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EXHIBIT D
Case 1:17-cv-00616 Document 1 Filed OLl26l77 Page 1 of 21
T'NITED STATES DISTRICT COI]RT
SOUTHERN DISTRICT OF NEW YORK
JA}IE DOE 43,
PlaintiI COMPLAINT
vs. JI]RY TRIAL DEMANDEI)
JEFFREY EPSTEIN, GHTSLAINE CASE NO.:
MAXWELL, SARAH KELLEN, LESLEY
GROFF, AND NATALYA MALYSHEV,
Defendants.
Plaintiff Jane Doe 43, by and through her undersigned counsel, for her
claims against Defendanrc Jeftey Epstein, Ghislaine Maxwell, Sarah Kellen,
Lesley Groff, and Natalya Malyshw, alleges upon personal knowledge with
respect to her own acts and status and upon 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. $ 1331.
2. Plaintiff files this Complaint under a pseudonym in order to protect
her identity because this Complaint makes allegations of a sensitive sexual nature
and disclosure of Plaintiffs name publicly will cause firther harm to her.
3. At all times material to the events alleged in this causie of action the
Plaintiffwas a citizen of South Africa residing in New Yorh New York.
EXH!BIT
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4. At all times material to this cause of action Defendant Jeftey Epstein
had multiple residences, including in New York, New York and the United States
Virgtn Islands. He is currently a citizen of the United States and a resident of New
York and the U.S. Virgin Islands.
5. At all times material to this cause of action Defendant Jeffrey Epstein
was an adult male bom in 1953.
6. At all times material to this cause of action Defendant Ghislaine
Maxwell was residing in in New Yorlq New York and was a cittzen of Great
Britain and France.
7. At all times material to this cause of action Sarah Kellen was residing
in New York, New York, and on information and belief, was a citizen of the
United States.
8. At all times material to this cause of action Lesley Groffwas residing
in New York, New York and, on information and belief, was a citizen of the
United States.
9. At all material times, Natalya Malyshev was residing in New Yorlq
New York and, on information and belief, was a citizen of the United States.
10. Including because a substantial part of the events and omissions
glving rise to this cause of action occured in the Southem District of New Yorh
venue is proper in that District. 28 U.S.C. $ 1391(bX2)
Case 1:17-cv-0061-G Document 1 Filed OLl26lL7 Page 3 ot 2L
11. At all times material to this cause of action, Defendants Jeffrey
Epstein, Ghislaine Maxwell, Saratr Kellen, Lesley Grofi and Natalya Malyshw
owed a duty to Plaintiffto freat her in a non-negligent manner and not to commit
or conspire to commit intentional or tortious illegal acts against her.
FACTUAL ALLEGATIONS
12. At all times material to this calrse of action Defendant Jeftey Epstein
was an adult male over 50 years old. Defendant Epstein is known as a billionaire
who uses his extraordinary wealth to commit illegal sexual crimes in violation of
federal and state statutes and to employ numerousl others, including the named
Defendants, to conspire and assist in committing those crimes and additional torts
as well as to protect and conceal his crimes and torts from being discovered.
13. Defendant Epstein displays his enormous wealth,Inwer and influence
to his employees; to the victims procured for sexual purposes; and to the public in
order to advance and carry out his crimes and torts. At all relevant times,
Defendant Epstein owned and continues to own, directly or through nominee
individuals used to conceal his interests, a fleet of airplanes, motor vehicles, boats
and one or more helicopters. He oumed and owns numerolul properties and homes,
including a 51,000-square-foot mansion in Manhattan; a $30 Million, 7,500-acre
ranch in New Mexico; a70-acte private island formerly known as Little St. James
in or near St. Thomas, U.S. Virgtn Islands; a mansion in London, England; a home
Case 1:17-cv-00616 Document 1 Filed 0Ll26lL7 Page 4 ot Zl
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 Virgln Islands.
14. Defendant Epstein has a compulsive sexual preference for young
females as young as 13 and as 'rold'r as 25. Defendant had sex with young females
virtually every day and assisted in the dwelopment and execution of a sex
trafficking scheme designed to fulfill his sexual desires.
15. Defendant Maxwell was for decades the highesf-mrrking employee of
the Defendants' sex trafficking enterprise. She herself recruited young females;
oversaw and trained other recruitem on how best to recnrit grds fof sex; developed
and executed schemes designed to recruit young females; and ensured that all
participants of the Defendants' sex tafficking scherre acted in certain specific
ways in order to advance the purposes of the scheme and conceal it from law
enforcement.
16. Defendant Kellen recruited young females and maintained Epstein'q
sex schedule in order to e,nsure that he was not without the sexual favors of young
females for any extended period of time. Defendant Kellen also handled travel
arrangements for the various females being exploited for sexual pu{poses.
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Case 1:17-cv-00616 Document 1 Filed OU26|I7 page 5 of 21
Defendant Kellen reported directly up the enterprise's line of authority to
Defendant Murwell.
17. Defendant Epstein employed many recruiters of young females. The
nafiue of the Defendants' sex trafficking scheme enabled victims themselves, such
as Defendant Malyshev, to elevate their status to that of a paid recruiter of other
victims. Recruiters were taught by Defendants Epstein and Maxwell to inform
targeted victims that Epstein possessed extraordinary wealth, Ircwer, resources and
influence; that he was a philanthropist who would help female victims advance
their careers and lives; and that the recruits needed only to provide Epstein with
body massages in order to avail themselves of his financial assistance and
influence. In fact, howwer, these representatiors were fraudulent. The vast
majority of girls were required to perform intimate sexual acts at the Defendants'
direction and the Defendants did not help or intend to help advance the victims'
careeN.
18. Defendant Groff coordinated schedules between Defendant Epstein
and the various young females used for sex; made travel arrangements for the gnls;
tended to their living needs; and commruricated with them in order to maintain
their compliance with the rules of behavior imposed upon them by the enterprise.
19. The Defendants, led primarily by Defendants Epstein and Murwell,
fulfilled Epstein's compulsive need for sex with young fernales by preying on their
Case 1:17-cv-00616 Document 1 Filed OLl26lL7 Page 6 of 21
personal, psychological, financial, and related rnrlnerabilities. The Defendants'
tactics included promising the victims money, shelter, fiansportation, emploSment,
admission into educational institutions, educational tuition, and other things of
value in exchange for sex.
