EFTA00296277.pdf
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EFTA00296277
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
T
14
I
A
3.- X ttelV
V WIC
Plaintiff
xf,
EFFREY EP TEIN HI LAINE MAXWELL
AND
Defendants.
FIRST AMENDED COMPLAINT
Plaintiff JANE DOE 43, by and through her undersigned counsel, for her
EFTA00296278
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. *section 1331.
2. Plaintiff files this Complaint under a pseudonym in order to protect her
identity because this Complaint makes allegations of a sensitive sexual nature
andthe disclosure of name-publielsfrwillwhich, 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
was a citizen of South Africa residing in New York, New York.
4. At all times material to this cause of action Defendant Jeffrey Epstein had
multiple residences, including in New York, New York (within the Southern
District of New York) and the United States Virgin Islands. He is currently a citizen
of the United States and claims to be a resident ofNew--Y-Ork—ancl 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 a United States
citizen, residing in New York, New York, and, of
eiti-zea-ef-the-14nite€1-States (within the Southern District of New York).
8. At all times material to this cause of action was residinga United
States citizen, employed by New York based company and regularly
conducting business in New York, New York and, on information and belief, was a
citizen of the United States(within the Southern District of New York).
9.At all material times, n-was-resitling-in-New--Y-eFk r New
YOFIreandr en-infennatien-and-beliefrwas-a-eitizell-ef-the-binited-States,
9. -1414neluding-bec-ausea 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. -1-lat all times material to this cause of action, Defendants Jeffrey Epstein,
Ghislaine Maxwell, an —ann 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
EFTA00296280
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 4 of 31
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
EFTA00296281
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
EFTA00296282
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
eeneeal-4, including providing young females to Epstein for sexual purposes on
a daily basis, and concealing these activities from law enforcement.
4-67Defendant recruited young females for Epstein for sexual
purposes, brought gifts to females in order to entice those females to commit
sex acts with Epstein and to assist in concealing the illegal sexual conduct of the
venture and enterprise, and maintained 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 Defendant n intend art f the sex traffi kin venture and
enterprise and reported directly up the line of authority to
DefendeetDefendants Maxwell and Epstein.
-1-7,Defendant Epstein employed many recruiters of young females. The
nature of the Defendants' sex trafficking schemeventure and enter ris enabled
victims themselvesTsueh-as-Defendent to elevate their status to that of a
paid recruiter of other victims.
S
Recruiters were taught by Defendants Epstein-and, Maxwell andM 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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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
girlsyoung females were actually required to perform intimate sexual acts at the
Defendants' direction and the Defendants did not help efnor intend to help advance
the victims' careers. Victims id t brin F stem other
females for sex and were told by Defendants Epstein, Maxwell, and that
those young females who brought other females would further benefit from
bringing other girls,
17. -1-8,Defendant In was an integral part of the illegal venture and
enterprise. =coordinated schedules between Defendant Epstein and the various
young females used for sex; made travel arrangements for the girlsyoung females;
tended to thcirthe living needsafid-eemmunieateci-with-fliemeerder-te-mainta
-
their of those females; communicated and coordinated with Defendants
Epstein, Maxwell and to assist in facilitating young females being
available in locations where the other Defendants were traveling; and she
carried messages to the young females from the other Defendants including
false representations in order to maintain the young females' compliance with
the rules of beluwimsexual compliance imposed upon-them-by this structured
sex-trafficking group. was aware of
6
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the entewiseactivities of the venture and enterprise, including the fraudulent
representations and other coercion that was being applied to secure the
females' compliance with demands of sex.
-IA The Defendants, led primarily by Defendants Epstein and Maxwell,
fulfilled Epstein!) compulsive need for sex with young females by preying on their
personal, psychological, financial, and related vulnerabilities. The Defendants'
tactics included promising the victims money, shelter, transportation, gifts.,
employment, admission into educational institutions, educational tuition,
protection, and other things of value in exchange for sex. Defendants also took
possession of the victims' passports to coerce compliance with their demands.
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. 2.0:Defendants' sex trafficking venture and enterprise operated in a hierarchal
structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top-anil
underlings-belew,Defendants Epstein and Maxwell operated the sex trafficking
scheme dating back to at least the mid-nineties, and over the years perfected
their roles and the roles of oth
volume of young females recruited for sex and in insulating the enterprise from
criminalLiniesligationorprosetation.Defendantas ith
Defendant Epstein and Maxwell
7
since at least 2002 and continues to work for Defendant Epstein today.
Defendant legatusarkingwiththelasteinrrasextraffickintyenture
and enterprise as early as 2001 and her role in their venture and enterprise was
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 9 of 31
well-defined and primarily consisted of conspiring in the commission an
cover-up of sex crimes. Underlings included the other named Defendants as well as
unnamed co- conspirators such as various housekeepers and butlers; an airplane
pilot; and various employees, assistants and associates. Wittingly and unwittingly,
such underlings performed their respective roles with the purpose and effect of
insuring that the enterprise supplied young females to Defendant Epstein and others
for sexual purposes. At all times materials to this complaint, the venture and
enterprise was a group of two or more individuals associated in fact and deed.
20. 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 yettegand 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
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 10 of 31
exchange for providing sex acts to Epstein.
21Defendants specifically targeted underprivileged, emotionally vulnerable
and/or economically disadvantaged young females to join the Defendants'
entecpciseprovide sex for Epstein.
23.Additionally, Defendants always made clear to every you
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's
afecenwatienetithe 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.
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-conspirators and narticinant, .
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 sexual activities with dozens of young teenage school children. Each
child identified in that particular investigation was lured into Defendant
Epstein's Palm
2
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 10 of 31
Beach mansion with a promise that she would receive money for providing him with
a body massage, although once there, each el young female was made to engage
in a sex actsexual acts in order to receive the promised compensation.
