EFTA00615970.pdf
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EFTA00615970
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page I of 31
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
COMPLAINT
CASE NO.: 1:17-CV-00616
JANE DOE 43,
U
R
V
T
I
I
V tfel IV Z 3> t del V
Plaintiff
Ls,
EFFREY EP TEIN HI LAINE MAXWELL
AND
Defendants.
FIRST AMENDED COMPLAINT
Plaintiff JANE DOE 43, by and through her undersigned counsel, for her
EFTA00615971
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 2 of 31
claims against Defendants Jeffrey Epstein, Ghislaine Maxwell,
and 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. *Again 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
auElthe disclosure of Pleifttifgs-nanle-publiely-willwhich, in association with her
name, would cause further harm to her.
3. At all 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-/siew-Y-Orkrand 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.
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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
8. At all times material to this cause of action was •
9. -1424neluding-beeaffse-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)
2
10. 4-lat all times material to this cause of action, Defendants Jeffrey Epstein,
Ghislaine Maxwell, an -.Ina 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 illegal acts against her,
including any acts in violation of 18 U.S.C. §1595.
FACTUAL ALLEGATIONS
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11. 4-2,At all times material to this cause of action, Defendant Jeffrey Epstein was
an adult male over 50 years old. Defendant Epstein is knownwidely 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 eenspir-e-and-assist in
committing those crimes and additional torts as well as to preteet-and-conceal his
crimes and torts of the Epstein sex trafficking group from being discovered.
12 44-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-ewns(directly or indirectly) a Boeing
aircraft (of make and model B-727-31H with tail number N908JE) and a
Gulfstream aircraft
3
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 Islandsa
EFTA00615974
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 5 of 31
mansion in London, England; a home
; 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
described in this paragraph to facilitate the illegal sex trafficking venture and
enterprise described in this Complaint and in furtherance of that venture and
enterprise,
a 4-4:Defendant Epstein has a compulsive sexual preference for young females
as young as 13 and as told!: as 25. Through information and belief Defendant
hed-see-with-yeung-fenieieeaaiFtueilygastein engages iusxual actsa
range every day and accicted in the deve lopment 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:
and conceal the operation of the venture and enterprise and conduct of its
participants. As part of the venture and enterprise, Epstein also provided
young females for sexual purposes to his friends in order to secure social,
business, and other contacts as well as other things of value.
14. 44: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
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
iii, including providing young females to Epstein for sexual purposes on
a daily basis, and concealing these activities from law enforcement.
S
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.
and the Defendants did not help e*noc intend to help advance
the victims' careers. Victims were also paid to bring F'ipstein other young
females for sex and were told by Defendants Epstein, Maxwell.MIM that
those young females who brought other females would further benefit from
bringing other girls,
6
EFTA00615977
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a -1-97The Defendants, led primarily by Defendants Epstein and Maxwell,
fulfilled Epstein!) compulsive need for sex with young females by preying on their
4 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.
Defendants also trafficked young females to Epstein's friends and
acquaintances in order to secure financial and other benefits as well as social,
educational, and business connections
19. 2O Defendants' sex trafficking venture and enterprise operated in a hierarchal
structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top-and
itaderlings-helew. Defendants Epstein and Maxwell operated the sex traffiekinp
scheme dating back to at least the mid-nineties, and over the years perfected
theirlititisiathe roles of others, both in terms of the ability to tthe
volume of young females recruited for sex and in insulating the enterprise from
criminal investigation or prosecution.
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Underlings included
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. 2-hDefendants 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 yeungand coerce
the females into sex and, once sexual activities ensued, to cause them to remain in
the enterprise. The Defendants also transported females in
A
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
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 10 of 31
exchange for nroviding sex acts to Epstein.
22. 2-3AdditionallyJklendants_alnasstawitsle every r ngientale
that they were wealthy, well-connected and could either help or hurt the
females depending on their degree of cooperation. In fact, Defendants Epstein
and Maxwell have been known to threaten young females with physical harm,
It is unknown exactly how long Defendant Epstein and Maxwell':,
afecemeatiociecithe 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 venture and enterprise and
eeftspireey-up to the present time in some form or another and with additional
co-consnirators and partici . p s.