20. Defendants' sex tralficking venture and enterprise operated in a
hierarchal strucfire with Defendants Jeffrey Epstein and Ghislaine Ma>rwell at the
top and rurderlings below. Underlings included the other named Defendants as
well as unnarned co-conspirators such as various housekeepers and butlen; an
airplane pilot; and various employees, assistants and associates. Wittingly and
unwittingly, such underlings perfonrred their respective roles with the ptrpose and
effect of insuring that the enterprise supplied young females to Defendant Epstein
and others for sexual purposes. At all times materials to this complainq the
venfire and enterprise was a group of two or more individuals associated in fact
and deed.
21. Defendants Epstein and Maxwell, with help from assistants, associates
and underlings, recruited and procured hundreds of girls over the decades of the
operation of their sche,me. Such recruitnent and procurement included fraud,
coercion, the threat of coercion, ffid a combination of these and similar tactics.
Following the Defendants' recruifinent and procurement of the females to join
Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent
Case 1:17-cv-00616 Document 1 Filed OLl26lt7 PageT ot 2t
promises, coercion, and threats of coercion in order to entice young females into
sex and, once sexual activities ensued to cause them to remain in the enterprise.
The Defendants also transported fernales in interstate and foreign cornmerce and in
ways that affected interstate and foreign commerce.
22. Defendants specifically targeted underprivileged, emotionally
rnrlnerable and/or economically disadvantaged young females to joio the
Defendants' e,nterprise.
23. It is unknown exactly how long Defendant Epstein and Maxwell's
afore,mentioned criminal and illegal enterp,rise operatd 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 enterprise and conspiracy up to
the present time.
25. In 2005, Defendant Epstein and numerousl co-conspirators within the
enterprise were the subjects of a Palm Beach, Florida Police Department criminal
investigation which revealed that Defendant Epstein had engaged in sexual
activities with dozens of young teenage children. Each child was lured into
Defendant Epstein's Palm Beach mansion with a promise that she would receive
money for providing him with a body massage, although once there, each child
was made to engage in a sex act in order to recsive the promised compensation.
Case 1:17-cv-00616 Document 1 Filed O1l26lt7 Page 8 of 21
Several were also made to engage in sex with another of Defendant Epstein's
female sexual traveling companions.
26. Ir12006, the Palm Beach Police Deparfinent investigation was turned
over to the FBI and the United States Attorney's Office for the Southem District of
Florida. The United States Attorneyrs Office investigated Defendant Epstein and
his co-conspirators for their violations of numerous federal statutes, including 18
U.S.C. $1591, one of the statutory bases for this complaint.
27. The United States Attomey's investigation continued from 2006
through Septerrber 2007, at which time a Non-Prosecution Agreement was signed
between Jeffrey Epstein and the United States Attorney's Office defeming fedsral
prosecution of Defendant Epstein and his numerous ceconspirators for identified
federal sex crimes against more than 30 minors.
28. From late 2006 through Septerrber 2007, Epstein's team of lawyers
negotiated with the federal govemment in an effort to avoid the filing of the fifty-
three-page draft indictment of Epstein. During these negotiations, Defendant
Epstein decamped from Palm Beach to New York and the U.S. Virgin lslands in
order to convey an image to prosecutors that he and his co-conqpirators had
stopped committing sex crimes.
29. Remarkably, however-as this case will highlight-Defendant
Epstein and his co-Defendants, including the other defendants named herein, did
Case 1:L7-cv-00616 Document 1 Filed OU26|I7 Page 9 of 21
not abandon their sex trafficking enterprise even while they were under state and
federal investigation for crimes commiued in violation of 18 U.S.C. $ 1591, among
other laws, and even as Defendants and their attomeys were busy arguing Epstein's
innocence and publicly defaming his victims as liars. Rather, Defendants merely
changed their style. Instead of targeting local Palm Beach Florida high school
grrls, the Defendants transported young females from other places in the U.S. and
abroad and brought them to Defendant Epstein's mansion in New York and his
private island in the Virgin Islands.
30. In June of 2008, Epstein pleaded gurlty to Florida state felony sex
offenses for procuring a minor for prostitution and soliciting prostitution by
minors.
31. Defendants Epstein and Maxwell developed and implemented a
sophisticated system designed to insulate them from criminal and civil liability by
protecting them from potential testimony of knowledgeable subordinates. The
system included requiring subordinates to sign confidentiality agreements covering
civil and criminal activity; requiring subordinates and victims to refrain from
speaking with law enforcernent officials; requiring them to noti$ Defendant
Epstein's lawyers in the event they (subordinates and victims) were contacted by
law enforcement officials; requiring them to accept the representation of attomeys
paid for by Defendant Epstein; requiring them to invoke the Fiffh Amendment in
Case L:17-cv-00616 Document 1 Frled OU26|L7 Page 10 of 21
resllonse to questions they might be asked by investigators and prosecutors;
requiring them to invoke the Fiflh Amendment in order to refirse to turn over
incriminating and non-incriminating evidence to law enforcement officers;
requiring them to destroy evidence or refuse to reveal knowledge of desfroyed
evidence; and requiring them generally to refise all cooperation with law
enforcement offi cials or investigations.
32. tn 2005, Defe,ndant Epstein and other co-conspirators, aware that law
enforcement offrcials were preparing imminently to execute a search warrant of his
home, removed computer systerns that logged information about Epstein and his
co-conspirators' illegal and criminal conduct; the identities of witnesses; nude
photographs of young females; scheduling books; message pads; tangible items
such as vibrators and toys; and other incriminating matter.
33. Commencing in approximately October 2006 and continuing through
April 2007, Defendants recruited Plaintiff into their sexual enterprise by
fraudulently promising to use their corurections and resources to secure her
admission to an institution of higher education at the expeme of Defendant
Epstein.
34. Defendant Malyshev was working as one of the enterprise's recruiters
of young females when she approached and recruited Plaintiff.
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35. Defendant Malyshev 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 Plaintiffachieve their personal and professional goals and aspirations.
36. Defendant Malyshev reported to her superiors, Defendants Kellen,
Groff and Maxwell, and was paid for her recruifinent of young females, including
the recruitnent of Plaintiff.
