken from Plaintiff. 53. 50.The relationship between Plaintiff and Defendants Epstein and Maxwell was defined and characterized by Defendant Epstein’s and Defendant Maxwell’s frequent and persistent fraudulent representations that they would provide Plaintiff with a formal education and career advancement if she provided sex to Defendant Ike EFTA00296297

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 20 of 31 Epstein and others in the times, places and manners demanded by Defendants. Defendants and each also told Plaintiff that Defendant Epstein would advance Plaintiff's education and career in order to coerce Plaintiff into career. As a result of these and other representations by Defendants, Plaintiff reasonably relied on thesethese representations. In fact, however, thesethese representations were knowingly false, were not acted upon_by Defendants, and were made by Defendants Epstein, J. WE. and Maxwell solely for the purpose of maintaining 44 Plaintiff's financial dependence on, emotional vulnerability to, and sexual compliance with DefendantsDefendant Epstein-andMaxwel-andtheir’s demands. The other Defendants intentionally repeated thesethese representations and intentionally attemptedmade statements designed to convince Plaintiff that the representations were true and could be relied upon._These representations and_ statements were made to Plaintiff in furtherance of the sex trafficking venture and enterprise for which they were each employed. 54, As part of the venture and enterprise, Defendants Epstein, Maxwell, and || took possession of Plaintiff's passport when she was being trafficked by Islands. The Defendants took possession of Plaintiff's passport in the course of sexually trafficking Plaintiff and with the intent to violate laws against sex trafficking, including 18 U.S.C. 1591 et. seg. The Defendants used their control f Plaintiff” 20 EFTA00296298

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 21 of 31 passport in order to coerce compliance with their demands, including their demands that Plaintiff have sex with Epstein and others. 55. 54-In January 2007, as_part of their illegal venture _and_enterprise, Defendants sent Plaintiff from the-United-StatesNew York City, in the Southern District of New York, to South Africa-in-part to recruit, for a promised fee, one or more aspiring female models supposedly for Defendant-Epsteinto-use-as-an-aleged personatassistant—Epstein to use as a personal assistant. The Defendants did not care whether the prospective female was qualified to work as _a_ personal assistant because each knew that the female recruit would be immediately placed into the same sexually vulnerable position as Plaintiff (and the dozens of other victims of the sex trafficking enterprise) and would be induced and coerced into being used for sex through fraudulent representations and other means. 56. Defendants Epstein and Maxwell continuously and frequently demanded that Plaintiff fulfill this task of bringing another female back to the United States and Defendants’ control as a condition of herPlaintiffs receiving the education, career and related benefits promised by Defendants Epstein and Maxwell. Based upon Plaintiff's experience with Defendants, however, she did-net-believeknew that the requested female model would not be placed in a legitimate position of employment with Defendant Epstein but would, instead, be forced into sexual servitude. Plaintiff also knew that this objective was the only purpose of Defendants | i. EFTA00296299

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 22 of 31 1 Maxwell and Epstein’s demand for Plaintiffs recruitment efforts, As a result, Plaintiff deliberately refused to perform the recruitment assignment. 57. 52-:As part of their ongoing scheme, Defendants inflicted serious emotional and psychological harm on Plaintiff as a means of coercing her to continue engaging in commercial sex acts_with Epstein and others. While Plaintiff was in South Africa, Defendants Epstein and Maxwell informed Plaintiff that she would not be permitted to return to the United States to receive her promised education unless she underwent a diet and lowered her body weight from 57 kilograms +5 (approximately 125 pounds) to 52 kilograms (approximately 114 pounds). Epstein and Maxwell promised Plaintiff that, if she complied, she would veceiv e her promised cu Defendant P| Sn Plaintiff's urelets in Tr meleht and continued to communicate with Plaindtl, about - ted rm help further that coercion, «Believing she had no ne choice in the matter, Plaintiff attempted to comply with the order but, given her physical height and body structure and her already existing+ew body weight, the diet imposed upon her placed her in serious physical jeopardy, including kidney malfunction and extreme emotional and psychological distress. Is 58. 53:As_part of their_scheme, Defendants Epstein and Maxwell called Plaintiffs parents in South Africa to tell them that DefendantsDefendant Epstein would take good care of Plaintiff when she returned to the United States, and that theyDefendants Maxwell and Epstein would use their connections and influence EFTA00296300

