EFTA00596325.pdf
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
CASE NO.:
P.C.
Plaintiff,
vs.
JEFFREY EPSTEIN,
GHISLAINE MAXWELL,
LPSLEY R FF
AND
Defendants.
COMPLAINT
Plaintiff P.C., by and through her undersigned counsel, sues the Defendants
Jeffrey Epstein, Ghislaine Maxwell, Lesley Groff and a
and alleges as follows:
1. This cause of action arises under federal statute 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 and
disclosure of Plaintiffs name publicly will cause further harm to her.
EFTA00596325
3. At all 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 and the United States
Virgin Islands. He is currently a citizen of the United States and a resident of the
U.S. Virgin Islands.
5. At all times material to this cause of action Defendant Jeffrey Epstein was an
adult male born in 1953.
6. At all 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. At all times material to this cause of action_was residing in
New York, New York, and, on information and belief, was a citizen of New York.
8. At all times material to this cause of action Lesley Groff was a residing in
New York, New York and, on information and belief, was a citizen of New York
9. At all material times, was residing in New York, New
York and, on information and belief, was a citizen of New York.
10. Because a substantial part of the 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)b(2)
2
EFTA00596326
11. At all times material to this cause of action, Defendants Jeffrey Epstein,
Ghislaine Maxwell, .,esley Groff, and owed a
duty to Plaintiff to treat her in a non-negligent manner and not to commit or
conspire to commit intentional or tortious illegal acts against her.
FACTUAL ALLEGATIONS
12. At all times material to this cause of action Defendant Jeffrey Epstein was an
adult male over 50 years old. Defendant Epstein is known as a billionaire who
uses his extraordinary wealth to commit illegal sexual crimes in violation of
federal and state statutes and to employ numerous others, including the named
Defendants, to conspire and assist in committing those crimes and additional torts
as well as to protect and conceal his crimes and torts from being discovered.
13. 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. He owned and owns 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 mansion in London, England; a home in Paris,
3
EFTA00596327
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.
14. Defendant Epstein has a compulsive sexual preference for young females as
young as 13 and as "old" as 25. Defendant had sex with young females virtually
every day and assisted in the development and execution of a sex trafficking
scheme designed to fulfill his sexual desires.
15. Defendant Maxwell was for decades the highest-ranking employee of the
Defendants' sex trafficking enterprise. She herself recruited young 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 acted in certain specific
ways in order to advance the purposes of the scheme and conceal it from law
enforcement.
16. Defendant recruited young females and maintained Epstein's sex
schedule in order to ensure that he was not without the sexual favors of young
females for any extended period of time. Defendant also handled travel
arrangements for the various females being exploited for sexual purposes.
4
EFTA00596328
Defendant reported directly up the enterprise's line of authority to
Defendant Maxwell.
17. Defendant Epstein employed many recruiters of young females. The nature
of the Defendants' sex trafficking scheme enabled victims themselves, such as
Defendant to elevate their status to that of a paid recruiter of other
victims. 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 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 vast
majority of girls were required to perform intimate sexual acts at the Defendants'
direction and the Defendants did not help or intend to help advance the victims'
careers.
18. Defendant Groff coordinated schedules between Defendant Epstein and the
various young females used for sex; made travel arrangements for the girls; tended
to their living needs; and communicated with them in order to maintain their
compliance with the rules of behavior imposed upon them by the enterprise.
19. The Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled
Epstein's compulsive need for sex with young females by preying on their
5
EFTA00596329
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
underlings below. 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 maximized the number of young females made
available for sexual purposes to Defendant Epstein and others. At all times
materials to this complaint, the venture and enterprise was a group of two or more
individuals associated in fact and deed.
21. Defendants Epstein and Maxwell, with help from assistants, associates and
underlings, recruited and procured hundreds of females over the decades of the
operation of their scheme. Such recruitment and procurement included fraud,
coercion, the threat of coercion, and a combination of these and similar tactics.
Following the Defendants' recruitment and procurement of the females to join
Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent
6
EFTA00596330
promises, coercion, and threats of coercion in order to entice young 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.
