EFTA01249981.pdf

Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 3. of 52 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO.: PRISCILLA DOE, Plaintiff, vs. DARREN K. INDYKE AND RICHARD D. KAHN AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN, NINE EAST 715T STREET, CORPORATION, FINANCIAL TRUST COMPANY, INC., NES, LLC, MAPLE, INC., LSJ, LLC, HBRK ASSOCIATES, INC., JEGE, INC., Defendants. COMPLAINT Plaintiff, PRISCILLA DOE, by and through her undersigned counsel, for her claims against Defendants, alleges as follows: 1. This action is brought pursuant to 18 U.S.C. §1591 - §1595. Therefore, 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 the disclosure of which, in association with her name, would cause further harm to her. 3501.484-002 Page 1 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095907 EFTA01249981  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 2 of 52 3. Plaintiff is currently a resident of and domiciled in the 4. At all times material, Jeffrey Epstein was a citizen of the United States and a resident of the U.S. Virgin Islands. Jeffrey Epstein was a man of extraordinary wealth who travelled between and stayed regularly in multiple residences, including in New York, New York (within the Southern District of New York) at 9 East 7P Street, New York, NY 10021; in Palm Beach, Florida at 358 El Brillo Way, Palm Beach, Florida 33480; in New Mexico at 49 Zorro Ranch Road, Stanley, New Mexico 87056, and in the United States Virgin Islands at Island Little St. James Island No. 6B USVI 00802. 5. At all times material to this cause of action Jeffrey Epstein was an adult male born in 1953, who died on August 10, 2019. 6. Defendant, Darren K. Indyke and Richard D. Kahn as Joint Personal Representatives of the Estate of Jeffrey E. Epstein ("Estate of Jeffrey E. Epstein") the Estate of Jeffrey E. Epstein was opened and domiciled in the United States Virgin Islands, St. Thomas Division, and is the legal entity responsible for intentional, criminal, or tortious conduct committed by Jeffrey Epstein as described in this Complaint. 7. At all times material hereto, Defendant Nine East 71st Street, Corporation ("Nine East") was a domestic business corporation conducting business 2 3501.484-002 Page 2 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095908 EFTA01249982  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 3 of 52 in New York, with its principal place of business located at 575 Lexington Avenue, Fourth Floor, New York, NY 10022. 8. At all times material hereto, Defendant Financial Trust Company, Inc. ("Financial Trust"), was and is a U.S. Virgin Islands corporation conducting business in multiple locations including New York. 9. At all times material hereto, Defendant NES, LLC, ("NES") was and is a domestic limited liability company registered in and conducting business in multiple locations including New York. 10. At all times material hereto, Defendant, Maple, Inc., ("Maple") is and was a U.S. Virgin Islands corporation which conducted business in New York. 11. At all times material hereto, Defendant L.S.J., LLC, ("LSJ") was a Delaware corporation conducting business in the United States Virgin Islands with a registered agent located at 1209 Orange Street, Wilmington, Delaware 19801. 12. At all times material hereto, Defendant HBRK Associates, Inc., ("HBRK") is and was a domestic business corporation registered in and conducting business in multiple locations including New York with a Registered Agent located at 1365 York Avenue, Apartment 28, New York, New York 10021. 13. At all times material hereto, Defendant JEGE, Inc., ("JEGE") was a Delaware corporation conducting business throughout the United States of America, including but not limited to, Florida, New York, and the United States Virgin 3 3501.484-002 Page 3 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095909 EFTA01249983  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 4 of 52 Islands, with a registered agent located at 1209 Orange Street, Wilmington, Delaware 19801. 14. Corporate Defendants NES, LLC; Financial Trust Company, Inc; Nine East 71 " Street; Maple, Inc.; L.S.J., LLC; HBRK Associates, Inc.; and JEGE, Inc., referred to as "Corporate Defendants," each performed business, in whole or part, in New York. 15. Plaintiff intends to amend this complaint to add or substitute additional parties as discovery reveals the identities of other tortious corporate or individual actors. 16. Jeffrey Epstein, the leader of a complex commercial sex trafficking and abuse ring, was an officer, director, or employee of many corporate entities registered in various states throughout the United States, one or more of which may also be legally responsible for the crimes he committed against young females, including Plaintiff 17. Additionally, individuals who worked at the residences where sexual criminal acts were committed, or friends or acquaintances who assisted Jeffrey Epstein in committing such violations or those of his wealthy, famous, or socially powerful friends with whom Jeffrey Epstein caused Plaintiff to be sexually abused by, or those who were employed through, or worked for, numerous other corporate 4 3501.484-002 Page 4 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095910 EFTA01249984  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 5 of 52 entities whose participation caused or contributed to causing the sexual violations that caused harm to Plaintiff, may additionally be added as defendants. 