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 23 of 31 to have her admitted to F.L.T. or another well-regarded fashion school_or school of higher learning. 59. _As part of their scheme, Epstein and told Plaintiff that she should fill out an application for admission to F.I.T., and supporting essay, and send it to Epstein for his review. Pursuant to these instructions, Plaintiff completed an application, and supporting essay, and sent it to Epstein. As part of his scheme, 60. As part of their scheme, Epstein and Maxwell told Plaintiff that they had contacts at F.1.T. and at modeling agencies who could ensure her admission to 23 ntacts, in addition to those identified above, throughout New York City an elsewhere. 61. 54:In February of 2007, in reliance on promises made by the Defendants, Plaintiff returned to New York City, in the Southern District of New York, and EFTA00296301

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 24 of 31 was promptly ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants Maxwell, J. HB. and Epstein_each fraudulently promised herPlaintiff again that her sexual compliance would be rewarded with admission to F.1.T. or a comparable college, a promise which they knew-te-befalseeach knew to be false. In fact all four Defendants had for years worked solely to recruit crimes like those committed against Plaintiff. Plaintiff knew that if she did not comply, Defendants Maxwell and Epstein would use their power, influence and connections in order to ensure that Plaintiff was unable to gain admission to F.I.T. or a comparable school, and that they would destroy her career,_just as they had destroyed the careers of others who had failed to comply_with their demands. 62, 55-Defendants Epstein and Maxwell continued to provide Plaintiff with things of value in exchange for Plaintiffs continued compliance with Epstein!’s 46 sexual demands; however, they failed and refused to perform their promises to help Plaintiff be admitted to F.I.T. or another school, or to provide financial support for 24 college admission or on-going education, false promises they repeatedly made in order to coerce her into commercial sex acts. 63, 56-Defendants—Epstein—and—Maxiwell's’? sexual demands on Plaintiff continued while she was in New York erothergeegraphieCity, in the Southern District of New York, or in other locations in close proximity to the Defendants. EFTA00296302

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 25 of 31 In addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, each of the Defendants continued to pressure her to lose excessive amounts of body weight and offered her no opportunity to decline or resist their instructions. 64, 54In May, 2007, Plaintiff left the United States and did not return. Between returning from South Africa in February 2007 and leaving in May 200 Defendan and Maxwell each continued to _r ly_mak fraudulent promises in order to have sex with Plaintiff. 65. In and after May 2007, Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females. Defendant’s cover-up included efforts to intimidate witnesses who might provide corroborating testimony to Plaintiff_as well _as_ destruction of ocuments and other evidence regarding what they had done. I 66. 58-Unknown to Plaintiff, Defendants’ representations and promises_to Plaintiff were all false and fraudulent. Fheitthreats4vereconsidered by Plaintiff reasonably relied on the representations and promises of the Defendants. Plaintiff also considered the Defendants’ threats against the current and future well-being and safety of Plaintiff to be real and credible. All such representations, promises, and threats were made solely for the purpose of coercing and otherwise EFTA00296303

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 26 of 31 inducing Plaintiff into prolonged sexual compliance. Defendants knowingly benefitted financially and received things of value as a result of theircoercing and inducing Plaintiff into sexual compliance and otherwise participating in their illegal venture and enterprise. COUNT I CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 18 U.S.C. § 1595 67. 59-Plaintiff adopts and realleges paragraphs | through 5866 above. H 68. 60-Defendants individually and together, within the special maritime and territorial jurisdiction of the United States, in interstate and foreign commerce, and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, maintained, patronized, solicited, threatened, forced, and coerced Plaintiff to engage in commercial sex acts. Such actions by Defendants were undertaken with knowledge and/or reckless disregard of the fact that their threats of force, fraud, coercion, and combinations of such means would IR be used, and were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In so doing, Defendants violated 18 U.S.C. §$1591-+threugh—_1594 and§1591, EFTA00296304