24. 2-5,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
2
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25, 264n 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. 2-7-.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-filing-of-thea fifty-
three-page dra€IFederal felony indictment offrom being filed against Epstein.
During these
14
EFTA00615981
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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!) innocence and publicly defaming his
victims as liars. Rather, Defendants merely changed their stylelocation. 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 Epsteinns mansion in New York City and his private island in the
Virgin Islands.
29. 3&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. 3-1-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.
11
EFTA00615982
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3-24n 2005, Defendant Epstein and other co-conspirators, aware that law
enforcement officials were preparing imminently to execute a search warrant efkr
his home, removed computer systems that logged information about Epstein and his
co-conspirators' illegal and criminal conduct; the identities of witnesses; nude
12
photographs of young females; scheduling books; message pads; tangible items such
as vibrators and toys; and other incriminating matter.
32. The sex recruiting and trafficking venture and enterprise designed to
procure young females for sexual purposes and to conceal those activities was
developed and fine-tuned over time, and each of the named Defendants had a
well-defined role and improved in his/her role over time, with practice and
EFTA00615983
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 iarticii ation in the venture and
enterprise.
33. A typical 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. 'l in=Beginning in approximately October 2006 and continuing
through April 2007,
EFTA00615984
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 14 of 31
10
14
39. &Defendant Maxwell told Plaintiff she would need to provide Defendant
EFTA00615985
- 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 knew that
Plaintiff was actually being recruited for sexual purposes, andleach knowingly
and deliberately made false representations to ensure that Plaintiff would
cooperate in fulfilling Epstein's sexual desires. These false and fraudulent
representations included Defendants' telling Plaintiff that Epstein would use
his connections to have her admitted inter a similar institute, college,
universi y or school of higher learning and provide her with employment
opportunities. Plaintiff reasonably relied on these representations and had a
credible basis for such reliance, including the credible representations of
Epstein and the other Defendants that they possessed extensive political,
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
15
connections sufficient to arrange for and insure her admission into or a
similar school of higher learning.
41, Maxwell and Epstein also threatened Plaintiff that, while they had the ability
EFTA00615986
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 no-formal education if
she failed to provide the sexual favors desired by Defendant Epstein or abide by the
instructions given her by Defendants Epstein and Maxwell.
-14
42. 31XPlaintiff reasonably believed that her compliance with Defendants'
demands was crucial to her physical, psychological, financial, and reputational
well-being and survival.
41,Defenflents—Maxwell and Epstein informed Plaintiff that other young
females in Defendant-Epstein's company were there net-enly-to-pcovkle-massages;
but-also to perform sexual acts, for E stein and his friends.
16
EFTA00615987
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 17 of 31
The Defendants all participated in
arranging for Plaintiff to be transported Plaintiff in interstate and foreign
commerce, and affecting interstate and foreign commerce, for these sexual purposes.
The Defendants Epstein, Maxwell, and a j
4-2
47. 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.
17
psychological, financial, and reputational harm, with-the-puipose-and-OffeGt-Og
EFTA00615988
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4--3
50. 4-7,Defendant Epstein's wealth, influence, power and connections were used
by Defendants Maxwell, and both as an inducement to provide sex
(in exchange for promises of support to Plaintiff}, and as a means of threatening
punishment (sheuklin the event Plaintiff refuserefused to comply with Defendants'
instructions to provide sex to Epstein and others).
a 4.8.,In addition to Plaintiff's being trafficked on Defendant-Epstein!:s private
planeairplane, Defendants ME, Maxwell and with the knowledge of and
instruction by Defendant Epstein,
EFTA00615989
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 19 of 31
18
a 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
12
EFTA00615990
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.
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 a and Maxwell solely for the
purpose of maintaining
44 Plaintiffs financial dependence on, emotional vulnerability to, and sexual
compliance with DefectElantsDefendant Epstein-anE14.4exwell-a•ncl-their:q 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 enternrice far which they were each emnlavetl
20
EFTA00615991
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 21 of 31
O.1 $4-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 Min -pact to recruit, for a promised fee, one or
more aspiring female models supposedly for Defendant-Epstein-te-use-as-an-alleged
per-senal-assistantrEpstein 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.