Several were also made to engage in sex with another of Defendant Epstein's
female sexual-tfaveling-eempathenstraveling sex companions who Epstein
referred to as his lesbian sex slave and bragged about purchasin her from
her family when she herself was underage.
15, 2.-.67In 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
and named by the Federal Government as co- conspirators,
for identified federal sex crimes against more than 30 minors.
27. 28.From late 2006 through September 2007, Epstein's team of lawyers
negotiated with the federal government in an effort to avoid the-filing-ef-thea fifty-
three-page dra€tFederal felony indictment effrom being filed against Epstein.
During these
14
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 11 of 31
negotiations, Defendant Epstein decamped from Palm Beach to New York and the
U.S. Virgin Islands in order to convey an image to prosecutors that he and his co-
conspirators had stopped committing sex crimes.
28. 24Remarkably, 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 yenture 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 stylciocation. 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 Epsteinl's mansion in New York City and his private island in the
Virgin Islands.
29. 40,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
reaistered 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
Defendants and adapted to the system and also carried it out for
years in exchange for significant pay, benefits, and protection from
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 12 of 31
prosecution. The system included requiring subordinates to sign confidentiality
agreements evering-eivil-andbarring disclosure of criminal activity; maintaining
records of underage females who were abused by Epstein; requiring
subordinates and victims to refrain from speaking with law enforcement officials;
requiring them to notify Defendant Epstein's lawyers in the event they (subordinates
and victims) were contacted by law enforcement officials; requiring them to accept
the representation of attorneys paid for by Defendant Epstein; requiring them to
invoke the Fifth Amendment in
4 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.
IL 32In 2005, Defendant Epstein and other co-conspirators, aware that law
enforcement officials were preparing imminently to execute a search warrant effor
his home, removed computer systems that logged information about Epstein and his
co-conspirators' illegal and criminal conduct; the identities of witnesses; nude
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
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 13 of 31
experience. By the time Plaintiff was recruited into victimization, each
Defendant had years of experience perfecting methods of coercion,
understanding Epstein's requirements, and becoming more loyal to the
continuance and survival of the venture and enterprise. All of the
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 I articii ation in the venture and
enterprise.
E. A typical way 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, ff eenfirnerkeingjlegim_g
lin in approximately October 2006 and continuing
through April 2007, Defendants recruited Plaintiff into their sexual enterprise by
fraudulently
U
promising to use their connections and resources to secure her admission to an
institution of higher education at the expense of Defendant Epstein.
34.Defendant W113 working as One of the enterprise's snafu
recruiters-efaatilurkinglascruit young females_for
Epstein for sex when she approached and recruited Plaintiff.
EFTA00296291
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 14 of 31
44
4-5-,Defendana informed Plaintiff that she would introduce Plaintiff
to Defendant Epstein, whom she described as a wealthy philanthropist who regularly
used his wealth, influence and connections to help financially poor females like
Plaintiff achieve their personal and professional goals and aspirations.
37. 36.Defendant reported to her superiors, Defendants M,
and Maxwell, and was paid for her recruitment of young females, including-the
feeruitment-ef 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."31 in New
York City; or into a similar institute of higher learning offering a curriculum of
fashion industry training. Between October 2006 and May 2007, Defendants
Maxwell, and IM each also confirmed and reiterated this promise to
Plaintiff many timest each telling Plaintiff that Epstein would use his wealth and
connections to advance Plaintiff's education. More specifically, each of the
Defendants last verified this information that Epstein was using his
connections to ensure Plaintiff was admitted
14
into F.I.T. in exchange for Plaintiff's continued sexual cooperation with
Epstein in March or April of 2007.
39. 38.Defendant Maxwell told Plaintiff she would need to provide Defendant
EFTA00296292
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 15 of 31
Epstein with body massages in order to reap the benefits of his and'
connections.
40. All Defendants, including Maxwell, Epstein, and M, knew that
Plaintiff was actually being recruited for sexual purposes, and each knowingly
and deliberately made false representations to ensure that Plaintiff would
cooperate in fulfilling Epstein's sexual desires. These false and fraudulent
representations included Defendants' telling Plaintiff that Epstein would use
his connections to have her admitted into F.I.T. or 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 F.I.T. or a
similar school of higher learning.
41, Maxwell and Epstein also threatened Plaintiff that, while they had the ability
EFTA00296293
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 16 of 31
to advance her education and career, they also had the ability to make sure that
shePlaintiff would not obtain ne-formal education or modeling agency contracts if
she failed to provide the sexual favors desired by Defendant Epstein or abide by the
instructions given her by Defendants Epstein and Maxwell.
44
42 3-9,Plaintiff reasonably believed that her compliance with Defendants'
demands was crucial to her physical, psychological, financial, and reputational
weiatingan_d_survival.
43. 4&Defendant Maxwell instructed Plaintiff how to massage Epstein using the
techniques that heMaxwell knew that Epstein 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 her and to avoid Defendants' threatened retaliation against her if Plaintiff
did not perform as demanded.
j4, 4-I,Defendants—Maxwell and Epstein informed Plaintiff that other young
females in Defendant-Epstein's company were there net-enly-te-previde-massages3
but-also to perform sexual acts, for Epstein and his friendsnd
!piped to secure the presence of the other young females for these purposes,
11
427Plaintiff was instructed dozens of times to provide body massages to
Defendant Epstein, both at his townhouse in New York and on his private island in
the U.S. Virgin Islands. Each time she was so instructed she was also required to
EFTA00296294
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 17 of 31
perform a sexual act with-Defendant Epstein. The Defendants all participated in
arranging for Plaintiff to be transported Plaintiff in interstate and foreign
commerce, and affecting interstate and foreign commerce, for these sexual purposes.