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 27 of 31 together, knowingly concealed, removed, confiscated, and possessed Plaintiff's passport and associated immigration documents, in the course of violating 18 U.S.C. § 1591, and with the intent of violating 18 U.S.C. § 1591, and to prevent. restrict, attempt to restrict, without lawful authority, Plaintiff's liberty to move or travel. in order to maintain the sexual services of Plaintiff, while Plaintiff was a victim of a severe form of sex trafficking, a fined in section 1 f th Trafficking Victims P ion Act of 2000 Lin 22 U.S.C. § 7102.1 ing, Defendants violated 18 U.S.C. § 1592. These Defendants al: truct I tool 1 to interfere with the enf £18 U.S.C. § 70. Additionally, Defendants knowingly benefitted, financially and by in_a venture (the Epstein sex S.C. § 1592 and 1595(a), knowing that the venture had engaged in such violations. In so doing, Defendants violat S.C. § 1593 A, 1. Additionally, Defendants attempted to violate 1 S.C. § 1591. In loing, Defend iolated 18 U.S.C. § 1594(a) IS 2. Additionally, Defendants conspir ith each other, and with other rsons_known an nknown, to violate 1 1592. In in Defendants violated 18 U.S.C. § 1594(b). 73. Additionally, Defendants conspired with each other, and with other EFTA00296305

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 28 of 31 rsons known and unknown, to violate 18 U.S.C. 1591. In so doin Defendants violated 18 U.S.C. § 1594(c). 4. By virt f their violations of 18 U.S.C. §§ 1591, 1592, 1593A, and 1594 Defendants are subject to civil causes of action under 18 U.S.C. § torts-and_crimes-deseribed-in-this-complaint1595 by Plaintiff, who is a victim of their violations. 75. 62-Certain property of Defendant Epstein's was essential to the commission of the federal crimes and torts described herein, including the use of multiple private aircraft including a Boeing aircraft (of make and model B-727- 31H with tail number N9O8JE) and a Gulfstream aircraft (of make and model G- 1159B with tail number N909JE). Such aircraft, along with other of Defendants’ 48 property, were used as means and instruments of Defendants’ tortious and criminal offenses and, as such, are subject to forfeiture. 6. 63-Additionally, Defendant Epstein’s New York mansion, located at 9 East 71st Street, New York, New York, in the Southern District of New York, and his private island located in the United States Virgin Islands, were used as means and instruments of Defendants’ tortious and criminal offenses and, as such, are subject to EFTA00296306

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 29 of 31 forfeiture. 71. 64-As a direct and proximate result of Defendants’ commission of the aforementioned criminal offenses enumerated in+itle 18 U.S.C. § 459+-et-seq- 1591, 1592, 1593A, and 1594, and the_associated civil remedies provided in § 1595, Plaintiff has in the past suffered and will continue to suffer injury and pain; emotional distress; psychological and psyehi—atriepsychiatric trauma; mental anguish; humiliation; confusion; embarrassment; loss of self- esteem; loss of dignity; loss of enjoyment of life; invasion of privacy; and other damages associated with Defendants' actions. Plaintiff will incur_further medical and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to these losses, Plaintiff has incurred attorneys’ fees and will be required do so in the future. WHEREFORE, Plaintiff demands judgment against Defendants for compensatory and general damages, attorney'’s fees, punitive damages and such other and further relief as this Court deems just and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury. Dated: January26,2047June 5, 2017. Respectfully Submitted, EFTA00296307

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 3U of 31 29 EFTA00296308

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 By: ss A Bradley J. Edwards Bradley J. PRO HAC VICE BOIES, SCHILLER & FLEXNER LLPBy+/s# David Boies —David- Botes Boies Schiller & Flexner LLP Sigrid McCawley Meredith Schultz Boies Schiller & Flexner LLP Paul G Cassell HB. Quinney College of Law at the University of Utah PRO HAC VICE EFTA00296309

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 EFTA00296310

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 31 of 31 CERTIFICATE OF SERVICE » 5th day » 2 foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via STEPTOE & JOHNSON, LLP Michael C. Miller Justin Y.K. Chu Jeffrey Epstein & Stn baci = ALSTON & BIRD, LLP John E, Stephenson, Jr, Alexander S. Lorenzo Attorneys for Defer EZ By: Ls/ Bradley J. Edwards SS te » Patti 2 al ie - o EFTA00296311

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 31 of 31 ee EFTA00296312