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 EFTA00615970

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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 COMPLAINT CASE NO.:.1:17-CV-00616 JANE DOE 43, J tL R ¥ YY R } ~ | D E M o’ N dD E b Plaintiff .} vs. JEFFREY EPSTEIN, GHISLAINE MAXWELL Defendants. i FIRST AMENDED COMPLAINT Plaintiff JANE DOE 43, by and through her undersigned counsel, for her EFTA00615971

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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, IS EE. EE HE and BR 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 Plaintiffs-name-publich—wilwhich, 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 } 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. EFTA00615972

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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 [I] I vi iii 8. Atall times material to this cause of action J I was 9. 40A+neliding—because-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) tN 10. +4-At all times material to this cause of action, Defendants Jeffrey Epstein, Ghislaine Maxwell, [i T. and BS ER oc RE 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 #tegatacts against her-., including any acts in violation of 18 U.S.C. §1595. FACTUAL ALLEGATIONS EFTA00615973

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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 EFTA00615974

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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 EFTA00615975

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acted in certain specific ways in order to advance the purposes of the scheme-and eeneea it from law enforcement. Recruiters were taught by Defendants Epstein-and Maxwell 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 EFTA00615976

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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. Po Po and the Defendants did not help ernor intend to help advance the victims’ careers. EFTA00615977

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49:The Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled Epstein’s compulsive need for sex with young females by preying on their S$ personal, psychological, financial, and related vulnerabilities. The Defendants’ tactics included promising the victims money, shelter, transportation, employment, admission into educational institutions, educational tuition, and other things of value in exchange for sex. 20.:Defendants’ sex trafficking venture and enterprise operated in a hierarchal structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top-and # | alin x5 b a} yy EFTA00615978

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page Y of 31 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 8 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 EFTA00615979

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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. that they were wealthy, well-connected and could either help or hurt the females depending on their degree of cooperation. In fact, Defendants Epstein It is unknown exactly how long 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 eonspiraey-up to the present time_in_some form or another and with additional co-conspirators and participants. 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 ;n ee EFTA00615980

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 10 of 31 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. 2%The United States Attorneys 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 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-fling of thea fifty- three-page draftFederal felony indictment offrom being filed against Epstein. During these lS EFTA00615981

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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 $ not abandon their sex trafficking yenture and enterprise even while they were under state and federal investigation for crimes committed in violation of 18 U.S.C. Ssection 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 st4elocation. 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 EFTA00615982

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32:In 2005, Defendant Epstein and other co-conspirators, aware that law enforcement officials were preparing imminently to execute a search warrant eff his home, removed computer systems that logged information about Epstein and his co-conspirators’ illegal and criminal conduct; the identities of witnesses; nude photographs of young females; scheduling books; message pads; tangible items such as vibrators and toys; and other incriminating matter. EFTA00615983

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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 years 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 Defendant’s 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. 33._A_ typical J the Defendants procured young females for sex _with Defendant Epstein was to make false promises of a modeling opportunity, offer a_better life, offer payment for a formal education, or offer other money or consideration. 34. 326 sineBeginning in approximately October 2006 and continuing through April 2007, a 13 EFTA00615984

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39. 38-Defendant Maxwell told Plaintiff she would need to provide Defendant EFTA00615985

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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 Maxwell's connections. 40. All Defendants, including Maxwell, Epstein TTT 0 that Plaintiff was actually being recruited for sexual purposes, andfeach knowingly and deliberately made false representations to ensure that Plaintiff would cooperate in fulfilling Epstein’s sexual desires. These false and fraudulent hi nnections to have her admitted int r_a similar institut LI 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 int ora similar school of higher learning. 41. Maxwell and Epstein also threatened Plaintiff that, while they had the ability EFTA00615986

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to advance her education and career, they also had the ability to make sure that she would obtain ne-formal education Po if she failed to provide the sexual favors desired by Defendant Epstein or abide by the instructions given her by Defendants Epstein, J. IJ and Maxwell. dh 39-Plaintiff reasonably believed that her compliance with Defendants’ demands was crucial to her physical, psychological, financial, and reputational survival. 44-Defendants—Maxwell and Epstein informed Plaintiff that other young females in Defendant-Epstein’s company were there but-also sexual acts: EFTA00615987