18. A substantial part of the acts, events, and omissions giving rise to this cause of action occurred in the Southern District of New York; venue is proper in this District. 28 U.S.C. section 1391(b)(2). 19. At all times material to this cause of action, Jeffrey Epstein (legally represented now through Darren K. Indyke and Richard D. Kahn as Joint Personal Representatives of the Estate of Jeffrey E. Epstein (and referred to herein as "Estate of Jeffrey E. Epstein") and Corporate Defendants owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit, or conspire to commit, or cause to be committed intentional, criminal, fraudulent, or tortious acts against Plaintiff, including any acts that would cause Plaintiff to be harmed through conduct committed against her in violation of Common law battery, New York Penal Law section 130.20; or New York Penal Law 130.35; or New York Penal Law 130.50; or New York Penal Law 130.52; or New York Penal Law 130.66; or any violation of 18 U.S.C. §1591 - §1595. FACTUAL ALLEGATIONS 20. At all times material to this cause of action, Jeffrey Epstein was an adult male over 45 years old. Epstein was a tremendously wealthy individual, widely recognized as a billionaire, who used his wealth, power, resources, and connections 5 3501.484-002 Page 5 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095911 EFTA01249985  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 6 of 52 to commit illegal sexual crimes in violation of federal and state laws and who employed or conspired with other individuals and corporate entities to assist him in committing those crimes or torts or who facilitated or enabled those acts to occur. 21. Epstein displayed his enormous wealth, power, and influence to his employees; to the employees of the corporate or company entities who worked at his direction; to the victims procured for sexual purposes; and to the public, in order to advance, carry out and conceal his crimes and torts. 22. At all relevant times, Epstein had access to numerous mansions, as well as a fleet of airplanes, motor vehicles, boats and one or more helicopters. For example, he regularly traveled by private jet aboard a Boeing aircraft (of make and model B-727-31H with tail number N908JE) or a Gulfstream aircraft (of make and model G-1159B with tail number N909JE). 23. Jeffrey Epstein also frequently inhabited and travelled between numerous properties and homes, each of which he admitted to being owned or controlled by him, including a Manhattan townhotne located at 9 East 71' Street, New York, NY 10021 valued conservatively by Jeffrey Epstein's own admission at $55,931,000.00; a ranch located at 49 Zorro Ranch Road, Stanley, New Mexico 87056 valued conservatively by Jeffrey Epstein's own admission at $17,246,208.00; a home located at 358 El Brillo Way, Palm Beach, Florida 33480 valued conservatively by Jeffrey Epstein's own admission at $12,380,209.00; an apartment 6 3501.484-002 Page 6 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095912 EFTA01249986  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 7 of 52 located at 22 Avenue Foch, Paris, France 75116 valued conservatively by Jeffrey Epstein's own admission at $8,672,820.00; an Island located at Great St. James Island No. 6A USVI 00802 (parcels A, B, C); and an Island Little St. James Island No. 6B USVI 00802 (A, B, C). See Jeffrey Epstein "Asset Summary — June 30, 2019" filed in Case 1:19-cr-00490-RMB on July 15, 2019 attached hereto as Exhibit A. 24. Jeffrey Epstein controlled or was otherwise affiliated with the corporation or business entities that owned, managed, or maintained each of the real properties listed in the preceding paragraph. 25. The allegations herein concern Jeffrey Epstein's tortious conduct committed against Plaintiff; while at the residence owned by Defendant Nine East and then Defendant Maple; or the residence located in the United States Virgin Islands owned by LSJ. Many such acts were facilitated by Defendant NES, or Defendant HBRK, or Defendant JEGE. 26. Epstein had a compulsive sexual preference for young females, as young as 14 years old, and acted on that sexual preference for decades. 27. Epstein enjoyed sexual contact with young females, including minor children, and also took pleasure corrupting vulnerable and innocent young females, including minor children, into engaging in sexual acts with him. 7 3501.484-002 Page 7 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095913 EFTA01249987  Case 1:19-cv-07772-ALC-DCF Document 3. Filed 08/20/19 Page 8 of 52 28. Epstein directed a complex system of individuals, including employees and associates of Defendant entities, to work in concert and at his direction, for the purpose of harming young females through sexual exploitation, abuse and trafficking. 29. It was widely known among individuals regularly in Epstein's presence that he obtained pleasure from corrupting and inducing vulnerable young females into engaging in uncomfortable and unwanted sexual acts for his own gratification. 