EFTA00615992
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 22 of 31
57. 52as 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
=, 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
ha
58. 51:3,As part of their scheme,,Defendants Epstein and Maxwell called
Plaintiff's parents in to tell them that DefenElantsDefendant Epstein
would take good care of Plaintiff when she returned to the United State; and that
theyDefendants Maxwell and Epstein would use their connections and influence
EFTA00615993
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 23 of 31
to have her admitted to
r 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 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,
Epstein told Plaintiff that he had reviewed these materials. His statements were
intended to convince Plaintiff and had the effect of convincing plaintiff (as they
)vomA have convinced maimulAIKuQA,
nri - tt that her admissionAi),,i
F VT was
ys
a "done deal" if she would comply with his instructions. also made the
same representations to plaintiff on Epstein's behalf. Plaintiff reasonably
relied on these representations by Epstein and =,
60. As part of their scheme, Epstein and Maxwell told Plaintiff that they had
contacts at-and at modeling_agencies who could ensure her admission to
and advance Plaintiff's career. As part of their scheme, Epstein and
Maxwell told Plaintiff about Epstein's vast wealth and specifically identified
him as a billionaire. Epstein and Maxwell told Plaintiff that they had extensive
23
contacts, in addition to those identified above, throughout New York City and
elsewhere.
61. 54An February of 2007, in reliance on promises made by the Defendant;
Plaintiff
EFTA00615994
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 to- 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.
5-SDefendants Epstein and Maxwell continued to provide Plaintiff with
things of value in exchange for Plaintiff-) continued compliance with Epstein!)
4-6 sexual demands; however, they failed and refused to perform their promises to
help Plaintiff be admitted to ar 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.
fia, S&Defendants Epstein and Maxwell':,_' sexual demands on Plaintiff
continued while she was in New York or other geographicCity, in the Southern
Districtof New York, or in other locations in close proximity to the Defendants.
EFTA00615995
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Paae 25 of 31
57:In May, 2007, Plaintiff left the United States and did not return. Between
returning from in February 2007 and leaving in May 2007,
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
documents and other evidence regarding what they had done.
25
66. S&Unknown to Plaintiff, Defendants' representations and promises to
Plaintiff were all false and fraudulent. Their—threats-were-sensidered-byPlaintiff
reasonably relied on the representations and promises of the Defendants.
Plaintiff also considered the Defendants' threats against the current and future
well-beinp and safety of Plaintiff to be real and credible. All such representations,
promisesa and threats were made solely for the purpose of coercing and otherwise
EFTA00615996
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 their-coercing 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
76 . 49,Plaintiff adopts and realleges paragraphs 1 through 5-86.§ above.
4-7
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
21
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
andW91,
A' 'onallv. Defendants Enstein. Maxwell. and ainatithalLyand
EFTA00615997
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 27 of 31
together,]
In so
doing, Defendants violated18 1592. These Defendants also obstructed,
and attempted to obstruct and to interfere with the enforcement of 18 U.S.C. 4
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
t Defendants violated 18 U.S.C. § 1594(a),
dokg,
27
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
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 2N of 31
persons known and unknown, to violate 18 U.S.C. § 1591. In so doing,
Defendants violated 18 U.S.C. 8 1594(c).
74. By virtue of 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. §
-1-59576-1,Defendatits-additionetly-prefited-from-the-sex-tr-efftelEing-ef-Plein
ebstrueted4nvestigatiens-ef-the-vielatiensauerapted-and-eenspiced-te-vielate,and
suseeeded-in-vielatiugr i-8-1447C-4*-1-541-threugh-1445,by-the-Gemmissien-ecthe
tofts-and-efimes-deser-ibed-iii-this-sernplaiiii1595 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
N908JE) and a Gulfstream aircraft (of make and model G- 1159B with tail number
N909JE). Such aircraft, along with other of Defendants'
4S property, were used as means and instruments of Defendants' tortious and
criminal offenses and, as such, are subject to forfeiture.