The Defendants Epstein, Maxwell, andased possession and control of
Plaintiff's passport to induce and coerce Plaintiff into nerforminiz sexual acts
with Epstein and others.
46. 43:During many sexual encounters, Defendant Epstein gave Plaintiff no
option, opportunity, or choice not to participate in the prescribed sexual acts.
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. Defendant Maxwell also
gave instructions on how to perform certain sexual techniques on Epstein.
Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with
other females.
4-SDefendants Epstein and Maxwell intimidated, threatened, humiliated and
verbally abused Plaintiff in order to coerce her into sexual compliance. These
Defendants threatened Plaintiff with serious harm, as well as serious
psychological, financial, and reputational harm, with4hesufpese-and-OffeGt-eg
EFTA00296295
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 1$ of 31
compelling Plaintiff to perform and continue performing the demanded-commercial
sexual activity demanded by Defendants.
49_, 46,On one occasion, after suffering verbal abuse and threats by Defendants
Epstein, Maxwell, and M, Plaintiff attempted to escape from Defendant
Epstein's private island. A search party led by DcfcndantDefendants Epstein and
Maxwell located her and physically returned her to the main house on the island.
Through these and other actions, the Defendants intended to cause, and did cause,
Plaintiff to believe that failure to perform the actions they requested would result in
physical restraint and potential harm to her person, as well as harm to her reputation,
employability, and stable state of mind. Defendants further used possession and
control of Plaintiff's passport, without lawful consent or authority, to restrict
Plaintifralikertismiiherthilorethenforayidtienniaskins
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 (sheuldin the event Plaintiff fecuserefused to comply with Defendants'
instructions to provide sex to Epstein and others).
a 48,In addition to Plaintiff's being trafficked on Defendant-Epstein!:s private
planeairplane, Defendants =, Maxwell and with the knowledge of and
instruction by Defendant Epstein, arranged Plaintiffs living accommodations,
private car travel,
EFTA00296296
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 19 of 31
18
and commercial air travel on numerous occasions for the purpose of causing
Plaintiff to commit commercial sex acts. These Defendants worked in concert
with one another to recruit, procure, entice, and otherwise cause many other
females to engage in commercial sex acts, through their use of threats, fraud,
and coercion. Among these means of coercion were the Defendant's possession
and control of the females' passports and other immigration documents. This
coercion was most salient, and especially effective, while the females, including
Plaintiff, were on Epstein's island.
52. 4-9,1n furtherance of their venture and enterprise, Defendants provided
living quarters for Plaintiff at 301 East 66th Street, New York, in the Southern
District of New York; a car service for Plaintiff to use as needed; a cell phone; and
other valuable consideration in order to maintain Plaintiffs sexual compliance. Each
of the Defendants told Plaintiff she would obtain the benefits of a place to live
and phone and transportation as long as she remained compliant with their
demands that she service Epstein sexually. Each of the Defendants also told her
that if she was not compliant, these benefits would be taken from Plaintiff.
53. 544,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
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Epstein and others in the times, places and manners demanded by Defendants.
Defendants and each also told Plaintiff that Defendant Epstein
would advance Plaintiffs education and career in order to coerce Plaintiff into
sex. Defendant told Plaintiff that Epstein had done the same for her
career. As a result of these and other representations by Defendants, Plaintiff
reasonably relied on thestn representations. In fact, however, thosethese
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 DefendantsDefendant Epstein4144-Ma*well-and-their:a demands.
The other Defendants intentionally repeated thesethese representations and
intentionally attetpteilmade statements designed to convince Plaintiff that the
representations were true and could be relied upon. These representations and
statements were made to Plaintiff in furtherance of the sex trafficking
venture and enterprise for which they were each employed.
54. As part of the venture and enterprise, Defendants Epstein, Maxwell, and
took possession of Plaintiffs passport when she was being trafficked by
them, including when she travelled to E stein's island in the U.S. Virgin
Islands. 'The Defendants took possession of Plaintiffs passport in the course of
sexually trafficking Plaintiff and with the intent to violate laws against sex
trafficking, including 18 U.S.C. 1591 et. seq. The Defendants used their control
of Plaintiffs
20
EFTA00296298
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 21 of 31
passport in order to coerce compliance with their demands, including their
demands that Plaintiff have sex with Epstein and others.
$4-In January 2007 as part of their illegal venture and enterprise,
Defendants sent Plaintiff from the-Uctited4takasNew York City, in the Southern
District of New York, to South Africa-in-pact to recruit, for a promised fee, one or
more aspiring female models supposedly for Defendant-Erstein-te-use-as-an-alleged
per-sefial-assistant,Epstein to use as a personal assistant. The Defendants did not
care whether the prospective female was qualified to work as a personal
assistant because each knew that the female recruit would be immediately
placed into the same sexually vulnerable position as Plaintiff (and the dozens of
other victims of the sex trafficking enterprise) and would be induced and
coerced into being used for sex through fraudulent representations and other
means.
56. Defendants Epstein and Maxwell continuously and frequently demanded that
Plaintiff fulfill this task of bringing another female back to the United States and
Defendants' control as a condition of herPlaintiff's receiving the education, career
and related benefits promised by Defendants Epstein and Maxwell. Based upon
Plaintiff's experience with Defendants, however, she did-net-believeknew that the
requested female model would not be placed in a legitimate position of employment
with Defendant Epstein but would, instead, be forced into sexual servitude. Plaintiff
also knew that this objective was the only purpose of Defendants n
EFTA00296299
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 22 of 31
Maxwell and Epstein's demand for rAjilies recruitment efforts. As a result,
Plaintiff deliberately refused to perform the recruitment assignment.