37. Defendant Malyshev introduced Plaintiff to Defendant Epstein, who
confirmed to Plaintiffthat he would use his wealth and influence to have Plaintiff
admitted into The Fashion Institute of Technology, known as "F.I.T.", in New
York City, or into a similar institute of higher learning offering a curriculum of
fashion industry training. Defendants Maxwell, Kellen and Groff each confirmed
this promise to Plaintiffmany times.
38. Defendant Maxwell told Plaintiff she would need to provide
Defendant Epstein with body massages in order to reap the benefrts of his and
Maxwell's connections. Maxwell and Epstein also threatened Plaintiffthat, while
they had the ability to advance her education and career, they also had the ability to
make sure that she would obtain no formal education or modeling agency contracts
if she failed to provide the sexual favors desired by Defendant Epstein or abide by
the instnrctions given her by Defendan* Epstein and Maxwell.
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39. Plaintiff reasonably believed that her compliance with Defendants'
demands was crucial to her physical, psychological, financial, and reputational
survival.
40. Defendant Maxwell instucted Plaintiffhow to massage Epstein using
the techniques that he preferred. During Plaintiffs first massage, Defendant
Epstein converted it into a sexual act and made it known to Plaintiff that firther
sex would be required in order for her to obtain the assistance he promised and to
avoid Defendants' threatened retaliation if Plaintitrdid not perfonn as demanded.
41. Defendants Maxwell and Epstein informed Plaintiffthat other young
females in Defendant Epstein's company were there not only to provide ma,ssages,
but also sexual acts.
42. Plaintiff was instnrcted dozens of times to provide body massages to
Defendant Epstein, both at his toumhouse in New York and on his private island in
the U.S. Virgin Islands. Each time she was so instnrcted she was also required to
perform a sexual act with Defendant Epstein. The Defendants fiansported Plaintiff
in interstate and foreign corlmerce, ffid affecting int€rstate and foreign commerce,
for these sexual purposes.
43. During many sexual encounters, Defendant Epstein gave Plaintiffno
option, opportunity or choice not to participate in the prescribed sexual acts.
t2
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4. Defendant Ma:rwell frequently controlled the assignment, or
"rotation," of Plaintiffand the other young females concerning the time, place and
manner of the sex acts they were told to provide to Defendant Epstein. Defendants
Maxwell and Epstein also required Plaintiff to engage in sex acts with other
females.
45. Defendants Epstein and Maxwell intimidated threatened, humiliated
and verbally abused Plaintiffin order to coerce her into sexual compliance. These
Defendants threatened Plaintiff with serious harm, as well as serious
psychological, financial, and reputational harrn, with the purpose and effect of
compelling Plaintiff to perform and continue performing the demanded
commercial sexual activity.
46. On one occasion, after suffering verbal abuse and threats by
Defendants Epstein, Maxwell, and Kellen, Plaintiff attempted to escape from
Defendant Epstein's private island. A search party led by Defendant Epstein
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 caluie, 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, ernployability, and stable state of mind.
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47. Defendant Epstein's wealth, influence, power and connections were
used both as an inducement to provide sex (in exchange for promises of support),
and as a means of threatening punishment (should Plaintiffrefirse to comply with
Defendants' instnrctions).
48. In addition to Plaintiffs being trafficked on Defendant Epstein's
private plane, Defendants Groff, Maxwell and Kellen, urith the knowledge of and
instuction by Defendant Epstein, arranged Plaintiffs commercial air travel on
numercusl occasions for the purpose of causing Plaintiffto commit commercial sex
acts.
49. Defendants provided living quarters for Plaintiffat 301 East 66 Street,
New York; a car service for Plaintiff to use as needed; a cell phone; and other
valuable consideration in order to maintain Plaintiffs sexual compliance.
50. The relationship between Plaintiff and Defendants Epstein and
Maxwell was defined and characterizcd by Defendant Epstein's and Defendant
Maxwell's freque,nt and persistent fraudulent rqrresentations that they would
provide Plaintitr with a fonnal education and career advancement if she provided
sex to Defendant Epstein and others in the times, places and manners demanded by
Defendants. Plaintiffreasonably relied on those representations. In fact, however,
those representations were knowingly false, were not acted ulx)n, and were made
by Defendants Epstein and Maxwell solely for the purpose of maintaining
t4
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Plaintiffs financial dependence or, emotional vulnerability to, and sexual
compliance with Defsndants Epstein and Maxwell and their demands. The other
Defendants intentionally repeated those representations and intentionally at0empted
to convince Plaintiffthat the representations were tue and could be relied upon.
51. In January 2007, Defendants sent Plaintiff from the United States to
South Africa in part to recruit, for a promised fee, one or more aspiring female
models supposedly for Defe,ndant Epstein to use as an alleged personal assistant.
Defendants Epstein and Maxwell continuously and frequently demanded that
Plaintiff fulflll this task as a condition of her receiving the education, career and
related benefits promised by Defendants Epstein and Morwell. Based upon
Plaintiffs experience with Defendants, however, she did not believe that the
requested model would be placed in a legitimate position of employment with
Defendant Epstein but would, instea4 be forced into sexual senitude. As a resulg
Plaintiffdeliberately refitsed to perform the recruitment assignment.
52. As part of their ongoing scheme, Defendans inflicted serious
emotional and psychological harm on Plaintiff as a means of coercing her to
continue engaging in commercial sex acts. While Plaintiff was in South Africa,
Defendants Epstein and Maxwell informed Plaintiff that she would not be
permiued to return to the United States to receive her promised education rmless
she underwent a diet and lowered her body weight from 57 kilograms
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Case 1-:17-cv-00616 Document 1 Filed OU26|L7 Page 16 of 21
(approximately 125 pounds) to 52 kilograms (ap,proximately ll4 pounds).
Believing she had no practical choice in the matter, Plaintiff atterrpted to comply
with the order but, give,n her physical height and stnrcflre and her existing low
body weight, the diet imposed upon her placed her in serious physical jeopardy,
including kidney malfirnction and extreme emotional andpsychological distess.
53. Defendants Epstein and Maxwell called Plaintiffs parents in South
Africa to tell them that Defendants would take good care of Plaintiff when she
retumed to the United States and that they would use their connections and
influence to have her adrritted to F.I.T. or another well-regarded fashion school.