30. Epstein's illegal sexual activities were investigated by law enforcement on at least two occasions, once in 2005-2008 by the United States Attorney for the Southern District of Florida, and more recently by the United States Attorney for the Southern District of New York. 31. On July 2, 2019, the United States Attorney's Office for the Southern District of New York filed a Sealed Two Count Indictment including One Count of Sex Trafficking Conspiracy and One Count of Sex Trafficking for violations of 18 U.S.C. §1591, in part due to Epstein's criminal activities against children in the New York Mansion located at 9 East 71s1 Street. 32. On July 8, 2019, Jeffrey Epstein was arrested pursuant to the aforementioned Indictment, which is attached hereto as Exhibit B. 33. The Indictment stated in part, and Plaintiff herein adopts as true and relevant to her Complaint, that "Jeffrey Epstein, the defendant, enticed and recruited, 8 3501.484-002 Page 8 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095914 EFTA01249988  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 9 of 52 and caused to be enticed and recruited, minor girls to visit his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residence") to engage in sex acts with him, after which the victims were given hundreds of dollars in cash." Criminal Indictment at 1. 34. "Moreover, and in order to maintain and increase his supply of victims, Epstein also paid certain of his victims to recruit additional girls to be similarly abused by EPSTEIN. In this way, EPSTEIN created a vast network of underage victims for him to sexually exploit in locations including New York and Palm Beach." Criminal Indictment at 1-2. 35. "The victims described herein were as young as 14 years old at the time they were abused by Jeffrey Epstein, and were, for various reasons, often particularly vulnerable to exploitation. Epstein intentionally sought out minors and knew that many of his victims were in fact under the age of 18, including because, in some instances, minor victims expressly told him their age." Criminal Indictment at 2. 36. "In creating and maintaining this network of minor victims in multiple states to sexually abuse and exploit, JEFFREY EPSTEIN ... worked and conspired with others, including employees and associates who facilitated his conduct by, among other things, contacting victims and scheduling their sexual encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence." Criminal Indictment at 2. 9 3501.484-002 Page 9 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095915 EFTA01249989  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 10 of 52 37. The indictment further explained, and Plaintiff adopts and alleges, that, "[v]ictims were initially recruited to provide `massages' to Epstein, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts." Criminal Indictment at 3. 38. "Epstein abused numerous minor victims at the New York Residence by causing these victims to be recruited to engage in paid sex acts with him." Criminal Indictment at 3. 39. In addition to the allegations in the criminal indictment referenced above, Epstein also utilized a similar, if not the same, scheme many years before the time period that was charged and many years after, as well as in additional locations nationally and internationally. 40. Corporate Defendants enabled Jeffrey Epstein to receive daily massages from young females, often minors, who were not experienced in massage. Rather than receive regular body massages, Epstein was predictably sexually abusing the young females, including Plaintiff, in violation of New York Penal Law Section 130. 41. Additionally, employees of the various Corporate Defendant performed actions or failed to perform actions that further placed victims, including Plaintiff, in danger of being sexually abused by Epstein, and assisted in the concealment of his sexually abusive acts. 10 3501.484-002 Page 10 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095916 EFTA01249990  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page u. of 52 42. Defendants employed many recruiters of young females, or directed employees of his related companies, to recruit young females. In order to grow the enterprise and satisfy his insatiable sexual desire, Epstein and those working at his direction enabled victims themselves to elevate their status within the enterprise to that of a paid recruiter of other victims, an elevation only made possible through the assistance of Defendants. 43. Recruiters were taught by Jeffrey Epstein or by employees of Corporate Defendants to inform targeted young female victims that Epstein possessed extraordinary wealth, power, resources, and influence; that he was a philanthropist who would help female victims advance their education, careers, and lives; and that she only needed to provide Epstein with body massages in order to avail herself of his nearly unlimited assistance and influence. 