22. Defendants specifically targeted underprivileged, emotionally vulnerable
and/or economically disadvantaged young females to join the Defendants'
enterprise.
23. It is unknown exactly how long Defendant Epstein and Maxwell's
aforementioned criminal and illegal enterprise operated, although on information
and belief Plaintiff alleges that it was at least continuously and actively in
operation from the mid-1990's through and including the calendar year 2007.
24. Plaintiff also alleges on information and belief that Defendant Epstein has
continued the scheme up to the present time.
25. In 2005, Defendant Epstein and numerous co-conspirators within the
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 children. Each child was lured into
Defendant Epstein's Palm Beach mansion with a promise that she would receive
money for providing him with a body massage, although once there, each child
was made to engage a sex act in order to receive the promised compensation.
7
EFTA00596331
Several were also made to engage in sex with another of Defendant Epstein's
female sexual traveling companions.
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.
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 for identified
federal sex crimes against more than 30 minors.
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 the fifty-
three-page draft indictment of Epstein. During these 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.
29. Remarkably, however—as this case will highlight—Defendant Epstein and
his co-Defendants, including the other defendants named herein, did not abandon
8
EFTA00596332
their sex trafficking 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 style. Instead of targeting local Palm Beach Florida high school
girls, the Defendants transported young females from other places in the U.S. and
abroad and brought them to Defendant Epstein's mansion in New York and his
private island in the Virgin Islands.
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. He
avoided state prison and, instead, served part of an 18-month "soft" jail sentence
consisting primarily of day-time release to a nearby private office where, among
other liberties, he surfed the internet and communicated with past victims.
31. 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. The
system included requiring subordinates to sign confidentiality agreements covering
civil and criminal activity; 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
9
EFTA00596333
law enforcement officials; requiring them to accept the representation of attorneys
paid for by Defendant Epstein; requiring them to invoke the Fifth Amendment in
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.
32. In 2005, Defendant Epstein and other co-conspirators, aware that law
enforcement officials were preparing imminently to execute a search warrant of 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.
SPECIFIC FACTS
33. Commencing in approximately October 2006 and continuing through April
2007, Defendants recruited Plaintiff into their sexual enterprise by promising to
use their connections and resources to secure her admission to an institution of
higher education at the expense of Defendant Epstein.
I0
EFTA00596334
34. Defendant was working as one of the enterprise's recruiters of
young females when she approached and recruited Plaintiff.
35. Defendant 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.
36. Defendant reported to her superiors, Defendants Groff and
Maxwell, and was paid for her recruitment of young females, including the
recruitment of Plaintiff.
37. Defendant introduced Plaintiff to Defendant Epstein, who
confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff
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. Defendants Maxwell, and Groff each confirmed
this promise to Plaintiff many times.
38. Defendant Maxwell told Plaintiff she would need to provide Defendant
Epstein with body massages in order to reap the benefits of his and Maxwell's
connections. Maxwell and Epstein also made known to Plaintiff that, while they
had the ability to advance her education and career, they also had the ability to
make sure that she would obtain no formal education or modeling agency contracts
11
EFTA00596335
if she failed to provide the sexual favors desired by Defendant Epstein or abide by
the instructions given her by Defendants Epstein and Maxwell.
39. Plaintiff reasonably believed that her compliance with Defendants' demands
was crucial to her physical, psychological, financial and reputational survival.
40. Defendant Maxwell instructed Plaintiff how to massage Epstein using the
techniques that he preferred. During Plaintiff's 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.
41. Maxwell and Epstein informed Plaintiff that other young females in
Epstein's company were there not only to provide massages, but also sexual acts.
42. Plaintiff was instructed dozens of times to provide body massages to
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 perform a
sexual act with Epstein. The Defendants transported Plaintiff in interstate and
foreign commerce, and affecting interstate and foreign commerce, for these sexual
purposes.
43. During many sexual encounters, Defendant Epstein gave Plaintiff no option,
opportunity or choice not to participate in the prescribed sexual acts.