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transported—PiaintH#f in interstate and foreign commerce, and affecting interstate and foreign commerce, for these sexual purposes. 42 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. Po psychological, financial, and reputational harm, withthe-purpese-and-effect of EFTA00615988

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at 4+Defendant Epstein’s wealth, influence, power and connections were used la HB. both as an inducement to provide sex (in exchange for promises of support ); and as a means of threatening punishment (skewed Plaintiff refuse: to comply with Defendants’ instructions ). 48.In addition to Plaintiff's being trafficked on Defendant-Epstein"’s private plane , Defendants J. Maxwell and . with the knowledge of and EFTA00615989

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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 EFTA00615990

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Epstein and others in the times, places and manners demanded by Defendants. reasonably relied on these representations. In fact, however, these representations were knowingly false, were not acted upon , and were made by Defendants Epstein, i. IB. and Maxwell solely for the purpose of maintaining +4 Plaintiff's financial dependence on, emotional vulnerability to, and sexual compliance with Defendants Epstein-and Maxwellandtheir’s demands. The other Defendants intentionally repeated these representations and intentionally attempted to convince Plaintiff that the representations were true and could be relied upon. EFTA00615991

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S41n January 2007, Defendants sent Plaintiff from the-United-States to f | GB in-part to recruit, for a promised fee, one or more aspiring female models supposedly for EFTA00615992

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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 . While Plaintiff was in MMB. 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 FP 83. Defendants Epstein and Maxwell called Plaintiff’s parents in |] IJ to tell them that Defendants would take good care of Plaintiff when she returned to the United States, and that they would use their connections and influence EFTA00615993

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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 a. 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 o 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. Id Plaintiff that he h view ials. Hi 60. As part of their scheme, Epstein and Maxwell told Plaintiff that they had contacts at na at modeling agencies who could ensure her admission to 23 ontacts, in addition to those identified above, throughout New York City and elsewhere. 61. 54.In February of 2007, in reliance on promises made by the Defendants, Pain aa EFTA00615994

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 24 of 31 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 fio: 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 Hor 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—_Marxwell!'s’? sexual demands on Plaintiff continued while she was in New York er-other-geegraphieCity, in the Southern proximity to the Defendants. EFTA00615995

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57-In May, 2007, Plaintiff left the United States and did not return. 38. Defendants’ representations and promises were all false and fraudulent. + Plaintiff to be real and credible. All such representations, promises, and threats were made solely for the purpose of coercing and otherwise EFTA00615996

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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, EFTA00615997

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 27 of 31 doing, Defendants violated 18 U.S.C. § 1592. These Defendants also obstructed, and attempted to obstruct and to interfere with the enforcement of 18 U.S.C. § 1592. 70. Additionally, Defendants knowingly benefitted, financially and by receiving things of value, from participating in a venture (the Epstein sex trafficking venture enterprise) which had engaged in acts in violation of 18 U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in such violations. In so doing, Defendants violated 18 U.S.C. § 1593A. 71. Additionally, Defendants attempted to violate 18 U.S.C. § 1591. In so doing, Defendants violated 18 U.S.C. § 1594(a). nm 72. Additionally, Defendants conspired with each other, and with other persons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants violated 18 U.S.C. § 1594(b), 73. Additionally, Defendants conspired with each other, and with other EFTA00615998

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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 EFTA00615999

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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: Janvary26,2017June 5, 2017. Respectfully Submitted, oe SSL = EFTA00616000

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 3U of 31 29 EFTA00616001

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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. BOIES, SCHILLER & FLEXNER aden David Boies —David- Sigrid McCawley Meredith Schultz HAC VICE-+0-befited S.J. Quinney College of Law at the University of Utah PRO HAC VICE EFTA00616002

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 EFTA00616003

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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 & | | | By: 4/ Bradley J. Edwards-Farmerteffe- EFTA00616004

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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 31 of 31 ee EFTA00616005