44. Epstein and Corporate Defendants and their many employees fulfilled Epstein's compulsive need for sex with young females by preying on their personal, psychological, financial, and related vulnerabilities. Epstein and Defendants' tactics included promising the victims money, shelter, transportation, gifts, employment, admission into educational institutions, educational tuition, profession, licensure, protection, healthcare, and other things of value. 45. Jeffrey Epstein's sexual attraction to young, often underage, females dated back to at least the mid-nineties and the number of victims increased 11 3501.484-002 Page 11 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095917 EFTA01249991  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 12 of 52 substantially with the necessary assistance from Defendants and Defendants' employees. 46. Defendants, at the direction of Epstein or in furtherance of his demands, and with help from assistants, associates and underlings, and even other victims, recruited or procured dozens if not hundreds of young females, including minors, for the purpose of Epstein's sexual gratification. 47. Jeffrey Epstein, and employees of certain Corporate Defendants, including at least Defendant HBRK, specifically targeted underprivileged, emotionally vulnerable and/or economically disadvantaged young females to sexually molest and abuse. 48. Additionally, Jeffrey Epstein and Corporate Defendants, through employees, informed young females, including Plaintiff, that Jeffrey Epstein was wealthy, well-connected, and had the power and ability to impact the life of any young female recruited or obtained to provide a massage. 49. Each of the Corporate Defendants committed acts of negligence that allowed for Epstein to commit acts in violation of New York Penal Law section 130. 50. Each of the Defendants committed acts against Plaintiff in violation of 18 U.S.C. §I59 I - §1595. 12 3501.484-002 Page 12 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095918 EFTA01249992  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 13 of 52 PRISCILLA DOE 51. Plaintiff was twenty years old when she met Jeffrey Epstein in 2006, at a time when Jeffrey Epstein was under federal criminal investigation by the United States Attorney for the Southern District of Florida in relation to his commission of various federal crimes, including violations of 18 U.S.C. §1591, against more than 30 identified minor females. 52. Plaintiff was a_in New York when she was recruited to meet Jeffrey Epstein by another young female who had also fallen prey to Jeffrey Epstein's sex trafficking scheme. 53. The recruiter asked Plaintiff if she wanted a job giving massages to a very wealthy man. 54. Plaintiff agreed to meet Jeffrey Epstein, knowing that she would be going to a New York mansion to give a wealthy man a massage. 55. The first time to the Mansion at 9 East 71st Street, she was taken upstairs and Jeffrey Epstein paid her hundreds of dollars to give him a massage. This massage was not sexual and Jeffrey Epstein used the time to ask Plaintiff about her life, during which he learned that 13 3501.484-002 Page 13 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095919 EFTA01249993  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 14 of 52 56. Jeffrey Epstein paid Plaintiff for the massage, took her number and told her someone would call her to return. 57. Associate I called Plaintiff and told her to come back for a second time. 58. Again, on a second visit, Plaintiff was taken to the massage room in the Mansion and Jeffrey Epstein spent much of the time asking questions about Plaintiff, learning what she cared about, what professional plans she had, and what problems she was experiencing. 59. By the third visit, in 2006, Jeffrey Epstein informed Plaintiff that he had resources that he would use to advance Plaintiff's career if she would do what he wanted her to do. 60. Plaintiff started visiting Jeffrey Epstein more regularly and he began making the massages more sexual, digitally penetrating Plaintiff, and using sexual objects to insert in Plaintiff. 61. Jeffrey Epstein always reminded Plaintiff that because of the money he was paying her for the commercial sex acts that he called "massage," she was able, for the first time, to pay for her mother's rent and for her own groceries. 62. During her conversations with Jeffrey Epstein, 14 3501.484-002 Page 14 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095920 EFTA01249994  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 15 of 52 63. Despite the fact that he had assured Plaintiff he would not try to have sexual intercourse with her, Jeffrey Epstein forced himself on Plaintiff against her will and wishes. 64. In 2006, Jeffrey Epstein told Plaintiff she was going on a trip with him to his island in the United States Virgin Islands. 65. On that trip was Jeffrey Epstein, Jean Luc Brunel, Ghislaine Maxwell, Associate 2, Associate 8, and two other victims in addition to Plaintiff. 66. It was there that Ghislaine Maxwell taught Plaintiff the "proper way to give a blow job," describing to her the exact way that Jeffrey Epstein liked to he sexually serviced orally. 67. Ghislaine Maxwell explicitly told Plaintiff she needed to learn how to properly sexually service Jeffrey Epstein in the exact way that he preferred. 