54. In February of 2N7, Plaintiffreturned to New York and was promptly
ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants
Maxwell and Epstein fraudulently promised her again that her sexual compliance
would be rewarded with admission to F.I.T. or a comparable college, a promise
which they knew to be false. Plaintiffknew that if she did not comply, Defendants
Maxwell and Epstein would use their lx)wer, influence and connections in order to
eruiure that Plaintiffwas unable to gain adurission to F.I.T. or a comparable school,
and that they would destroy her career as they had destroyed the caxeers of others
who had failed to comply.
55. Defendants Epstein and Maxwell continued to provide Plainfiff with
things of value in exchange for Plaintiffs continued compliance with Epstein's
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sexual demands; however, they failed and refirsed to perform their promises to help
Plaintiff be admitted to F.I.T. or another school, or to provide financial support for
college admission or on-going education, false promises they repeatedly made in
order to coerce her into commercial sex acts.
56. Defendants Epstein and Morwell's sexual demands on Plaintiff
continued while she was in New York or other geographic proximity to the
Defendants. In addition to their requiring Plaintiff to provide Defendant Epstein
with sex acts, Defendants continued to pressure her to lose excessive arrrounts of
body weight and offered her no opportunity to decline or resist their instuctions.
57 . In May, 2N7, Plaintiffleft the United States and did not rehrm.
58. Defendants' representations and promises were all false and
fraudulent. Their threats were considered by Plaintiffto be real and credible. All
such representations, promises and threats were made solely for the purpose of
coercing and otherwise inducing Plaintiff into prolonged sexual compliance.
Defendants knowingly benefitted financially and received things of value as a
result of their participating in their illegal enterprise.
COI]NT I
CAUSE OF ACTION AGNNST DEFEI\DAIITS PTIRSUAI\IT TO 18 U.S.C.
s 159s
59. Plaintiffadopts and realleges paragraphs 1 through 58 above.
t7
Case L:17-cv-00616 Document 1 Filed 01126117 Page 1-8 of 2L
60. Defendants individually and together, within the special maritime and
territorial jurisdiction of the United States, in interstate and foreign corrmerce
and/or affecting intemtate and foreign commerce, knowingly recruited, enticed,
harbored, transported, provided maintaine4 patronized" solicited, threatened"
forced, and coerced Plaintiff to engage in commercial sex acts. Such actions by
Defendants were undertaken with knowledge and/or recHess disregard of the fact
that their threats of force, frau{ coercion, and combinations of such meailt would
be used and were in fact use( in order to cause Plaintiffto engage in commercial
sex acts. In so doirg, Defendants violated 18 U.S.C. $$1591 through 1594 and are
subject to civil causes of action under 18 U.S.C. $ 1595.
6t. Defendants additionally profited from the sex haffrcking of Plaintiff;
obstnrcted investigations of the violations; atterrpted and conspired to violate, and
succeeded in violating, 18 U.S.C. $$ 1591 through 1595, by the commission of the
torts and crimes described in this complaint.
62. Certain property of Defendant Epstein's was essential to the
commission of the federal crimes and torts described herein, including the use of
multiple private aircraft including a Boeing aircraft (of make and model 8-727-
3lH with tail number N908JE) and a Gulfsteam aircraft (of make and model G-
1159B with tail nunber N909JE). Such aircraft, along with other of Defendants'
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property, were used as means and instruments of Defendants'tortious and criminal
offenses and as such, are subject to forfeiture.
63. Additionally, Defendant Epstein's New York mansion, located at 9
East 71st street New Yorh New Yorlq and his private island located in the United
States Vi.grn Islands, were used as means and instnrments of Defetrdants' tortious
and criminal offenses an4 as such, are subject to forfeitrue.
64. As a direct and proximate result of Defendants' commission of the
aforementioned criminal offenses enumerated in Title 18 U.S.C. $ 1591 et. seq.
and the civil remedies provided in $ 1595, Plaintiff has in the past suffered and will
continue to suffer iojrr.y and pain; emotional distress; psychological and psychi-
atric trauma; mental anguish; humiliation; confusion; errbalrassment; loss of self-
esteein; loss of digrrty; loss of enjoyment of life; invasion of privacy; and other
damages associated with Defendants' actions. Plaintiff will incur medical and
psychological expenses. These injuries are pennanent in nature and Plaintiff will
continue to suffer from them in the future. In addition to these losses, Plaintiffhas
incurred atlorneys' fees and will do so in the future.
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WHEREFORE, Plaintiff demands judgment against Defendants for
compensatory damages, attorney's fees, punitive damages and such other and
firther relief as this Court deerns just and proper. Plaintiffhereby demands trial by
jury on all issues tiable as ofrightby a jury.
Dated: January 26,2017
Respectfully Submitte(
BOIES, SCHILLER & FLDO{ER LLP
By: /s/ David Boies
David Boies
Boies Schiller & Flexner LLP
333 Main Street
Armonk, New York 10504
T: (9la) 749 8200
E: [email protected]
Alex Boies
Boies Schiller & Flexner LLP
575l-exngton Ave., 76 Fl.
New York, New York 10022
T: (212) 4/16-2300
E: [email protected]
Sigrid McCawl
Meredith Schultz
Boies Schiller & Flexner LLP
401 East Las Olas Blvd., Ste. 1200
, Fort Lauderdale, Florida 33301
T: (954) 3s6-0011
E: [email protected]
E: [email protected]
Pro Hac Yice to befiled
20
Case 1:17-cv-00616 Document 1 Frled OU26|L7 Page 2L of 2L
Bradley J. Edwards
Farmer, Jaffe, Weissing, Edwards,
Fistos & Lehrman, P.L.
425 North Andrews Ave., StE. 2
Fort Lauderdale, Florida 33301
T: (95a) s24-2820
E : brad@pathtojustice. com
Pro Hac Vice to befiled
J. Stanley Pottinger
J. Stanley Pottinger PLLC
Suite 100
49 Twin Lakes Road
South Salenl New York 10590
T: (9la) 763-8333
E: [email protected]
2l
Case 1:17-cv-00616 Document 1 Filed OLl26l77 Page 1 of 21
T'NITED STATES DISTRICT COI]RT
SOUTHERN DISTRICT OF NEW YORK
JA}IE DOE 43,
PlaintiI COMPLAINT
vs. JI]RY TRIAL DEMANDEI)
JEFFREY EPSTEIN, GHTSLAINE CASE NO.:
MAXWELL, SARAH KELLEN, LESLEY
GROFF, AND NATALYA MALYSHEV,
Defendants.