44. Defendant Maxwell frequently controlled the assignment, or "rotation," of
Plaintiff and the other young females concerning the time, place and manner of the
12
EFTA00596336
sex acts they were told to provide to Defendant Epstein. Defendants Maxwell and
Epstein also required Plaintiff to engage in sex acts with other females.
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, including psychological,
financial, and reputational harm, in ways and means that, under the surrounding
circumstances, would have compelled any reasonable person of the same or similar
background and circumstances as Plaintiff's to perform and continue performing
the demanded commercial sexual activity.
46. On one occasion, after suffering verbal abuse and threats by Defendants
Epstein, Maxwell, and Plaintiff attempted to escape from Defendant
Epstein's private island. A search party led by Defendant Epstein located her and
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.
47. Defendant Epstein's wealth, influence, power and connections were used
both as an inducement to provide sex (in exchange for promises of support), and as
13
EFTA00596337
a means of threatening punishment (should Plaintiff refuse to comply with
Defendants' instructions).
48. In addition to Plaintiff's being trafficked on Epstein's private plane,
Defendants Groff, Maxwell and , with the knowledge of and instruction by
Defendant Epstein, arranged Plaintiffs commercial air travel on numerous
occasions for the purpose of causing Plaintiff to commit commercial sex acts.
49. Defendants provided living quarters for Plaintiff at 301 East 66 Street, New
York; a car service for Plaintiff to use as needed; a cell phone; and other valuable
consideration in order to maintain Plaintiffs sexual compliance.
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 representations that they would provide Plaintiff with a
formal education and career advancement if she provided sex to Defendant Epstein
and others in the times, places and manners demanded by Defendants. Plaintiff
reasonably relied on those representations. In fact, however, those representations
were knowingly false, were not acted upon, and were made by Defendants Epstein
and Maxwell solely for the purpose of maintaining Plaintiffs financial dependence
on, emotional vulnerability to, and sexual compliance with Defendants Epstein and
Maxwell and their demands. The other Defendants intentionally repeated those
14
EFTA00596338
representations and intentionally attempted to convince Plaintiff that the
representations were true and could be relied upon.
51. In January 2007, Defendants sent Plaintiff from the United States to South
Africa in part to recruit, for a promised fee, one or more aspiring female models
supposedly for Epstein to use as an alleged personal assistant. Epstein and
Maxwell continuously and frequently demanded that Plaintiff fulfill this task as a
condition of her receiving the education, career and related benefits promised by
Defendants Epstein and Maxwell. Based upon Plaintiff's experience with
Defendants, however, she did not believe that the requested model would be placed
in a legitimate position of employment with Defendant Epstein but would, instead,
be forced into sexual servitude. As a result, Plaintiff deliberately refused to
perform the recruitment assignment.
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 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 (approximately 125 pounds) to 52 kilograms
(approximately 114 pounds). Believing she had no practical choice in the matter,
Plaintiff attempted to comply with the order but, given her physical height and
15
EFTA00596339
structure and her existing low body weight, the diet imposed upon her placed her in
serious physical jeopardy, including kidney malfunction and extreme emotional
and psychological distress.
53. Epstein and Maxwell called Plaintiffs parents in South Africa 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 to have her admitted
to F.I.T. or another well-regarded fashion school.
54. In February of 2007, Plaintiff returned to New York and was promptly
ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants
Maxwell and Epstein fraudulently promised her again that her sexual compliance
would be rewarded with admission to F.I.T. or a comparable college, a promise
which they knew to be false. 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 as they had destroyed the careers of others
who had failed to comply.
55. Defendants Epstein and Maxwell continued to provide Plaintiff with things
of value in exchange for Plaintiffs continued compliance with Epstein's 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
16
EFTA00596340
college admission or on-going education, false promises they repeatedly made in
order to coerce her into commercial sex acts.
56. Defendants Epstein and Maxwell's sexual demands on Plaintiff continued
while she was in New York or other geographic proximity to the Defendants. In
addition to their requiring Plaintiff to provide Defendant Epstein with sex acts,
Defendants continued to pressure her to lose excessive amounts of body weight
and offered her no opportunity to decline or resist their instructions.