76. (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
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 29 of 31
forfeiture.
77. 4zhAs a direct and proximate result of Defendants' commission of the
aforementioned criminal offenses enumerated in Title 18 U.S.C. § 1591 ct. scq.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 pnychi atricpsychiatric 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, attorneys 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: Januafy-26r 201-7-.June 5, 2017.
Respectfully Submitted,
FARMER. JAFFE. WaVING. EDWARDS.
FISTOS, LEHRMAN, M.
EFTA00616000
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29
EFTA00616001
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31
By: A/Bradley J. Edwards Bradley J.
Edwards
BOIES, SCHILLER & FLEXNER
LLPB.5 David Boies_ David
Boies-
Alex Boies Boics Schiller & Flcxncr LLP 575
Sigrid McCawley
Meredith Schultz
HAC VICE-te-befiled
Paul G Cassell
S.J. Quinney College of Law at the University of
Utah
EFTA00616002
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31
20
This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation
EFTA00616003
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 31 of 31
CERTIFICATE OF SF.RVICF,
I HEREBY CERTIFY that on the 5t day of June, 2017, I electronically filed the
foregoing document with the Clerk of Court by using the CNI/ECF system. I also certify that
the foregoing document is being served this day on the individuals identified below via
transmission of Notices of Electronic Filing generated by CM/ECF
$TEPTOE & JOHNSON, LLP Michael C. Miller Justin Y.K. Chu
Attorneysfor Defendants
Jeffrey Epstein &
By: A/Bradley J. Edwards Farmer, Jaffe,
Weissi43achiasEds=Ristasn lasgaaINM:
Pr6(41GE-glee4040-111061
J,Stanley-Ilettingec
J. Stanley Pottinger PLLC Suite 100
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31
EFTA00616005
6:18:32 PM
Input:
Document 1 ID file://CAUsers\pparkerlDesktop101 Complaint.pdf
Description 01 Complaint
file://CAUsers1pparkerlDesktoplFirst Amended
Document 2 ID
Complaint.pdf
Description First Amended Complaint
Rendering set Steptoe - Standard
Legend:
Insertion
Deletion-
Moved to
Style change
Format change
Meved-deletion-
Inserted cell
Deleted cell
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Split/Merged cell
Padding cell
Statistics:
Count
Insertions 333
Deletions 225
Moved from 0
Moved to 0
Style change 0
Format changed 16
Total changes 574
EFTA00615970
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page I of 31
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
COMPLAINT
CASE NO.: 1:17-CV-00616
JANE DOE 43,
U
R
V
T
I
I
V tfel IV Z 3> t del V
Plaintiff
Ls,
EFFREY EP TEIN HI LAINE MAXWELL
AND
Defendants.
FIRST AMENDED COMPLAINT
Plaintiff JANE DOE 43, by and through her undersigned counsel, for her
EFTA00615971
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 2 of 31
claims against Defendants Jeffrey Epstein, Ghislaine Maxwell,
and 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. *Again 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
auElthe disclosure of Pleifttifgs-nanle-publiely-willwhich, in association with her
name, would cause further harm to her.
3. At all 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-/siew-Y-Orkrand 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.
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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
8. At all times material to this cause of action was •
9. -1424neluding-beeaffse-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)
2
10. 4-lat all times material to this cause of action, Defendants Jeffrey Epstein,
Ghislaine Maxwell, an -.Ina 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 illegal acts against her,
including any acts in violation of 18 U.S.C. §1595.
FACTUAL ALLEGATIONS
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11. 4-2,At all times material to this cause of action, Defendant Jeffrey Epstein was
an adult male over 50 years old. Defendant Epstein is knownwidely 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 eenspir-e-and-assist in
committing those crimes and additional torts as well as to preteet-and-conceal his
crimes and torts of the Epstein sex trafficking group from being discovered.