Plaintiff Jane Doe 43, by and through her undersigned counsel, for her
claims against Defendanrc Jeftey Epstein, Ghislaine Maxwell, Sarah Kellen,
Lesley Groff, and Natalya Malyshw, alleges upon personal knowledge with
respect to her own acts and status and upon 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. $ 1331.
2. Plaintiff files this Complaint under a pseudonym in order to protect
her identity because this Complaint makes allegations of a sensitive sexual nature
and disclosure of Plaintiffs name publicly will cause firther harm to her.
3. At all times material to the events alleged in this causie of action the
Plaintiffwas a citizen of South Africa residing in New Yorh New York.
EXH!BIT
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4. At all times material to this cause of action Defendant Jeftey Epstein
had multiple residences, including in New York, New York and the United States
Virgtn Islands. He is currently a citizen of the United States and a resident of New
York and the U.S. Virgin Islands.
5. At all times material to this cause of action Defendant Jeffrey Epstein
was an adult male bom in 1953.
6. At all times material to this cause of action Defendant Ghislaine
Maxwell was residing in in New Yorlq New York and was a cittzen of Great
Britain and France.
7. At all times material to this cause of action Sarah Kellen was residing
in New York, New York, and on information and belief, was a citizen of the
United States.
8. At all times material to this cause of action Lesley Groffwas residing
in New York, New York and, on information and belief, was a citizen of the
United States.
9. At all material times, Natalya Malyshev was residing in New Yorlq
New York and, on information and belief, was a citizen of the United States.
10. Including because a substantial part of the events and omissions
glving rise to this cause of action occured in the Southem District of New Yorh
venue is proper in that District. 28 U.S.C. $ 1391(bX2)
Case 1:17-cv-0061-G Document 1 Filed OLl26lL7 Page 3 ot 2L
11. At all times material to this cause of action, Defendants Jeffrey
Epstein, Ghislaine Maxwell, Saratr Kellen, Lesley Grofi and Natalya Malyshw
owed a duty to Plaintiffto freat her in a non-negligent manner and not to commit
or conspire to commit intentional or tortious illegal acts against her.
FACTUAL ALLEGATIONS
12. At all times material to this calrse of action Defendant Jeftey Epstein
was an adult male over 50 years old. Defendant Epstein is known as a billionaire
who uses his extraordinary wealth to commit illegal sexual crimes in violation of
federal and state statutes and to employ numerousl others, including the named
Defendants, to conspire and assist in committing those crimes and additional torts
as well as to protect and conceal his crimes and torts from being discovered.
13. Defendant Epstein displays his enormous wealth,Inwer and influence
to his employees; to the victims procured for sexual purposes; and to the public in
order to advance and carry out his crimes and torts. At all relevant times,
Defendant Epstein owned and continues to own, directly or through nominee
individuals used to conceal his interests, a fleet of airplanes, motor vehicles, boats
and one or more helicopters. He oumed and owns numerolul properties and homes,
including a 51,000-square-foot mansion in Manhattan; a $30 Million, 7,500-acre
ranch in New Mexico; a70-acte private island formerly known as Little St. James
in or near St. Thomas, U.S. Virgtn Islands; a mansion in London, England; a home
Case 1:17-cv-00616 Document 1 Filed 0Ll26lL7 Page 4 ot Zl
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 Virgln Islands.
14. Defendant Epstein has a compulsive sexual preference for young
females as young as 13 and as 'rold'r as 25. Defendant had sex with young females
virtually every day and assisted in the dwelopment and execution of a sex
trafficking scheme designed to fulfill his sexual desires.
15. Defendant Maxwell was for decades the highesf-mrrking employee of
the Defendants' sex trafficking enterprise. She herself recruited young females;
oversaw and trained other recruitem on how best to recnrit grds fof sex; developed
and executed schemes designed to recruit young females; and ensured that all
participants of the Defendants' sex tafficking scherre acted in certain specific
ways in order to advance the purposes of the scheme and conceal it from law
enforcement.
16. Defendant Kellen recruited young females and maintained Epstein'q
sex schedule in order to e,nsure that he was not without the sexual favors of young
females for any extended period of time. Defendant Kellen also handled travel
arrangements for the various females being exploited for sexual pu{poses.
4
Case 1:17-cv-00616 Document 1 Filed OU26|I7 page 5 of 21
Defendant Kellen reported directly up the enterprise's line of authority to
Defendant Murwell.
17. Defendant Epstein employed many recruiters of young females. The
nafiue of the Defendants' sex trafficking scheme enabled victims themselves, such
as Defendant Malyshev, to elevate their status to that of a paid recruiter of other
victims. Recruiters were taught by Defendants Epstein and Maxwell to inform
targeted victims that Epstein possessed extraordinary wealth, Ircwer, resources and
influence; that he was a philanthropist who would help female victims advance
their careers and lives; and that the recruits needed only to provide Epstein with
body massages in order to avail themselves of his financial assistance and
influence. In fact, howwer, these representatiors were fraudulent. The vast
majority of girls were required to perform intimate sexual acts at the Defendants'
direction and the Defendants did not help or intend to help advance the victims'
careeN.
18. Defendant Groff coordinated schedules between Defendant Epstein
and the various young females used for sex; made travel arrangements for the gnls;
tended to their living needs; and commruricated with them in order to maintain
their compliance with the rules of behavior imposed upon them by the enterprise.
19. The Defendants, led primarily by Defendants Epstein and Murwell,
fulfilled Epstein's compulsive need for sex with young fernales by preying on their
Case 1:17-cv-00616 Document 1 Filed OLl26lL7 Page 6 of 21
personal, psychological, financial, and related rnrlnerabilities. The Defendants'
tactics included promising the victims money, shelter, fiansportation, emploSment,
admission into educational institutions, educational tuition, and other things of
value in exchange for sex.
20. Defendants' sex tralficking venture and enterprise operated in a
hierarchal strucfire with Defendants Jeffrey Epstein and Ghislaine Ma>rwell at the
top and rurderlings below. Underlings included the other named Defendants as
well as unnarned co-conspirators such as various housekeepers and butlen; an
airplane pilot; and various employees, assistants and associates. Wittingly and
unwittingly, such underlings perfonrred their respective roles with the ptrpose and
effect of insuring that the enterprise supplied young females to Defendant Epstein
and others for sexual purposes. At all times materials to this complainq the
venfire and enterprise was a group of two or more individuals associated in fact
and deed.