57. In May, 2007, Plaintiff left the United States and did not return.
58. Defendants' representations and promises were all false and fraudulent.
Their threats were considered by Plaintiff to be real and credible. All such
representations, promises and threats were made solely for the purpose of coercing
and otherwise inducing Plaintiff into prolonged sexual compliance. Defendants
knowingly benefitted financially and received things of value as a result of their
participating in their illegal enterprise.
COUNT I
CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 18 U.S.C.
1595
59. Plaintiff adopts and realleges paragraphs 1 through 58 above.
60. Defendants individually and together, within the special maritime and
territorial jurisdiction of the United States, in interstate and foreign commerce
17
EFTA00596341
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
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 through 1594 and are
subject to civil causes of action under 18 U.S.C. § 1595.
61. Defendants additionally profited from the sex trafficking of Plaintiff;
obstructed investigations of the violations; attempted and conspired to violate, and
succeeded in violating, 18 U.S.C. §§ 1591 through 1594, by the commission of the
torts and crimes described in this complaint.
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 N908JE) and a Gulfstream aircraft (of make and model G-1159B with tail
number N909JE). Such aircraft, along with other of Defendants' property, were
used as means and instruments of Defendants' tortious and criminal offenses and,
as such, are subject to forfeiture.
18
EFTA00596342
63. Additionally, Defendant Epstein's New York mansion, located at 9 East 71st
street, New York, 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 forfeiture.
64. As a direct and proximate result of Defendants' commission of the
aforementioned criminal offenses enumerated in Title 18 U.S.C. § 1591 et. seq.
and the civil remedies provided in § 1595, Plaintiff has in the past suffered and will
continue to suffer injury and pain; emotional distress; psychological and psychi-
atric 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 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 do so in the future.
WHEREFORE, Plaintiff demands judgment against Defendants for
compensatory 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: January 2016.
Respectfully Submitted,
19
EFTA00596343
BOIES, SCHILLER & FLEXNER LLP
By: /s/ David Boies
David Boies
Boies Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
20
EFTA00596344
SOUTHERN DISTRICT OF NEW YORK
CASE NO.:
P.C.
Plaintiff,
vs.
JEFFREY EPSTEIN,
GHISLAINE MAXWELL,
LPSLEY R FF
AND
Defendants.
COMPLAINT
Plaintiff P.C., by and through her undersigned counsel, sues the Defendants
Jeffrey Epstein, Ghislaine Maxwell, Lesley Groff and a
and alleges as follows:
1. This cause of action arises under federal statute 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 and
disclosure of Plaintiffs name publicly will cause further harm to her.
EFTA00596325
3. At all 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 and the United States
Virgin Islands. He is currently a citizen of the United States and a resident of the
U.S. Virgin Islands.
5. At all times material to this cause of action Defendant Jeffrey Epstein was an
adult male born in 1953.
6. At all 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. At all times material to this cause of action_was residing in
New York, New York, and, on information and belief, was a citizen of New York.
8. At all times material to this cause of action Lesley Groff was a residing in
New York, New York and, on information and belief, was a citizen of New York
9. At all material times, was residing in New York, New
York and, on information and belief, was a citizen of New York.
10. Because a substantial part of the 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)b(2)
2
EFTA00596326
11. At all times material to this cause of action, Defendants Jeffrey Epstein,
Ghislaine Maxwell, .,esley Groff, and owed a
duty to Plaintiff to treat her in a non-negligent manner and not to commit or
conspire to commit intentional or tortious illegal acts against her.
FACTUAL ALLEGATIONS
12. At all times material to this cause of action Defendant Jeffrey Epstein was an
adult male over 50 years old. Defendant Epstein is known as a billionaire who
uses his extraordinary wealth to commit illegal sexual crimes in violation of
federal and state statutes and to employ numerous others, including the named
Defendants, to conspire and assist in committing those crimes and additional torts
as well as to protect and conceal his crimes and torts from being discovered.
13. 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. He owned and owns 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 mansion in London, England; a home in Paris,
3
EFTA00596327
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.