57. 5-2,As part of their ongoing scheme, Defendants inflicted serious emotional
and psychological harm on Plaintiff as a means of coercing her to continue engaging
in commercial sex acts with Epstein and others. While Plaintiff was in South
Africa, Defendants Epstein and Maxwell informed Plaintiff that she would not be
permitted to return to the United States to receive her promised education unless she
underwent a diet and lowered her body weight from 57 kilograms
4-5 (approximately 125 pounds) to 52 kilograms (approximately 114 pounds).
Epstein and Maxwell promised Plaintiff that if she complied, she would
receive her promised education. Defendant monitored Plaintiffs
progress in losing weight and continued to communicate with Plaintiff about
Plaintiff's application to be admitted into F.I.T. as part of the Defendants'
ruse to coerce Plaintiff to return to the United States for sex. Defendant =
was aware of the coercion Epstein and Maxwell were applying to Plaintiff and
acted to help further that coercion. Believing she had no practical choice in the
matter, Plaintiff attempted to comply with the order but, given her physical height
and body structure and her already existing-lew body weight, the diet imposed
upon her placed her in serious physical jeopardy, including kidney malfunction
and extreme emotional and psychological distress.
ha
a 53.As part of their scheme,,Defendants Epstein and Maxwell called
Plaintiff-'s parents in South Africa to tell them that DefendentsDefendant 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
EFTA00296300
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 23 of 31
to have her admitted to
F.I.T. or another well-regarded fashion school or school of higher learning,
59. As part of their scheme, Epstein and told Plaintiff that she should
fill out an application for admission to F.I.T., and supporting essay_ and send it
to Epstein for his review. Pursuant to these instructions, Plaintiff completed an
armlication, 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
)vomAl have convinced maimul
nri i that her admission F.I.T. was
ys
41.
I" if she s ul c nt t with i ns. 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 F.LT. and at modeling agencies who could ensure her admission to
F.I.T. 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. 54,In February of 2007, in reliance on promises made by the Defendant;
Plaintiff returned to New York City, in the Southern District of New York, and
EFTA00296301
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 24 of 31
was promptly ordered by Defendant Maxwell to have sex with Defendant Epstein.
Defendants Maxwell. and Epstein each fraudulently promised
herPlaintiff again that her sexual compliance would be rewarded with admission to
F.I.T. or a comparable college, a promise which they letew-te-be-faiseeach knew to
be false. In fact all four Defendants had for years worked solely to recruit
females for sex and to conceal the operation of the sex scheme, and in 2007 were
under Federal investigation for their conspiracy to engage in Federal sexual
crimes like those committed against Plaintiff. Plaintiff knew that if she did not
comply, Defendants Maxwell and Epstein would use their power, influence and
connections in order to ensure that Plaintiff was unable to gain admission to F.I.T. or
a comparable school, and that they would destroy her career, just as they had
destroyed the careers of others who had failed to comply with their demands.
12a 5-SDefendants Epstein and Maxwell continued to provide Plaintiff with
things of value in exchange for Plaintiff-:s continued compliance with Epsteie
4-6 sexual demands; however, they failed and refused to perform their promises to
help Plaintiff be admitted to F.I.T. or another school, or to provide financial
support for
24
college admission or on-going education, false promises they repeatedly made in
order to coerce her into commercial sex acts.
13.. 5&Defendants Epstein and Maxwell':,_' sexual demands on Plaintiff
continued while she was in New York or other gcographicCity, in the Southern
District of New York, or in other locations in close proximity to the Defendants.
EFTA00296302
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 25 of 31
In addition to their requiring Plaintiff to provide Defendant Epstein with sex acts,
each of the Defendants continued to pressure her to lose excessive amounts of body
weight and offered her no opportunity to decline or resist their instructions.
5-77In May, 2007, Plaintiff left the United States and did not return. Between
returtaSouth Africa Min in May 2007.
Defendants M,a, and Maxwell each continued to repeatedly make
false representations to Plaintiff, including false and fraudulent
representations that she would be admitted to F.I.T. if she continued to engage
in sex with Epstein. Defendant Epstein continued to make similar false and
fraudulent promises in order to have sex with Plaintiff.
65. In and after May 2007, Defendants actively concealed and covered up
what they had done to Plaintiff and other similarly situated females.
Defendant's cover- up included efforts to intimidate witnesses who might
provide corroborating testimony to Plaintiff as well as destruction of
documents and other evidence regarding what they had done.
25
66. 5-8,Unknown to Plaintiff, Defendants' representations and promises to
Plaintiff were all false and fraudulent. Their—threats-,were-considered-byPlaintiff
reasonably relied on the representations and promises of the Defendants.
Plaintiff also considered the Defendants' threats against the current and future
well-being and safety of Plaintiff to be real and credible. All such representations,
promisesa and threats were made solely for the purpose of coercing and otherwise
EFTA00296303
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
EFTA00296304
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 27 of 31
together, knowingly concealed, removed, confiscated, and possessed Plaintiff's
passport and associated immieratioulocuments, in the course of violating 18
U.S.C. § 1591, and with the intent of violating 18 U.S.C. § 1591, and to prevent,
restrict, attempt to restrict, without lawful authority, Plaintiff's liberty to move
or travel, in order to maintain the sexual services of Plaintiff, while Plaintiff
was a victim of a severe form of sex trafficking, as defined in section 103 of the
Trafficking Victims Pi ted 2 0, Ilat
cgd in 22 U.S.C.. /0
1 2. In se
doing, Defendants violated 18 U.S.C. § 1592. These Defendants also obstructed,
and attempted to obstruct and to interfere with the enforcement of 18 U.S.C.
1592.
70. Additionally, Defendants knowingly benefitted, financially and by
receiving things of value, from participating in a venture (the Epstein sex
trafficking venture enterprise) which had engaged in acts in violation of 18
U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in such
violations. In so doing, Defendants violated 18 U.S.C. § 1593A.