12 44-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-ewns(directly or indirectly) a Boeing
aircraft (of make and model B-727-31H with tail number N908JE) and a
Gulfstream aircraft
3
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 Islandsa
EFTA00615974
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 5 of 31
mansion in London, England; a home
; 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
described in this paragraph to facilitate the illegal sex trafficking venture and
enterprise described in this Complaint and in furtherance of that venture and
enterprise,
a 4-4:Defendant Epstein has a compulsive sexual preference for young females
as young as 13 and as told!: as 25. Through information and belief Defendant
hed-see-with-yeung-fenieieeaaiFtueilygastein engages iusxual actsa
range every day and accicted in the deve lopment 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:
and conceal the operation of the venture and enterprise and conduct of its
participants. As part of the venture and enterprise, Epstein also provided
young females for sexual purposes to his friends in order to secure social,
business, and other contacts as well as other things of value.
14. 44: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
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
iii, including providing young females to Epstein for sexual purposes on
a daily basis, and concealing these activities from law enforcement.
S
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
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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.
and the Defendants did not help e*noc intend to help advance
the victims' careers. Victims were also paid to bring F'ipstein other young
females for sex and were told by Defendants Epstein, Maxwell.MIM that
those young females who brought other females would further benefit from
bringing other girls,
6
EFTA00615977
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a -1-97The Defendants, led primarily by Defendants Epstein and Maxwell,
fulfilled Epstein!) compulsive need for sex with young females by preying on their
4 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.
Defendants also trafficked young females to Epstein's friends and
acquaintances in order to secure financial and other benefits as well as social,
educational, and business connections
19. 2O Defendants' sex trafficking venture and enterprise operated in a hierarchal
structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top-and
itaderlings-helew. Defendants Epstein and Maxwell operated the sex traffiekinp
scheme dating back to at least the mid-nineties, and over the years perfected
theirlititisiathe roles of others, both in terms of the ability to tthe
volume of young females recruited for sex and in insulating the enterprise from
criminal investigation or prosecution.
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Underlings included
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. 2-hDefendants 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 yeungand coerce
the females into sex and, once sexual activities ensued, to cause them to remain in
the enterprise. The Defendants also transported females in
A
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
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 10 of 31
exchange for nroviding sex acts to Epstein.
22. 2-3AdditionallyJklendants_alnasstawitsle every r ngientale
that they were wealthy, well-connected and could either help or hurt the
females depending on their degree of cooperation. In fact, Defendants Epstein
and Maxwell have been known to threaten young females with physical harm,
It is unknown exactly how long Defendant Epstein and Maxwell':,
afecemeatiociecithe 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 venture and enterprise and
eeftspireey-up to the present time in some form or another and with additional
co-consnirators and partici . p s.
24. 2-5,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
2
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25, 264n 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. 2-7-.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-filing-of-thea fifty-
three-page dra€IFederal felony indictment offrom being filed against Epstein.
During these
14
EFTA00615981
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!) innocence and publicly defaming his
victims as liars. Rather, Defendants merely changed their stylelocation. 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 Epsteinns mansion in New York City and his private island in the
Virgin Islands.
29. 3&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. 3-1-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.
11
EFTA00615982
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 12 of 31
3-24n 2005, Defendant Epstein and other co-conspirators, aware that law
enforcement officials were preparing imminently to execute a search warrant efkr
his home, removed computer systems that logged information about Epstein and his
co-conspirators' illegal and criminal conduct; the identities of witnesses; nude
12
photographs of young females; scheduling books; message pads; tangible items such
as vibrators and toys; and other incriminating matter.
32. The sex recruiting and trafficking venture and enterprise designed to
procure young females for sexual purposes and to conceal those activities was
developed and fine-tuned over time, and each of the named Defendants had a
well-defined role and improved in his/her role over time, with practice and
EFTA00615983
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 iarticii ation in the venture and
enterprise.
33. A typical 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. 'l in=Beginning in approximately October 2006 and continuing
through April 2007,
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 14 of 31
10
14
39. &Defendant Maxwell told Plaintiff she would need to provide Defendant
EFTA00615985
- 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 knew that
Plaintiff was actually being recruited for sexual purposes, andleach knowingly
and deliberately made false representations to ensure that Plaintiff would
cooperate in fulfilling Epstein's sexual desires. These false and fraudulent
representations included Defendants' telling Plaintiff that Epstein would use
his connections to have her admitted inter a similar institute, college,
universi y or school of higher learning and provide her with employment
opportunities. Plaintiff reasonably relied on these representations and had a
credible basis for such reliance, including the credible representations of
Epstein and the other Defendants that they possessed extensive political,
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
15
connections sufficient to arrange for and insure her admission into or a
similar school of higher learning.