14. Defendant Epstein has a compulsive sexual preference for young females as
young as 13 and as "old" as 25. Defendant had sex with young females virtually
every day and assisted in the development and execution of a sex trafficking
scheme designed to fulfill his sexual desires.
15. Defendant Maxwell was for decades the highest-ranking employee of the
Defendants' sex trafficking enterprise. She herself recruited young 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 acted in certain specific
ways in order to advance the purposes of the scheme and conceal it from law
enforcement.
16. Defendant recruited young females and maintained Epstein's sex
schedule in order to ensure that he was not without the sexual favors of young
females for any extended period of time. Defendant also handled travel
arrangements for the various females being exploited for sexual purposes.
4
EFTA00596328
Defendant reported directly up the enterprise's line of authority to
Defendant Maxwell.
17. Defendant Epstein employed many recruiters of young females. The nature
of the Defendants' sex trafficking scheme enabled victims themselves, such as
Defendant to elevate their status to that of a paid recruiter of other
victims. 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 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 vast
majority of girls were required to perform intimate sexual acts at the Defendants'
direction and the Defendants did not help or intend to help advance the victims'
careers.
18. Defendant Groff coordinated schedules between Defendant Epstein and the
various young females used for sex; made travel arrangements for the girls; tended
to their living needs; and communicated with them in order to maintain their
compliance with the rules of behavior imposed upon them by the enterprise.
19. The Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled
Epstein's compulsive need for sex with young females by preying on their
5
EFTA00596329
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
underlings below. 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 maximized the number of young females made
available for sexual purposes to Defendant Epstein and others. At all times
materials to this complaint, the venture and enterprise was a group of two or more
individuals associated in fact and deed.
21. Defendants Epstein and Maxwell, with help from assistants, associates and
underlings, recruited and procured hundreds of females over the decades of the
operation of their scheme. Such recruitment and procurement included fraud,
coercion, the threat of coercion, and a combination of these and similar tactics.
Following the Defendants' recruitment and procurement of the females to join
Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent
6
EFTA00596330
promises, coercion, and threats of coercion in order to entice young 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.
22. Defendants specifically targeted underprivileged, emotionally vulnerable
and/or economically disadvantaged young females to join the Defendants'
enterprise.
23. It is unknown exactly how long Defendant Epstein and Maxwell's
aforementioned criminal and illegal enterprise operated, although on information
and belief Plaintiff alleges that it was at least continuously and actively in
operation from the mid-1990's through and including the calendar year 2007.
24. Plaintiff also alleges on information and belief that Defendant Epstein has
continued the scheme up to the present time.
25. In 2005, Defendant Epstein and numerous co-conspirators within the
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 children. Each child was lured into
Defendant Epstein's Palm Beach mansion with a promise that she would receive
money for providing him with a body massage, although once there, each child
was made to engage a sex act in order to receive the promised compensation.
7
EFTA00596331
Several were also made to engage in sex with another of Defendant Epstein's
female sexual traveling companions.
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.
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 for identified
federal sex crimes against more than 30 minors.
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 the fifty-
three-page draft indictment of Epstein. During these 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.
29. Remarkably, however—as this case will highlight—Defendant Epstein and
his co-Defendants, including the other defendants named herein, did not abandon
8
EFTA00596332
their sex trafficking 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 style. Instead of targeting local Palm Beach Florida high school
girls, the Defendants transported young females from other places in the U.S. and
abroad and brought them to Defendant Epstein's mansion in New York and his
private island in the Virgin Islands.
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. He
avoided state prison and, instead, served part of an 18-month "soft" jail sentence
consisting primarily of day-time release to a nearby private office where, among
other liberties, he surfed the internet and communicated with past victims.
31. 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. The
system included requiring subordinates to sign confidentiality agreements covering
civil and criminal activity; 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
9
EFTA00596333
law enforcement officials; requiring them to accept the representation of attorneys
paid for by Defendant Epstein; requiring them to invoke the Fifth Amendment in
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.
32. In 2005, Defendant Epstein and other co-conspirators, aware that law
enforcement officials were preparing imminently to execute a search warrant of 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.