71. Additionally, Defendants attempted to violate 18 U.S.C. § 1591. In so
dokg,
1 Defendants violated 18 U.S.C. § 1594(a).
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
6:18:32 PM
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Description 01 Complaint
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Description First Amended Complaint
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EFTA00296277
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
T
14
I
A
3.- X ttelV
V WIC
Plaintiff
xf,
EFFREY EP TEIN HI LAINE MAXWELL
AND
Defendants.
FIRST AMENDED COMPLAINT
Plaintiff JANE DOE 43, by and through her undersigned counsel, for her
EFTA00296278
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. *section 1331.
2. Plaintiff files this Complaint under a pseudonym in order to protect her
identity because this Complaint makes allegations of a sensitive sexual nature
andthe disclosure of name-publielsfrwillwhich, 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
was a citizen of South Africa residing in New York, New York.
4. At all times material to this cause of action Defendant Jeffrey Epstein had
multiple residences, including in New York, New York (within the Southern
District of New York) and the United States Virgin Islands. He is currently a citizen
of the United States and claims to be a resident ofNew--Y-Ork—ancl 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.
EFTA00296279
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 3 of 31
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 a United States
citizen, residing in New York, New York, and, of
eiti-zea-ef-the-14nite€1-States (within the Southern District of New York).
8. At all times material to this cause of action was residinga United
States citizen, employed by New York based company and regularly
conducting business in New York, New York and, on information and belief, was a
citizen of the United States(within the Southern District of New York).
9.At all material times, n-was-resitling-in-New--Y-eFk r New
YOFIreandr en-infennatien-and-beliefrwas-a-eitizell-ef-the-binited-States,
9. -1414neluding-bec-ausea 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. -1-lat all times material to this cause of action, Defendants Jeffrey Epstein,
Ghislaine Maxwell, an —ann 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
EFTA00296280
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 4 of 31
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
EFTA00296281
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
EFTA00296282
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
eeneeal-4, including providing young females to Epstein for sexual purposes on
a daily basis, and concealing these activities from law enforcement.
4-67Defendant recruited young females for Epstein for sexual
purposes, brought gifts to females in order to entice those females to commit
sex acts with Epstein and to assist in concealing the illegal sexual conduct of the
venture and enterprise, and maintained 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 Defendant n intend art f the sex traffi kin venture and
enterprise and reported directly up the line of authority to
DefendeetDefendants Maxwell and Epstein.
-1-7,Defendant Epstein employed many recruiters of young females. The
nature of the Defendants' sex trafficking schemeventure and enter ris enabled
victims themselvesTsueh-as-Defendent to elevate their status to that of a
paid recruiter of other victims.
S
Recruiters were taught by Defendants Epstein-and, Maxwell andM to inform
targeted victims that Epstein possessed extraordinary wealth, power, resources and
influence; that he was a philanthropist who would help female victims advance their
EFTA00296283
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 7 of 31
careers and lives; and that the recruits needed only to provide Epstein with body
massages in order to avail themselves of his financial assistance and influence. In
fact, however, these representations were fraudulent. The vast majority of
girlsyoung females were actually required to perform intimate sexual acts at the
Defendants' direction and the Defendants did not help efnor intend to help advance
the victims' careers. Victims id t brin F stem other
females for sex and were told by Defendants Epstein, Maxwell, and that
those young females who brought other females would further benefit from
bringing other girls,
17. -1-8,Defendant In was an integral part of the illegal venture and
enterprise. =coordinated schedules between Defendant Epstein and the various
young females used for sex; made travel arrangements for the girlsyoung females;
tended to thcirthe living needsafid-eemmunieateci-with-fliemeerder-te-mainta
-
their of those females; communicated and coordinated with Defendants
Epstein, Maxwell and to assist in facilitating young females being
available in locations where the other Defendants were traveling; and she
carried messages to the young females from the other Defendants including
false representations in order to maintain the young females' compliance with
the rules of beluwimsexual compliance imposed upon-them-by this structured
sex-trafficking group. was aware of
6
EFTA00296284
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page $ of 31
the entewiseactivities of the venture and enterprise, including the fraudulent
representations and other coercion that was being applied to secure the
females' compliance with demands of sex.
-IA The Defendants, led primarily by Defendants Epstein and Maxwell,
fulfilled Epstein!) compulsive need for sex with young females by preying on their
personal, psychological, financial, and related vulnerabilities. The Defendants'
tactics included promising the victims money, shelter, transportation, gifts.,
employment, admission into educational institutions, educational tuition,
protection, and other things of value in exchange for sex. Defendants also took
possession of the victims' passports to coerce compliance with their demands.
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. 2.0:Defendants' sex trafficking venture and enterprise operated in a hierarchal
structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top-anil
underlings-belew,Defendants Epstein and Maxwell operated the sex trafficking
scheme dating back to at least the mid-nineties, and over the years perfected
their roles and the roles of oth
volume of young females recruited for sex and in insulating the enterprise from
criminalLiniesligationorprosetation.Defendantas ith
Defendant Epstein and Maxwell
7
since at least 2002 and continues to work for Defendant Epstein today.
Defendant legatusarkingwiththelasteinrrasextraffickintyenture
and enterprise as early as 2001 and her role in their venture and enterprise was
EFTA00296285
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 9 of 31
well-defined and primarily consisted of conspiring in the commission an
cover-up of sex crimes. Underlings included the other named Defendants as well as
unnamed co- conspirators such as various housekeepers and butlers; an airplane
pilot; and various employees, assistants and associates. Wittingly and unwittingly,
such underlings performed their respective roles with the purpose and effect of
insuring that the enterprise supplied young females to Defendant Epstein and others
for sexual purposes. At all times materials to this complaint, the venture and
enterprise was a group of two or more individuals associated in fact and deed.