41, Maxwell and Epstein also threatened Plaintiff that, while they had the ability
EFTA00615986
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 no-formal education if
she failed to provide the sexual favors desired by Defendant Epstein or abide by the
instructions given her by Defendants Epstein and Maxwell.
-14
42. 31XPlaintiff reasonably believed that her compliance with Defendants'
demands was crucial to her physical, psychological, financial, and reputational
well-being and survival.
41,Defenflents—Maxwell and Epstein informed Plaintiff that other young
females in Defendant-Epstein's company were there net-enly-to-pcovkle-massages;
but-also to perform sexual acts, for E stein and his friends.
16
EFTA00615987
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 17 of 31
The Defendants all participated in
arranging for Plaintiff to be transported Plaintiff in interstate and foreign
commerce, and affecting interstate and foreign commerce, for these sexual purposes.
The Defendants Epstein, Maxwell, and a j
4-2
47. 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.
17
psychological, financial, and reputational harm, with-the-puipose-and-OffeGt-Og
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 18 of 31
4--3
50. 4-7,Defendant Epstein's wealth, influence, power and connections were used
by Defendants Maxwell, and both as an inducement to provide sex
(in exchange for promises of support to Plaintiff}, and as a means of threatening
punishment (sheuklin the event Plaintiff refuserefused to comply with Defendants'
instructions to provide sex to Epstein and others).
a 4.8.,In addition to Plaintiff's being trafficked on Defendant-Epstein!:s private
planeairplane, Defendants ME, Maxwell and with the knowledge of and
instruction by Defendant Epstein,
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18
a 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
12
EFTA00615990
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.
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 a and Maxwell solely for the
purpose of maintaining
44 Plaintiffs financial dependence on, emotional vulnerability to, and sexual
compliance with DefectElantsDefendant Epstein-anE14.4exwell-a•ncl-their:q 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 enternrice far which they were each emnlavetl
20
EFTA00615991
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 21 of 31
O.1 $4-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 Min -pact to recruit, for a promised fee, one or
more aspiring female models supposedly for Defendant-Epstein-te-use-as-an-alleged
per-senal-assistantrEpstein 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.
EFTA00615992
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 22 of 31
57. 52as 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
=, 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
ha
58. 51:3,As part of their scheme,,Defendants Epstein and Maxwell called
Plaintiff's parents in to tell them that DefenElantsDefendant Epstein
would take good care of Plaintiff when she returned to the United State; and that
theyDefendants Maxwell and Epstein would use their connections and influence
EFTA00615993
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 23 of 31
to have her admitted to
r 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 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,
Epstein told Plaintiff that he had reviewed these materials. His statements were
intended to convince Plaintiff and had the effect of convincing plaintiff (as they
)vomA have convinced maimulAIKuQA,
nri - tt that her admissionAi),,i
F VT was
ys
a "done deal" if she would comply with his instructions. also made the
same representations to plaintiff on Epstein's behalf. Plaintiff reasonably
relied on these representations by Epstein and =,
60. As part of their scheme, Epstein and Maxwell told Plaintiff that they had
contacts at-and at modeling_agencies who could ensure her admission to
and advance Plaintiff's career. As part of their scheme, Epstein and
Maxwell told Plaintiff about Epstein's vast wealth and specifically identified
him as a billionaire. Epstein and Maxwell told Plaintiff that they had extensive
23
contacts, in addition to those identified above, throughout New York City and
elsewhere.
61. 54An February of 2007, in reliance on promises made by the Defendant;
Plaintiff
EFTA00615994
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 to- 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.
5-SDefendants Epstein and Maxwell continued to provide Plaintiff with
things of value in exchange for Plaintiff-) continued compliance with Epstein!)