68. Ghislaine Maxwell then taught Plaintiff step by step, using her own hands to demonstrate, how to pleasure Jeffrey Epstein manually so that Plaintiff would know exactly how to make Jeffrey Epstein happy. 69. The instruction by Ghislaine Maxwell included training on the proper pressure to apply, the location in which pressure should be applied, the location of the various nerve endings that should be stimulated, and the areas of the penis that are the most sensitive for targeted stimulation. 15 3501.484-002 Page 15 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095921 EFTA01249995  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 16 of 52 70. Ghislaine Maxwell made it clear to Plaintiff that it was very important for her to understand and take this instruction seriously. The message delivered to Plaintiff by Ghislaine Maxwell was conveyed in a serious manner that instilled genuine fear in Plaintiff that her failure to comply would cause her serious harm. 71. When Plaintiff was called in to "massage" Jeffrey Epstein on the Island after Ghislaine Maxwell's instruction, he reiterated the same instruction that Plaintiff was provided by Ghislaine Maxwell using a hands on approach. 72. In addition to providing sexual instruction, Ghislaine Maxwell further made sure that Plaintiff and the other young females were constantly on call to sexually service Jeffrey Epstein. 73. While on the Island, Associate 2 also made it clear to Plaintiff that when Jeffrey Epstein asked her to engage in certain sexual behavior, she needed to comply. 74. Shortly thereafter, Jeffrey Epstein forced Plaintiff to engage in sexual activity with Associate 2 in his presence for his own sexual gratification. The experience between Plaintiff and Associate 2 was especially uncomfortable for Plaintiff. Jeffrey Epstein directed Associate 2 to use force on Plaintiff even after Plaintiff stated that she was uncomfortable and did not want to participate in the sexual acts then underway. At one point during the encounter, Jeffrey Epstein put his hands around Plaintiff's neck, which caused her a great deal of fear and 16 3501.484-002 Page 16 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095922 EFTA01249996  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 17 of 52 discomfort. Jeffrey Epstein then masturbated and instructed Plaintiff to leave the room. 75. Knowing that Jeffrey Epstein and his associates had confiscated her passport to prevent her from having the ability to leave the Island voluntarily, Plaintiff feared for her safety and felt forced into engaging in these sexual acts against her will. 76. It was clear by this trip that Jeffrey Epstein was extremely powerful and could cause serious harm to Plaintiff if she disobeyed. 77. Jeffrey Epstein learned in 2007 that 78. Plaintiff and Epstein talked numerous times about the fact that Plaintiff would only introduce him to her relative if he promised not to engage in any sexual conduct with her, to which Jeffrey Epstein agreed. 79. Jeffrey Epstein constantly reminded Plaintiff that he was going to help as a way to force Plaintiff to engage in commercial sex acts. 80. While Plaintiff was giving sexual massages, Jeffrey Epstein would always answer the phone if someone called. Important Business Person I, Important Business Person 2, Important Business Person 3, and Important Business Person 4 17 3501.484-002 Page 17 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095923 EFTA01249997  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/3.9 Page 18 of 52 were regular callers and people with whom Jeffrey Epstein would have telephone calls during sexual massages. Plaintiff does not want to reveal the identities of these individuals out of fear of retaliation. 81. There were also times when Jeffrey Epstein, during sexual massages, would be on the verge of ejaculating and would stop in order to make a phone call, at times saying that nearing sexual climax evoked certain important thoughts in Jeffrey Epstein's mind. Jeffrey Epstein would then take or initiate up to four business calls during any particular sexual massage. 82. During these phone calls, Jeffrey Epstein would seem to be advising the individuals he called in a very stern, authoritative voice. 83. On numerous calls, Plaintiff heard Jeffrey Epstein using a very angry and threatening tone and voice, making it known to the other party, and to Plaintiff, that he had the ability to cause serious harm to powerful people and anyone who did not cooperate with him. 84. The reasonable impression that Plaintiff had from overhearing his phone calls and listening to what he told her was that Jeffrey Epstein controlled very powerful and influential people and that disobeying him would cause serious repercussions for the disobedient party. 85. Plaintiff spent considerable time with Jeffrey Epstein and overheard many conversation. In most, Jeffrey Epstein seemed to be advising other powerful 18 3501.484-002 Page 18 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095924 EFTA01249998  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 19 of 52 individuals in a business context. However, Important Business Person 1 was someone Jeffrey Epstein spoke to frequently, not only about business matters but also about what appeared to be intimate personal matters. Based on the conversations she heard, and the manner and style of voice Epstein used, Plaintiff believed for many months that this person was a female. 