DataSet-9
EFTA00156974
1 pg
…who was also a victim but also used (or coerced) to
procure or befriend other kids.
• Does not specifically use the term "grooming the environment," but this is part of her views in general about
grooming.
• Perpetrators put themselves in…
DataSet-9
EFTA00731326
9 pg
… 9. Defendant engaged in a plan and scheme
in which he gained access to primarily economically disadvantaged minor girls in his home,
sexually assaulted these girls and/or coerced them to engage in prostitution, and in return gave
them money…
DataSet-9
EFTA00201211
18 pg
…¶ 10). It is further
alleged that from June 2002 until approximately August of 2003 the Defendant coerced and
enticed the minor plaintiff to commit various acts of sexual misconduct and that these acts
occurred, on average, one to three times…
DataSet-9
EFTA00801525
19 pg
…They are irrefutable proof that Plaintiff was too sophisticated to be defrauded, too
independent to be coerced, and that any alleged conduct even remotely supportive of Plaintiff's
cause of action occurred more than ten years before the Complaint was…
DataSet-9
EFTA00583385
4 pg
…There is no reality to the notion that Epstein somehow
coerced the United States government into a non-prosecution agreement by improper means.
There are a number of legal issues that the Court will be called upon to resolve that…
DataSet-9
EFTA00157731
91 pg
…gained access to economically disadvantaged
minor girls, such as Plaintiff, sexually assaulted these girls, and/or coerced
them to engage in prostitution, and in return gave these girls money.
10. The Defendant's plan, scheme and enterprise included an elaborate
…
DataSet-9
EFTA00086685
27 pg
…he "assembl[ed] a large, cult-like network ofunderage girls—with the help of young female
recruiters" (including Maxwell)—whom he coerced into performing sex acts "behind the walls ofhis opulent
waterfront mansion," among other locations, "as often as three…
DataSet-9
EFTA00210743
4 pg
…There is no reality to the notion that Epstein somehow
coerced the United States government into a non-prosecution agreement by improper means.
There are a number of legal issues that the Court will be called upon to resolve that…
DataSet-9
EFTA00307096
25 pg
…and wholly conclusory, as exemplified by
the allegations in paragraph 48 that "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…
DataSet-9
EFTA00728009
24 pg
…because of [him]"); 47(b) (S. told the FBI under oath that Epstein never kissed, touched or
treated her "in a sexual way" but in her second amended complaint alleged that Epstein "coerced
[her] . . . to commit various acts of sexual…
DataSet-9
EFTA00221227
9 pg
…enticement
(a) Whoever knowingly persuades, induces, entices, or coerces any
individual to travel in interstate or foreign commerce, or in any Territory or
Possession of the United States, to engage in prostitution, or in any sexual
activity for which any…
DataSet-9
EFTA01249131
45 pg
…was then fifteen years old) to come to Epstein's
mansion in a fashion very similar to the manner in which Epstein and his other co-conspirators
coerced dozens of other children (including Jane Doe M and Jane Doe MI)…
DataSet-9
EFTA01070451
50 pg
…part that "beginning In approximately late May or early June of
2002, and continuing until approximately August of 2003, the Defendant coerced and
enticed the impressionable, vulnerable, and economically deprived then minor Plaintiff
to commit various acts of sexual misconduct…
DataSet-9
EFTA00221995
10 pg
…enticement
(a) Whoever knowingly persuades, induces, entices, or coerces any
individual to travel in interstate or foreign commerce, or in any Territory or
Possession of the United States, to engage in prostitution, or in any sexual
activity for which any…
DataSet-9
EFTA00592738
4 pg
…There is no reality to the notion that Epstein somehow
coerced the United States government into a non-prosecution agreement by improper means.
There are a number of legal issues that the Court will be called upon to resolve that…
DataSet-9
EFTA00207677
36 pg
…16]. Plaintiff further alleges that —
Beginning in approximately February 2003 and continuing until
approximately June 2005, the defendant coerced and enticed the
impressionable, vulnerable, and economically deprived then minor Plaintiff
in order to commit various acts of sexual misc…
DataSet-9
EFTA00075477
74 pg
…20, 35-36 (1984) ("The prevention of the abuse that can attend the
coerced production of information under a State's discovery rule is sufficient
justification for the authorization of protective orders.").
The district court thought otherwise. But in ruling…
DataSet-9
EFTA00285477
14 pg
…and wholly conclusory, as exemplified by
the allegations in paragraph 45 that "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…
DataSet-9
EFTA00298455
10 pg
…the Defendants.
B. The Complaint Fails to Plead Coercion
The Complaint fails to allege that Epstein or =engaged in any conduct which coerced
the Plaintiff to perform sexual acts. The statute defines coercion to include the following
categories of conduct…
DataSet-9
EFTA00103709
25 pg
…enticed, and coerced" an individual identified as
Minor Victim-1 to travel from Florida to New York "with the intention that Minor Victim-1
would engage in one or more sex acts with Jeffrey Epstein, in violation of New York…
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