21. Defendants Epstein and Maxwell, with help from assistants, associates
and underlings, recruited and procured hundreds of girls over the decades of the
operation of their sche,me. Such recruitnent and procurement included fraud,
coercion, the threat of coercion, ffid a combination of these and similar tactics.
Following the Defendants' recruifinent and procurement of the females to join
Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent
Case 1:17-cv-00616 Document 1 Filed OLl26lt7 PageT ot 2t
promises, coercion, and threats of coercion in order to entice young females into
sex and, once sexual activities ensued to cause them to remain in the enterprise.
The Defendants also transported fernales in interstate and foreign cornmerce and in
ways that affected interstate and foreign commerce.
22. Defendants specifically targeted underprivileged, emotionally
rnrlnerable and/or economically disadvantaged young females to joio the
Defendants' e,nterprise.
23. It is unknown exactly how long Defendant Epstein and Maxwell's
afore,mentioned criminal and illegal enterp,rise operatd 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 enterprise and conspiracy up to
the present time.
25. In 2005, Defendant Epstein and numerousl co-conspirators within the
enterprise were the subjects of a Palm Beach, Florida Police Department criminal
investigation which revealed that Defendant Epstein had engaged in sexual
activities with dozens of young teenage children. Each child was lured into
Defendant Epstein's Palm Beach mansion with a promise that she would receive
money for providing him with a body massage, although once there, each child
was made to engage in a sex act in order to recsive the promised compensation.
Case 1:17-cv-00616 Document 1 Filed O1l26lt7 Page 8 of 21
Several were also made to engage in sex with another of Defendant Epstein's
female sexual traveling companions.
26. Ir12006, the Palm Beach Police Deparfinent investigation was turned
over to the FBI and the United States Attorney's Office for the Southem District of
Florida. The United States Attorneyrs Office investigated Defendant Epstein and
his co-conspirators for their violations of numerous federal statutes, including 18
U.S.C. $1591, one of the statutory bases for this complaint.
27. The United States Attomey's investigation continued from 2006
through Septerrber 2007, at which time a Non-Prosecution Agreement was signed
between Jeffrey Epstein and the United States Attorney's Office defeming fedsral
prosecution of Defendant Epstein and his numerous ceconspirators for identified
federal sex crimes against more than 30 minors.
28. From late 2006 through Septerrber 2007, Epstein's team of lawyers
negotiated with the federal govemment in an effort to avoid the filing of the fifty-
three-page draft indictment of Epstein. During these negotiations, Defendant
Epstein decamped from Palm Beach to New York and the U.S. Virgin lslands in
order to convey an image to prosecutors that he and his co-conqpirators had
stopped committing sex crimes.
29. Remarkably, however-as this case will highlight-Defendant
Epstein and his co-Defendants, including the other defendants named herein, did
Case 1:L7-cv-00616 Document 1 Filed OU26|I7 Page 9 of 21
not abandon their sex trafficking enterprise even while they were under state and
federal investigation for crimes commiued in violation of 18 U.S.C. $ 1591, among
other laws, and even as Defendants and their attomeys were busy arguing Epstein's
innocence and publicly defaming his victims as liars. Rather, Defendants merely
changed their style. Instead of targeting local Palm Beach Florida high school
grrls, the Defendants transported young females from other places in the U.S. and
abroad and brought them to Defendant Epstein's mansion in New York and his
private island in the Virgin Islands.
30. In June of 2008, Epstein pleaded gurlty to Florida state felony sex
offenses for procuring a minor for prostitution and soliciting prostitution by
minors.
31. Defendants Epstein and Maxwell developed and implemented a
sophisticated system designed to insulate them from criminal and civil liability by
protecting them from potential testimony of knowledgeable subordinates. The
system included requiring subordinates to sign confidentiality agreements covering
civil and criminal activity; requiring subordinates and victims to refrain from
speaking with law enforcernent officials; requiring them to noti$ Defendant
Epstein's lawyers in the event they (subordinates and victims) were contacted by
law enforcement officials; requiring them to accept the representation of attomeys
paid for by Defendant Epstein; requiring them to invoke the Fiffh Amendment in
Case L:17-cv-00616 Document 1 Frled OU26|L7 Page 10 of 21
resllonse to questions they might be asked by investigators and prosecutors;
requiring them to invoke the Fiflh Amendment in order to refirse to turn over
incriminating and non-incriminating evidence to law enforcement officers;
requiring them to destroy evidence or refuse to reveal knowledge of desfroyed
evidence; and requiring them generally to refise all cooperation with law
enforcement offi cials or investigations.
32. tn 2005, Defe,ndant Epstein and other co-conspirators, aware that law
enforcement offrcials were preparing imminently to execute a search warrant of his
home, removed computer systerns that logged information about Epstein and his
co-conspirators' illegal and criminal conduct; the identities of witnesses; nude
photographs of young females; scheduling books; message pads; tangible items
such as vibrators and toys; and other incriminating matter.
33. Commencing in approximately October 2006 and continuing through
April 2007, Defendants recruited Plaintiff into their sexual enterprise by
fraudulently promising to use their corurections and resources to secure her
admission to an institution of higher education at the expeme of Defendant
Epstein.
34. Defendant Malyshev was working as one of the enterprise's recruiters
of young females when she approached and recruited Plaintiff.
l0
Case 1:17-cv-00616 Document 1 Frled Oil26lt7 page 11 of 21
35. Defendant Malyshev 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 Plaintiffachieve their personal and professional goals and aspirations.
36. Defendant Malyshev reported to her superiors, Defendants Kellen,
Groff and Maxwell, and was paid for her recruifinent of young females, including
the recruitnent of Plaintiff.
37. Defendant Malyshev introduced Plaintiff to Defendant Epstein, who
confirmed to Plaintiffthat he would use his wealth and influence to have Plaintiff
admitted into The Fashion Institute of Technology, known as "F.I.T.", in New
York City, or into a similar institute of higher learning offering a curriculum of
fashion industry training. Defendants Maxwell, Kellen and Groff each confirmed
this promise to Plaintiffmany times.