20. 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 yettegand 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
EFTA00296286
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 10 of 31
exchange for providing sex acts to Epstein.
21Defendants specifically targeted underprivileged, emotionally vulnerable
and/or economically disadvantaged young females to join the Defendants'
entecpciseprovide sex for Epstein.
23.Additionally, Defendants always made clear to every you
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's
afecenwatienetithe 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.
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-conspirators and narticinant, .
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 sexual activities with dozens of young teenage school children. Each
child identified in that particular investigation was lured into Defendant
Epstein's Palm
2
EFTA00296287
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 10 of 31
Beach mansion with a promise that she would receive money for providing him with
a body massage, although once there, each el young female was made to engage
in a sex actsexual acts in order to receive the promised compensation.
Several were also made to engage in sex with another of Defendant Epstein's
female sexual-tfaveling-eempathenstraveling sex companions who Epstein
referred to as his lesbian sex slave and bragged about purchasin her from
her family when she herself was underage.
15, 2.-.67In 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
and named by the Federal Government as co- conspirators,
for identified federal sex crimes against more than 30 minors.
27. 28.From late 2006 through September 2007, Epstein's team of lawyers
negotiated with the federal government in an effort to avoid the-filing-ef-thea fifty-
three-page dra€tFederal felony indictment effrom being filed against Epstein.
During these
14
EFTA00296288
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. 24Remarkably, 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 yenture 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 stylciocation. 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 Epsteinl's mansion in New York City and his private island in the
Virgin Islands.
29. 40,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
reaistered 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
Defendants and adapted to the system and also carried it out for
years in exchange for significant pay, benefits, and protection from
EFTA00296289
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 12 of 31
prosecution. The system included requiring subordinates to sign confidentiality
agreements evering-eivil-andbarring disclosure of criminal activity; maintaining
records of underage females who were abused by Epstein; requiring
subordinates and victims to refrain from speaking with law enforcement officials;
requiring them to notify Defendant Epstein's lawyers in the event they (subordinates
and victims) were contacted by law enforcement officials; requiring them to accept
the representation of attorneys paid for by Defendant Epstein; requiring them to
invoke the Fifth Amendment in
4 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.
IL 32In 2005, Defendant Epstein and other co-conspirators, aware that law
enforcement officials were preparing imminently to execute a search warrant effor
his home, removed computer systems that logged information about Epstein and his
co-conspirators' illegal and criminal conduct; the identities of witnesses; nude
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
EFTA00296290
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
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 I articii ation in the venture and
enterprise.
E. A typical way 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, ff eenfirnerkeingjlegim_g
lin in approximately October 2006 and continuing
through April 2007, Defendants recruited Plaintiff into their sexual enterprise by
fraudulently
U
promising to use their connections and resources to secure her admission to an
institution of higher education at the expense of Defendant Epstein.
34.Defendant W113 working as One of the enterprise's snafu
recruiters-efaatilurkinglascruit young females_for
Epstein for sex when she approached and recruited Plaintiff.
EFTA00296291
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 14 of 31
44
4-5-,Defendana informed Plaintiff that she would introduce Plaintiff
to Defendant Epstein, whom she described as a wealthy philanthropist who regularly
used his wealth, influence and connections to help financially poor females like
Plaintiff achieve their personal and professional goals and aspirations.
37. 36.Defendant reported to her superiors, Defendants M,
and Maxwell, and was paid for her recruitment of young females, including-the
feeruitment-ef 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."31 in New
York City; or into a similar institute of higher learning offering a curriculum of
fashion industry training. Between October 2006 and May 2007, Defendants
Maxwell, and IM each also confirmed and reiterated this promise to
Plaintiff many timest each telling Plaintiff that Epstein would use his wealth and
connections to advance Plaintiff's education. More specifically, each of the
Defendants last verified this information that Epstein was using his
connections to ensure Plaintiff was admitted
14
into F.I.T. in exchange for Plaintiff's continued sexual cooperation with
Epstein in March or April of 2007.
39. 38.Defendant Maxwell told Plaintiff she would need to provide Defendant
EFTA00296292
Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 15 of 31
Epstein with body massages in order to reap the benefits of his and'
connections.
40. All Defendants, including Maxwell, Epstein, and M, knew that
Plaintiff was actually being recruited for sexual purposes, and each knowingly
and deliberately made false representations to ensure that Plaintiff would
cooperate in fulfilling Epstein's sexual desires. These false and fraudulent
representations included Defendants' telling Plaintiff that Epstein would use
his connections to have her admitted into F.I.T. or 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 F.I.T. or a
similar school of higher learning.
41, Maxwell and Epstein also threatened Plaintiff that, while they had the ability
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to advance her education and career, they also had the ability to make sure that
shePlaintiff would not obtain ne-formal education or modeling agency contracts if
she failed to provide the sexual favors desired by Defendant Epstein or abide by the
instructions given her by Defendants Epstein and Maxwell.
44
42 3-9,Plaintiff reasonably believed that her compliance with Defendants'
demands was crucial to her physical, psychological, financial, and reputational
weiatingan_d_survival.
43. 4&Defendant Maxwell instructed Plaintiff how to massage Epstein using the
techniques that heMaxwell knew that Epstein 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 her and to avoid Defendants' threatened retaliation against her if Plaintiff
did not perform as demanded.
j4, 4-I,Defendants—Maxwell and Epstein informed Plaintiff that other young
females in Defendant-Epstein's company were there net-enly-te-previde-massages3
but-also to perform sexual acts, for Epstein and his friendsnd
!piped to secure the presence of the other young females for these purposes,
11
427Plaintiff was instructed dozens of times to provide body massages to
Defendant Epstein, both at his townhouse in New York and on his private island in
the U.S. Virgin Islands. Each time she was so instructed she was also required to
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perform a sexual act with-Defendant Epstein. 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, andased possession and control of
Plaintiff's passport to induce and coerce Plaintiff into nerforminiz sexual acts
with Epstein and others.