86. As Jeffrey Epstein realized Plaintiff's vulnerabilities, he began controlling her even more to a point where she felt she had no choice but to engage in commercial sex acts without putting herself in serious danger. 87. Jeffrey Epstein would demand that Plaintiff massage him and if he went to sleep she was told she had to continue to massage him knowing that he would become very angry if he stopped. 88. From 2006, when Jeffrey Epstein first forced himself on her , until 2012, he forced her to engage in commercial sex with him—sex for money—including intercourse, regularly and consistently. At no time did he give her a choice not to cooperate. 89. During that time, Jeffrey Epstein controlled nearly every aspect of Plaintiff's life from the clothing and jewelry she was permitted to wear to the career path she was permitted to followed, to the food she was allowed to consumed. 90. When Jeffrey Epstein went to jail for sex offenses in Florida, he maintained contact with Plaintiff. He and employees of Defendant HBRK and 19 3501.484-002 Page 19 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095925 EFTA01249999  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 20 of 52 Defendant NES and Defendant JEGE caused Plaintiff to be transported to Florida in order to engage in commercial sex with Jeffrey Epstein in his Florida residence while on so-called "work release" from jail, while he was still wearing his ankle monitor. 91. After Jeffrey Epstein was no longer in "jail" or on "work release" and came back to New York, Plaintiff attempted to discontinue seeing Jeffrey Epstein. This attempt angered Jeffrey Epstein. 92. There came a time when Plaintiff, on her own, took a trip to Montreal and Jeffrey Epstein immediately knew that she was gone from New York and summoned her back to his New York Mansion. He told her she was not permitted to leave New York without his permission and that she was required at all time to remain in New York, on call to service his needs when told.. 93. This "disciplining" of Plaintiff in connection with her Montreal trip caused Plaintiff great fear that if she failed to engage in commercial sex on the terms and conditions set by Epstein, he or the Corporate Defendants would cause her serious hann. 94. Jeffrey Epstein told Plaintiff to move into an apartment in a building he owned or controlled at 301 East 66 Street, which Plaintiff did. 95. There it became obvious to her that she was under constant surveillance; that Jeffrey Epstein was able to monitor and know what she was doing 20 3501.484-002 Page 20 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095926 EFTA01250000  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 21 of 52 in the apartment at all times, and that he was able to know and monitor where she was going outside the apartment. 96. Plaintiff, between 2006 and 2012, was trafficked to Jeffrey Epstein's Island on Little Saint James on more than twenty occasions. On each occasion she was forced to engage in commercial sex. 97. On one occasion on the Island, Plaintiff posted a publicly readable social media post indicating that she was on the island. The next morning, Jeffrey Epstein woke her while holding her wrists tightly. He was in a state of great anger. His laptop computer was open. He began questioning her, stating, "Why did you make this post? Who has read it? What have you told them?" At the end of the angry conversation, Jeffrey Epstein threatened Plaintiff and commanded her never to tell anyone about the commercial sex acts in which he was making Plaintiff engage, and never to tell her mother of her activities with Jeffrey Epstein. As punishment for the post she had made, Jeffrey Epstein did not speak with Plaintiff for a month. 98. Jeffrey Epstein sent Plaintiff back to New York without paying her for any of the commercial sex acts she had engaged in with him on the island on a daily basis over the course of approximately one week. 99. Plaintiff, from that point forward in 2007, was in fear for her safety and her life and knew that strict compliance with the dictates of this very powerful man 21 3501.484-002 Page 21 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095927 EFTA01250001  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 22 of 52 was required as a condition of her maintaining her safety and her life. Epstein, in a show of his anger and power, kicked Plaintiff out of her living quarters, essentially rendering her homeless overnight. At the same time, Epstein informed Plaintiff that she was forbidden to tell anyone about him or the sexual activities he was engaging in with her. 100. In order to cause Plaintiff to continue to engage in commercial sexual activity, Jeffrey Epstein made it known that he was close friends with other powerful and influential people. 101. Jeffrey Epstein commonly bragged to Plaintiff that Bill Clinton, Donald Trump, Prince Andrew, and the Sultan of Dubai were among his closest friends. 