SPECIFIC FACTS
33. Commencing in approximately October 2006 and continuing through April
2007, Defendants recruited Plaintiff into their sexual enterprise by promising to
use their connections and resources to secure her admission to an institution of
higher education at the expense of Defendant Epstein.
I0
EFTA00596334
34. Defendant was working as one of the enterprise's recruiters of
young females when she approached and recruited Plaintiff.
35. Defendant 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.
36. Defendant reported to her superiors, Defendants Groff and
Maxwell, and was paid for her recruitment of young females, including the
recruitment of Plaintiff.
37. Defendant introduced Plaintiff to Defendant Epstein, who
confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff
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. Defendants Maxwell, and Groff each confirmed
this promise to Plaintiff many times.
38. Defendant Maxwell told Plaintiff she would need to provide Defendant
Epstein with body massages in order to reap the benefits of his and Maxwell's
connections. Maxwell and Epstein also made known to Plaintiff that, while they
had the ability to advance her education and career, they also had the ability to
make sure that she would obtain no formal education or modeling agency contracts
11
EFTA00596335
if she failed to provide the sexual favors desired by Defendant Epstein or abide by
the instructions given her by Defendants Epstein and Maxwell.
39. Plaintiff reasonably believed that her compliance with Defendants' demands
was crucial to her physical, psychological, financial and reputational survival.
40. Defendant Maxwell instructed Plaintiff how to massage Epstein using the
techniques that he preferred. During Plaintiff's 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.
41. Maxwell and Epstein informed Plaintiff that other young females in
Epstein's company were there not only to provide massages, but also sexual acts.
42. Plaintiff was instructed dozens of times to provide body massages to
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 perform a
sexual act with Epstein. The Defendants transported Plaintiff in interstate and
foreign commerce, and affecting interstate and foreign commerce, for these sexual
purposes.
43. During many sexual encounters, Defendant Epstein gave Plaintiff no option,
opportunity or choice not to participate in the prescribed sexual acts.
44. Defendant Maxwell frequently controlled the assignment, or "rotation," of
Plaintiff and the other young females concerning the time, place and manner of the
12
EFTA00596336
sex acts they were told to provide to Defendant Epstein. Defendants Maxwell and
Epstein also required Plaintiff to engage in sex acts with other females.
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, including psychological,
financial, and reputational harm, in ways and means that, under the surrounding
circumstances, would have compelled any reasonable person of the same or similar
background and circumstances as Plaintiff's to perform and continue performing
the demanded commercial sexual activity.
46. On one occasion, after suffering verbal abuse and threats by Defendants
Epstein, Maxwell, and Plaintiff attempted to escape from Defendant
Epstein's private island. A search party led by Defendant Epstein located her and
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.
47. Defendant Epstein's wealth, influence, power and connections were used
both as an inducement to provide sex (in exchange for promises of support), and as
13
EFTA00596337
a means of threatening punishment (should Plaintiff refuse to comply with
Defendants' instructions).
48. In addition to Plaintiff's being trafficked on Epstein's private plane,
Defendants Groff, Maxwell and , with the knowledge of and instruction by
Defendant Epstein, arranged Plaintiffs commercial air travel on numerous
occasions for the purpose of causing Plaintiff to commit commercial sex acts.
49. Defendants provided living quarters for Plaintiff at 301 East 66 Street, New
York; a car service for Plaintiff to use as needed; a cell phone; and other valuable
consideration in order to maintain Plaintiffs sexual compliance.
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 representations that they would provide Plaintiff with a
formal education and career advancement if she provided sex to Defendant Epstein
and others in the times, places and manners demanded by Defendants. Plaintiff
reasonably relied on those representations. In fact, however, those representations
were knowingly false, were not acted upon, and were made by Defendants Epstein
and Maxwell solely for the purpose of maintaining Plaintiffs financial dependence
on, emotional vulnerability to, and sexual compliance with Defendants Epstein and
Maxwell and their demands. The other Defendants intentionally repeated those
14
EFTA00596338
representations and intentionally attempted to convince Plaintiff that the
representations were true and could be relied upon.