46. 43:During many sexual encounters, Defendant Epstein gave Plaintiff no
option, opportunity, or choice not to participate in the prescribed sexual acts.
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. Defendant Maxwell also
gave instructions on how to perform certain sexual techniques on Epstein.
Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with
other females.
4-SDefendants Epstein and Maxwell intimidated, threatened, humiliated and
verbally abused Plaintiff in order to coerce her into sexual compliance. These
Defendants threatened Plaintiff with serious harm, as well as serious
psychological, financial, and reputational harm, with4hesufpese-and-OffeGt-eg
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compelling Plaintiff to perform and continue performing the demanded-commercial
sexual activity demanded by Defendants.
49_, 46,On one occasion, after suffering verbal abuse and threats by Defendants
Epstein, Maxwell, and M, Plaintiff attempted to escape from Defendant
Epstein's private island. A search party led by DcfcndantDefendants Epstein and
Maxwell located her and physically returned her to the main house on the island.
Through these and other actions, the Defendants intended to cause, and did cause,
Plaintiff to believe that failure to perform the actions they requested would result in
physical restraint and potential harm to her person, as well as harm to her reputation,
employability, and stable state of mind. Defendants further used possession and
control of Plaintiff's passport, without lawful consent or authority, to restrict
Plaintifralikertismiiherthilorethenforayidtienniaskins
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 (sheuldin the event Plaintiff fecuserefused to comply with Defendants'
instructions to provide sex to Epstein and others).
a 48,In addition to Plaintiff's being trafficked on Defendant-Epstein!:s private
planeairplane, Defendants =, Maxwell and with the knowledge of and
instruction by Defendant Epstein, arranged Plaintiffs living accommodations,
private car travel,
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18
and commercial air travel on numerous occasions for the purpose of causing
Plaintiff to commit commercial sex acts. These Defendants worked in concert
with one another to recruit, procure, entice, and otherwise cause many other
females to engage in commercial sex acts, through their use of threats, fraud,
and coercion. Among these means of coercion were the Defendant's possession
and control of the females' passports and other immigration documents. This
coercion was most salient, and especially effective, while the females, including
Plaintiff, were on Epstein's island.
52. 4-9,1n furtherance of their venture and enterprise, Defendants provided
living quarters for Plaintiff at 301 East 66th Street, New York, in the Southern
District of New York; a car service for Plaintiff to use as needed; a cell phone; and
other valuable consideration in order to maintain Plaintiffs sexual compliance. Each
of the Defendants told Plaintiff she would obtain the benefits of a place to live
and phone and transportation as long as she remained compliant with their
demands that she service Epstein sexually. Each of the Defendants also told her
that if she was not compliant, these benefits would be taken from Plaintiff.
53. 544,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
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Epstein and others in the times, places and manners demanded by Defendants.
Defendants and each also told Plaintiff that Defendant Epstein
would advance Plaintiffs education and career in order to coerce Plaintiff into
sex. Defendant told Plaintiff that Epstein had done the same for her
career. As a result of these and other representations by Defendants, Plaintiff
reasonably relied on thestn representations. In fact, however, thosethese
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 DefendantsDefendant Epstein4144-Ma*well-and-their:a demands.
The other Defendants intentionally repeated thesethese representations and
intentionally attetpteilmade statements designed to convince Plaintiff that the
representations were true and could be relied upon. These representations and
statements were made to Plaintiff in furtherance of the sex trafficking
venture and enterprise for which they were each employed.
54. As part of the venture and enterprise, Defendants Epstein, Maxwell, and
took possession of Plaintiffs passport when she was being trafficked by
them, including when she travelled to E stein's island in the U.S. Virgin
Islands. 'The Defendants took possession of Plaintiffs passport in the course of
sexually trafficking Plaintiff and with the intent to violate laws against sex
trafficking, including 18 U.S.C. 1591 et. seq. The Defendants used their control
of Plaintiffs
20
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 21 of 31
passport in order to coerce compliance with their demands, including their
demands that Plaintiff have sex with Epstein and others.
$4-In January 2007 as part of their illegal venture and enterprise,
Defendants sent Plaintiff from the-Uctited4takasNew York City, in the Southern
District of New York, to South Africa-in-pact to recruit, for a promised fee, one or
more aspiring female models supposedly for Defendant-Erstein-te-use-as-an-alleged
per-sefial-assistant,Epstein to use as a personal assistant. The Defendants did not
care whether the prospective female was qualified to work as a personal
assistant because each knew that the female recruit would be immediately
placed into the same sexually vulnerable position as Plaintiff (and the dozens of
other victims of the sex trafficking enterprise) and would be induced and
coerced into being used for sex through fraudulent representations and other
means.
56. Defendants Epstein and Maxwell continuously and frequently demanded that
Plaintiff fulfill this task of bringing another female back to the United States and
Defendants' control as a condition of herPlaintiff's receiving the education, career
and related benefits promised by Defendants Epstein and Maxwell. Based upon
Plaintiff's experience with Defendants, however, she did-net-believeknew that the
requested female model would not be placed in a legitimate position of employment
with Defendant Epstein but would, instead, be forced into sexual servitude. Plaintiff
also knew that this objective was the only purpose of Defendants n
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Maxwell and Epstein's demand for rAjilies recruitment efforts. As a result,
Plaintiff deliberately refused to perform the recruitment assignment.
57. 5-2,As part of their ongoing scheme, Defendants inflicted serious emotional
and psychological harm on Plaintiff as a means of coercing her to continue engaging
in commercial sex acts with Epstein and others. While Plaintiff was in South
Africa, Defendants Epstein and Maxwell informed Plaintiff that she would not be
permitted to return to the United States to receive her promised education unless she
underwent a diet and lowered her body weight from 57 kilograms
4-5 (approximately 125 pounds) to 52 kilograms (approximately 114 pounds).