38. Defendant Maxwell told Plaintiff she would need to provide
Defendant Epstein with body massages in order to reap the benefrts of his and
Maxwell's connections. Maxwell and Epstein also threatened Plaintiffthat, while
they had the ability to advance her education and career, they also had the ability to
make sure that she would obtain no formal education or modeling agency contracts
if she failed to provide the sexual favors desired by Defendant Epstein or abide by
the instnrctions given her by Defendan* Epstein and Maxwell.
ll
Case 1:17-cv-00616 Document 1 Flled OU26|L7 page L2 ot 2L
39. Plaintiff reasonably believed that her compliance with Defendants'
demands was crucial to her physical, psychological, financial, and reputational
survival.
40. Defendant Maxwell instucted Plaintiffhow to massage Epstein using
the techniques that he preferred. During Plaintiffs first massage, Defendant
Epstein converted it into a sexual act and made it known to Plaintiff that firther
sex would be required in order for her to obtain the assistance he promised and to
avoid Defendants' threatened retaliation if Plaintitrdid not perfonn as demanded.
41. Defendants Maxwell and Epstein informed Plaintiffthat other young
females in Defendant Epstein's company were there not only to provide ma,ssages,
but also sexual acts.
42. Plaintiff was instnrcted dozens of times to provide body massages to
Defendant Epstein, both at his toumhouse in New York and on his private island in
the U.S. Virgin Islands. Each time she was so instnrcted she was also required to
perform a sexual act with Defendant Epstein. The Defendants fiansported Plaintiff
in interstate and foreign corlmerce, ffid affecting int€rstate and foreign commerce,
for these sexual purposes.
43. During many sexual encounters, Defendant Epstein gave Plaintiffno
option, opportunity or choice not to participate in the prescribed sexual acts.
t2
Case 1:17-cv-00616 Document 1 Filed O\l26lt7 Page L3 of 21
4. Defendant Ma:rwell frequently controlled the assignment, or
"rotation," of Plaintiffand the other young females concerning the time, place and
manner of the sex acts they were told to provide to Defendant Epstein. Defendants
Maxwell and Epstein also required Plaintiff to engage in sex acts with other
females.
45. Defendants Epstein and Maxwell intimidated threatened, humiliated
and verbally abused Plaintiffin order to coerce her into sexual compliance. These
Defendants threatened Plaintiff with serious harm, as well as serious
psychological, financial, and reputational harrn, with the purpose and effect of
compelling Plaintiff to perform and continue performing the demanded
commercial sexual activity.
46. On one occasion, after suffering verbal abuse and threats by
Defendants Epstein, Maxwell, and Kellen, Plaintiff attempted to escape from
Defendant Epstein's private island. A search party led by Defendant Epstein
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 caluie, 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, ernployability, and stable state of mind.
13
Case 1:17-cv-00616 Document 1 Ftled OUZi|LT page L4 of 2\
47. Defendant Epstein's wealth, influence, power and connections were
used both as an inducement to provide sex (in exchange for promises of support),
and as a means of threatening punishment (should Plaintiffrefirse to comply with
Defendants' instnrctions).
48. In addition to Plaintiffs being trafficked on Defendant Epstein's
private plane, Defendants Groff, Maxwell and Kellen, urith the knowledge of and
instuction by Defendant Epstein, arranged Plaintiffs commercial air travel on
numercusl occasions for the purpose of causing Plaintiffto commit commercial sex
acts.
49. Defendants provided living quarters for Plaintiffat 301 East 66 Street,
New York; a car service for Plaintiff to use as needed; a cell phone; and other
valuable consideration in order to maintain Plaintiffs sexual compliance.
50. The relationship between Plaintiff and Defendants Epstein and
Maxwell was defined and characterizcd by Defendant Epstein's and Defendant
Maxwell's freque,nt and persistent fraudulent rqrresentations that they would
provide Plaintitr with a fonnal education and career advancement if she provided
sex to Defendant Epstein and others in the times, places and manners demanded by
Defendants. Plaintiffreasonably relied on those representations. In fact, however,
those representations were knowingly false, were not acted ulx)n, and were made
by Defendants Epstein and Maxwell solely for the purpose of maintaining
t4
Case 1:17-cv-00616 Document 1 Filed OU26ll7 Page 15 of 21
Plaintiffs financial dependence or, emotional vulnerability to, and sexual
compliance with Defsndants Epstein and Maxwell and their demands. The other
Defendants intentionally repeated those representations and intentionally at0empted
to convince Plaintiffthat the representations were tue and could be relied upon.
51. In January 2007, Defendants sent Plaintiff from the United States to
South Africa in part to recruit, for a promised fee, one or more aspiring female
models supposedly for Defe,ndant Epstein to use as an alleged personal assistant.
Defendants Epstein and Maxwell continuously and frequently demanded that
Plaintiff fulflll this task as a condition of her receiving the education, career and
related benefits promised by Defendants Epstein and Morwell. Based upon
Plaintiffs experience with Defendants, however, she did not believe that the
requested model would be placed in a legitimate position of employment with
Defendant Epstein but would, instea4 be forced into sexual senitude. As a resulg
Plaintiffdeliberately refitsed to perform the recruitment assignment.
52. As part of their ongoing scheme, Defendans inflicted serious
emotional and psychological harm on Plaintiff as a means of coercing her to
continue engaging in commercial sex acts. While Plaintiff was in South Africa,
Defendants Epstein and Maxwell informed Plaintiff that she would not be
permiued to return to the United States to receive her promised education rmless
she underwent a diet and lowered her body weight from 57 kilograms
l5
Case 1-:17-cv-00616 Document 1 Filed OU26|L7 Page 16 of 21
(approximately 125 pounds) to 52 kilograms (ap,proximately ll4 pounds).
Believing she had no practical choice in the matter, Plaintiff atterrpted to comply
with the order but, give,n her physical height and stnrcflre and her existing low
body weight, the diet imposed upon her placed her in serious physical jeopardy,
including kidney malfirnction and extreme emotional andpsychological distess.
53. Defendants Epstein and Maxwell called Plaintiffs parents in South
Africa to tell them that Defendants would take good care of Plaintiff when she
retumed to the United States and that they would use their connections and
influence to have her adrritted to F.I.T. or another well-regarded fashion school.