51. In January 2007, Defendants sent Plaintiff from the United States to South
Africa in part to recruit, for a promised fee, one or more aspiring female models
supposedly for Epstein to use as an alleged personal assistant. Epstein and
Maxwell continuously and frequently demanded that Plaintiff fulfill this task as a
condition of her receiving the education, career and related benefits promised by
Defendants Epstein and Maxwell. Based upon Plaintiff's experience with
Defendants, however, she did not believe that the requested model would be placed
in a legitimate position of employment with Defendant Epstein but would, instead,
be forced into sexual servitude. As a result, Plaintiff deliberately refused to
perform the recruitment assignment.
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 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 (approximately 125 pounds) to 52 kilograms
(approximately 114 pounds). Believing she had no practical choice in the matter,
Plaintiff attempted to comply with the order but, given her physical height and
15
EFTA00596339
structure and her existing low body weight, the diet imposed upon her placed her in
serious physical jeopardy, including kidney malfunction and extreme emotional
and psychological distress.
53. Epstein and Maxwell called Plaintiffs parents in South Africa 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 to have her admitted
to F.I.T. or another well-regarded fashion school.
54. In February of 2007, Plaintiff returned to New York and was promptly
ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants
Maxwell and Epstein fraudulently promised her again that her sexual compliance
would be rewarded with admission to F.I.T. or a comparable college, a promise
which they knew to be false. 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 as they had destroyed the careers of others
who had failed to comply.
55. Defendants Epstein and Maxwell continued to provide Plaintiff with things
of value in exchange for Plaintiffs continued compliance with Epstein's 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
16
EFTA00596340
college admission or on-going education, false promises they repeatedly made in
order to coerce her into commercial sex acts.
56. Defendants Epstein and Maxwell's sexual demands on Plaintiff continued
while she was in New York or other geographic proximity to the Defendants. In
addition to their requiring Plaintiff to provide Defendant Epstein with sex acts,
Defendants continued to pressure her to lose excessive amounts of body weight
and offered her no opportunity to decline or resist their instructions.
57. In May, 2007, Plaintiff left the United States and did not return.
58. Defendants' representations and promises were all false and fraudulent.
Their threats were considered by Plaintiff to be real and credible. All such
representations, promises and threats were made solely for the purpose of coercing
and otherwise inducing Plaintiff into prolonged sexual compliance. Defendants
knowingly benefitted financially and received things of value as a result of their
participating in their illegal enterprise.
COUNT I
CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 18 U.S.C.
1595
59. Plaintiff adopts and realleges paragraphs 1 through 58 above.
60. Defendants individually and together, within the special maritime and
territorial jurisdiction of the United States, in interstate and foreign commerce
17
EFTA00596341
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
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 through 1594 and are
subject to civil causes of action under 18 U.S.C. § 1595.
61. Defendants additionally profited from the sex trafficking of Plaintiff;
obstructed investigations of the violations; attempted and conspired to violate, and
succeeded in violating, 18 U.S.C. §§ 1591 through 1594, by the commission of the
torts and crimes described in this complaint.
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 N908JE) and a Gulfstream aircraft (of make and model G-1159B with tail
number N909JE). Such aircraft, along with other of Defendants' property, were
used as means and instruments of Defendants' tortious and criminal offenses and,
as such, are subject to forfeiture.
18
EFTA00596342
63. Additionally, Defendant Epstein's New York mansion, located at 9 East 71st
street, New York, 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 forfeiture.
64. As a direct and proximate result of Defendants' commission of the
aforementioned criminal offenses enumerated in Title 18 U.S.C. § 1591 et. seq.
and the civil remedies provided in § 1595, Plaintiff has in the past suffered and will
continue to suffer injury and pain; emotional distress; psychological and psychi-
atric 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 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 do so in the future.
WHEREFORE, Plaintiff demands judgment against Defendants for
compensatory 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: January 2016.
Respectfully Submitted,
19
EFTA00596343
BOIES, SCHILLER & FLEXNER LLP
By: /s/ David Boies
David Boies
Boies Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
20
EFTA00596344