102. Plaintiff overhead Jeffrey Epstein talking with the Sultan of Dubai and on one occasion met him in person, supporting Jeffrey Epstein's statements that he was closely associated with this and other powerful friends. 103. Plaintiff observed photographs of Jeffrey Epstein and Bill Clinton together and heard Jeffrey Epstein talk about times when Clinton was on his private island in Little Saint James. Plaintiff never saw Bill Clinton on the island. 104. As Plaintiff was trying to distance herself from Jeffrey Epstein, he called her into his massage room and warned her not to lie to him or there would be serious repercussions. He threatened her with these repercussions in order to cause her to continue to engage in commercial sex. Epstein worked with the people and 22 3501.484-002 Page 22 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095928 EFTA01250002  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 23 of 52 resources of his vast enterprise, including Corporate Defendants, to ensure that Plaintiff would comply. 105. On one occasion, Jeffrey Epstein forced Plaintiff to serve hors d'oeuvres at Epstein's private party with Woody Allen. This server's role was forced upon Plaintiff in order to demean her, frighten her, and impress upon her the need for her to conceal the commercial sex trafficking enterprise he was running. 106. Jeffrey Epstein constantly told Plaintiff that her opportunities were endless as long as she complied with his dictates but that he could take it all away from her if she did not. 107. There came a time when Jeffrey Epstein forced Plaintiff to give other powerful friends massages. During some of these massages she was sexually abused, by force, against her will, by the friends whom she had been required to massage. 108. Plaintiff, trying desperately to leave the proximity and influence of Jeffrey Epstein, failed to show up for multiple appointments at his mansion. Associate 1 contacted Plaintiff on behalf of Epstein and told her that Jeffrey Epstein was very upset with Plaintiff's behavior. This warning caused Plaintiff to experience extreme fear and anxiety for her safety and her life. This fear and anxiety ultimately had its intended effect and Plaintiff returned to Jefferey Epstein's mansion to continue to engage in commercial sex acts. 23 3501.484-002 Page 23 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095929 EFTA01250003  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 24 of 52 109. Jeffrey Epstein informed Plaintiff again that her career opportunities were endless as long as she complied with his demands. 110. Jeffrey Epstein instructed Plaintiff in 2011 that he was putting her through massage school and she had no choice but to attend. 111. While she was in massage school, Jeffrey Epstein constantly asked Plaintiff to recruit other young females from the massage school and became angry and threatening when she refused to do so. 112. Jeffrey Epstein forced Plaintiff to wear certain color panties, remove certain body piercings, and undergo surgery by Jeffrey Epstein's doctors to remove body moles. Plaintiff complied with these demands with the understanding, conveyed to her by Epstein, that she had no other choice. . 113. From 2006 through 2012, Jeffrey Epstein and his associates and employees recruited, enticed, harbored, transported, provided, obtained, maintained, and solicited Plaintiff knowing that force, threat of force, fraud or coercion would be used to compel Plaintiff to engage in commercial sex acts. 114. The commercial sex acts included intercourse, the use of sex toys inserted inside Plaintiff, digital penetration, forcible touching and many other sexual acts. 115. Plaintiff was made to engage in commercial sex acts in New York every year from 2006 to 2012 (except for a brief period of time in late 2008 through 2009 24 3501.484-002 Page 24 of 70 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00095930 EFTA01250004  Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 25 of 52 during which time Jeffrey Epstein was technically in jail in Florida); in the United States Virgin Islands from 2006 to 2012 (except, again, during a briefperiod of time during which Jeffrey Epstein was technically in jail in Florida); in Florida from 2007 to 2012 (including, as noted, sexual activity while Jeffrey Epstein wore his ankle bracelet); and in in New Mexico between 2007 and 2010. 116. There were sexual acts in addition to those described above which acts are too graphic and perverted to detail in the complaint. Each and all of such acts were required by Jeffrey Epstein and his Corporate Defendants, all of whom worked together to cause Plaintiff to engage in such acts, including Defendants' informing her that if she refused to engage in such acts she would suffer serious harm. 117. In order to maintain Plaintiff's compliance, Defendant Jeffrey Epstein also informed Plaintiff that he would use his vast resources to get Plaintiff's relative the serious medical care she needed, further enticing Plaintiff through fraud to engage in commercial sex acts. 118. Multiple associates, employees, and corporate entities assisted Defendants in causing Plaintiff to engage in commercial sex acts knowing fraud would be used to cause her to continue to engage in such acts. This assistance included making promises, schedu