Epstein and Maxwell promised Plaintiff that if she complied, she would
receive her promised education. Defendant monitored Plaintiffs
progress in losing weight and continued to communicate with Plaintiff about
Plaintiff's application to be admitted into F.I.T. as part of the Defendants'
ruse to coerce Plaintiff to return to the United States for sex. Defendant =
was aware of the coercion Epstein and Maxwell were applying to Plaintiff and
acted to help further that coercion. Believing she had no practical choice in the
matter, Plaintiff attempted to comply with the order but, given her physical height
and body structure and her already existing-lew body weight, the diet imposed
upon her placed her in serious physical jeopardy, including kidney malfunction
and extreme emotional and psychological distress.
ha
a 53.As part of their scheme,,Defendants Epstein and Maxwell called
Plaintiff-'s parents in South Africa to tell them that DefendentsDefendant 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
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to have her admitted to
F.I.T. or another well-regarded fashion school or school of higher learning,
59. As part of their scheme, Epstein and told Plaintiff that she should
fill out an application for admission to F.I.T., and supporting essay_ and send it
to Epstein for his review. Pursuant to these instructions, Plaintiff completed an
armlication, 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
)vomAl have convinced maimul
nri i that her admission F.I.T. was
ys
41.
I" if she s ul c nt t with i ns. 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 F.LT. and at modeling agencies who could ensure her admission to
F.I.T. 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. 54,In February of 2007, in reliance on promises made by the Defendant;
Plaintiff returned to New York City, in the Southern District of New York, and
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 24 of 31
was promptly ordered by Defendant Maxwell to have sex with Defendant Epstein.
Defendants Maxwell. and Epstein each fraudulently promised
herPlaintiff again that her sexual compliance would be rewarded with admission to
F.I.T. or a comparable college, a promise which they letew-te-be-faiseeach knew to
be false. In fact all four Defendants had for years worked solely to recruit
females for sex and to conceal the operation of the sex scheme, and in 2007 were
under Federal investigation for their conspiracy to engage in Federal sexual
crimes like those committed against Plaintiff. Plaintiff knew that if she did not
comply, Defendants Maxwell and Epstein would use their power, influence and
connections in order to ensure that Plaintiff was unable to gain admission to F.I.T. or
a comparable school, and that they would destroy her career, just as they had
destroyed the careers of others who had failed to comply with their demands.
12a 5-SDefendants Epstein and Maxwell continued to provide Plaintiff with
things of value in exchange for Plaintiff-:s continued compliance with Epsteie
4-6 sexual demands; however, they failed and refused to perform their promises to
help Plaintiff be admitted to F.I.T. or another school, or to provide financial
support for
24
college admission or on-going education, false promises they repeatedly made in
order to coerce her into commercial sex acts.
13.. 5&Defendants Epstein and Maxwell':,_' sexual demands on Plaintiff
continued while she was in New York or other gcographicCity, in the Southern
District of New York, or in other locations in close proximity to the Defendants.
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In addition to their requiring Plaintiff to provide Defendant Epstein with sex acts,
each of the Defendants continued to pressure her to lose excessive amounts of body
weight and offered her no opportunity to decline or resist their instructions.
5-77In May, 2007, Plaintiff left the United States and did not return. Between
returtaSouth Africa Min in May 2007.
Defendants M,a, and Maxwell each continued to repeatedly make
false representations to Plaintiff, including false and fraudulent
representations that she would be admitted to F.I.T. if she continued to engage
in sex with Epstein. Defendant Epstein continued to make similar false and
fraudulent promises in order to have sex with Plaintiff.
65. In and after May 2007, Defendants actively concealed and covered up
what they had done to Plaintiff and other similarly situated females.
Defendant's cover- up included efforts to intimidate witnesses who might
provide corroborating testimony to Plaintiff as well as destruction of
documents and other evidence regarding what they had done.
25
66. 5-8,Unknown to Plaintiff, Defendants' representations and promises to
Plaintiff were all false and fraudulent. Their—threats-,were-considered-byPlaintiff
reasonably relied on the representations and promises of the Defendants.
Plaintiff also considered the Defendants' threats against the current and future
well-being and safety of Plaintiff to be real and credible. All such representations,
promisesa and threats were made solely for the purpose of coercing and otherwise
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 26 of 31
inducing Plaintiff into prolonged sexual compliance. Defendants knowingly
benefitted financially and received things of value as a result of 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
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 27 of 31
together, knowingly concealed, removed, confiscated, and possessed Plaintiff's
passport and associated immieratioulocuments, in the course of violating 18
U.S.C. § 1591, and with the intent of violating 18 U.S.C. § 1591, and to prevent,
restrict, attempt to restrict, without lawful authority, Plaintiff's liberty to move
or travel, in order to maintain the sexual services of Plaintiff, while Plaintiff
was a victim of a severe form of sex trafficking, as defined in section 103 of the
Trafficking Victims Pi ted 2 0, Ilat
cgd in 22 U.S.C.. /0
1 2. In se
doing, Defendants violated 18 U.S.C. § 1592. These Defendants also obstructed,
and attempted to obstruct and to interfere with the enforcement of 18 U.S.C.
1592.
70. Additionally, Defendants knowingly benefitted, financially and by
receiving things of value, from participating in a venture (the Epstein sex
trafficking venture enterprise) which had engaged in acts in violation of 18
U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in such
violations. In so doing, Defendants violated 18 U.S.C. § 1593A.
71. Additionally, Defendants attempted to violate 18 U.S.C. § 1591. In so
dokg,
1 Defendants violated 18 U.S.C. § 1594(a).
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