54. In February of 2N7, Plaintiffreturned to New York and was promptly
ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants
Maxwell and Epstein fraudulently promised her again that her sexual compliance
would be rewarded with admission to F.I.T. or a comparable college, a promise
which they knew to be false. Plaintiffknew that if she did not comply, Defendants
Maxwell and Epstein would use their lx)wer, influence and connections in order to
eruiure that Plaintiffwas unable to gain adurission to F.I.T. or a comparable school,
and that they would destroy her career as they had destroyed the caxeers of others
who had failed to comply.
55. Defendants Epstein and Maxwell continued to provide Plainfiff with
things of value in exchange for Plaintiffs continued compliance with Epstein's
t6
Case 1:17-cv-00616 Document 1 Filed OLl26lL7 Page L7 ot 2I
sexual demands; however, they failed and refirsed to perform their promises to help
Plaintiff be admitted to F.I.T. or another school, or to provide financial support for
college admission or on-going education, false promises they repeatedly made in
order to coerce her into commercial sex acts.
56. Defendants Epstein and Morwell's sexual demands on Plaintiff
continued while she was in New York or other geographic proximity to the
Defendants. In addition to their requiring Plaintiff to provide Defendant Epstein
with sex acts, Defendants continued to pressure her to lose excessive arrrounts of
body weight and offered her no opportunity to decline or resist their instuctions.
57 . In May, 2N7, Plaintiffleft the United States and did not rehrm.
58. Defendants' representations and promises were all false and
fraudulent. Their threats were considered by Plaintiffto be real and credible. All
such representations, promises and threats were made solely for the purpose of
coercing and otherwise inducing Plaintiff into prolonged sexual compliance.
Defendants knowingly benefitted financially and received things of value as a
result of their participating in their illegal enterprise.
COI]NT I
CAUSE OF ACTION AGNNST DEFEI\DAIITS PTIRSUAI\IT TO 18 U.S.C.
s 159s
59. Plaintiffadopts and realleges paragraphs 1 through 58 above.
t7
Case L:17-cv-00616 Document 1 Filed 01126117 Page 1-8 of 2L
60. Defendants individually and together, within the special maritime and
territorial jurisdiction of the United States, in interstate and foreign corrmerce
and/or affecting intemtate and foreign commerce, knowingly recruited, enticed,
harbored, transported, provided maintaine4 patronized" solicited, threatened"
forced, and coerced Plaintiff to engage in commercial sex acts. Such actions by
Defendants were undertaken with knowledge and/or recHess disregard of the fact
that their threats of force, frau{ coercion, and combinations of such meailt would
be used and were in fact use( in order to cause Plaintiffto engage in commercial
sex acts. In so doirg, Defendants violated 18 U.S.C. $$1591 through 1594 and are
subject to civil causes of action under 18 U.S.C. $ 1595.
6t. Defendants additionally profited from the sex haffrcking of Plaintiff;
obstnrcted investigations of the violations; atterrpted and conspired to violate, and
succeeded in violating, 18 U.S.C. $$ 1591 through 1595, by the commission of the
torts and crimes described in this complaint.
62. Certain property of Defendant Epstein's was essential to the
commission of the federal crimes and torts described herein, including the use of
multiple private aircraft including a Boeing aircraft (of make and model 8-727-
3lH with tail number N908JE) and a Gulfsteam aircraft (of make and model G-
1159B with tail nunber N909JE). Such aircraft, along with other of Defendants'
l8
Case 1:17-cv-00616 Document 1 Filed OU26lt7 Page 1g of 21
property, were used as means and instruments of Defendants'tortious and criminal
offenses and as such, are subject to forfeiture.
63. Additionally, Defendant Epstein's New York mansion, located at 9
East 71st street New Yorh New Yorlq and his private island located in the United
States Vi.grn Islands, were used as means and instnrments of Defetrdants' tortious
and criminal offenses an4 as such, are subject to forfeitrue.
64. As a direct and proximate result of Defendants' commission of the
aforementioned criminal offenses enumerated in Title 18 U.S.C. $ 1591 et. seq.
and the civil remedies provided in $ 1595, Plaintiff has in the past suffered and will
continue to suffer iojrr.y and pain; emotional distress; psychological and psychi-
atric trauma; mental anguish; humiliation; confusion; errbalrassment; loss of self-
esteein; loss of digrrty; loss of enjoyment of life; invasion of privacy; and other
damages associated with Defendants' actions. Plaintiff will incur medical and
psychological expenses. These injuries are pennanent in nature and Plaintiff will
continue to suffer from them in the future. In addition to these losses, Plaintiffhas
incurred atlorneys' fees and will do so in the future.
19
Case 1:17-cv-00616 Document 1 Flled O1.l26lL7 Page 20 ot 2L
WHEREFORE, Plaintiff demands judgment against Defendants for
compensatory damages, attorney's fees, punitive damages and such other and
firther relief as this Court deerns just and proper. Plaintiffhereby demands trial by
jury on all issues tiable as ofrightby a jury.
Dated: January 26,2017
Respectfully Submitte(
BOIES, SCHILLER & FLDO{ER LLP
By: /s/ David Boies
David Boies
Boies Schiller & Flexner LLP
333 Main Street
Armonk, New York 10504
T: (9la) 749 8200
E: [email protected]
Alex Boies
Boies Schiller & Flexner LLP
575l-exngton Ave., 76 Fl.
New York, New York 10022
T: (212) 4/16-2300
E: [email protected]
Sigrid McCawl
Meredith Schultz
Boies Schiller & Flexner LLP
401 East Las Olas Blvd., Ste. 1200
, Fort Lauderdale, Florida 33301
T: (954) 3s6-0011
E: [email protected]
E: [email protected]
Pro Hac Yice to befiled
20
Case 1:17-cv-00616 Document 1 Frled OU26|L7 Page 2L of 2L
Bradley J. Edwards
Farmer, Jaffe, Weissing, Edwards,
Fistos & Lehrman, P.L.
425 North Andrews Ave., StE. 2
Fort Lauderdale, Florida 33301
T: (95a) s24-2820
E : brad@pathtojustice. com
Pro Hac Vice to befiled
J. Stanley Pottinger
J. Stanley Pottinger PLLC
Suite 100
49 Twin Lakes Road
South Salenl New York 10590
T: (9la) 763-8333
E: [email protected]
2l