4-6 sexual demands; however, they failed and refused to perform their promises to
help Plaintiff be admitted to ar 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.
fia, S&Defendants Epstein and Maxwell':,_' sexual demands on Plaintiff
continued while she was in New York or other geographicCity, in the Southern
Districtof New York, or in other locations in close proximity to the Defendants.
EFTA00615995
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Paae 25 of 31
57:In May, 2007, Plaintiff left the United States and did not return. Between
returning from in February 2007 and leaving in May 2007,
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
documents and other evidence regarding what they had done.
25
66. S&Unknown to Plaintiff, Defendants' representations and promises to
Plaintiff were all false and fraudulent. Their—threats-were-sensidered-byPlaintiff
reasonably relied on the representations and promises of the Defendants.
Plaintiff also considered the Defendants' threats against the current and future
well-beinp and safety of Plaintiff to be real and credible. All such representations,
promisesa and threats were made solely for the purpose of coercing and otherwise
EFTA00615996
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 their-coercing 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
76 . 49,Plaintiff adopts and realleges paragraphs 1 through 5-86.§ above.
4-7
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
21
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
andW91,
A' 'onallv. Defendants Enstein. Maxwell. and ainatithalLyand
EFTA00615997
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 27 of 31
together,]
In so
doing, Defendants violated18 1592. These Defendants also obstructed,
and attempted to obstruct and to interfere with the enforcement of 18 U.S.C. 4
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
t Defendants violated 18 U.S.C. § 1594(a),
dokg,
27
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
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 2N of 31
persons known and unknown, to violate 18 U.S.C. § 1591. In so doing,
Defendants violated 18 U.S.C. 8 1594(c).
74. By virtue of 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. §
-1-59576-1,Defendatits-additionetly-prefited-from-the-sex-tr-efftelEing-ef-Plein
ebstrueted4nvestigatiens-ef-the-vielatiensauerapted-and-eenspiced-te-vielate,and
suseeeded-in-vielatiugr i-8-1447C-4*-1-541-threugh-1445,by-the-Gemmissien-ecthe
tofts-and-efimes-deser-ibed-iii-this-sernplaiiii1595 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
N908JE) and a Gulfstream aircraft (of make and model G- 1159B with tail number
N909JE). Such aircraft, along with other of Defendants'
4S property, were used as means and instruments of Defendants' tortious and
criminal offenses and, as such, are subject to forfeiture.
76. (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
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 29 of 31
forfeiture.
77. 4zhAs a direct and proximate result of Defendants' commission of the
aforementioned criminal offenses enumerated in Title 18 U.S.C. § 1591 ct. scq.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 pnychi atricpsychiatric 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, attorneys 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: Januafy-26r 201-7-.June 5, 2017.
Respectfully Submitted,
FARMER. JAFFE. WaVING. EDWARDS.
FISTOS, LEHRMAN, M.
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29
EFTA00616001
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31
By: A/Bradley J. Edwards Bradley J.
Edwards
BOIES, SCHILLER & FLEXNER
LLPB.5 David Boies_ David
Boies-
Alex Boies Boics Schiller & Flcxncr LLP 575
Sigrid McCawley
Meredith Schultz
HAC VICE-te-befiled
Paul G Cassell
S.J. Quinney College of Law at the University of
Utah
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20
This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 31 of 31
CERTIFICATE OF SF.RVICF,
I HEREBY CERTIFY that on the 5t day of June, 2017, I electronically filed the
foregoing document with the Clerk of Court by using the CNI/ECF system. I also certify that
the foregoing document is being served this day on the individuals identified below via
transmission of Notices of Electronic Filing generated by CM/ECF
$TEPTOE & JOHNSON, LLP Michael C. Miller Justin Y.K. Chu
Attorneysfor Defendants
Jeffrey Epstein &
By: A/Bradley J. Edwards Farmer, Jaffe,
Weissi43achiasEds=Ristasn lasgaaINM:
Pr6(41GE-glee4040-111061
J,Stanley-Ilettingec
J. Stanley Pottinger PLLC Suite 100
EFTA00616004
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 31 of 31
31
EFTA00616005