EFTA00313649.pdf
Case 1:17•cv00616 Document 1 Filed 01/26/17 Page 10 of 21
response to questions they might be asked by investigators and prosecutors;
requiring them to invoke the Fifth Amendment in order to refuse to turn over
incriminating and non-incriminating evidence to law enforcement officers;
requiring them to destroy evidence or refuse to reveal knowledge of destroyed
evidence; and requiring them generally to refuse all cooperation with law
enforcement officials or investigations.
32. In 2005, Defendant Epstein and other co-conspirators, aware that law
enforcement officials were preparing imminently to execute a search warrant of his
home, removed computer systems that logged information about Epstein and his
co-conspirators' illegal and criminal conduct; the identities of witnesses; nude
photographs of young females; scheduling books; message pads; tangible items
such as vibrators and toys; and other incriminating matter.
33. Commencing in approximately October 2006 and continuing through
April 2007, Defendants recruited Plaintiff into their sexual enterprise by
fraudulently promising to use their connections and resources to secure her
admission to an institution of higher education at the expense of Defendant
Epstein.
34. Defendant was working as one of the enterprise's recruiters
of young females when she approached and recruited Plaintiff.
It)
EFTA00313649
response to questions they might be asked by investigators and prosecutors;
requiring them to invoke the Fifth Amendment in order to refuse to turn over
incriminating and non-incriminating evidence to law enforcement officers;
requiring them to destroy evidence or refuse to reveal knowledge of destroyed
evidence; and requiring them generally to refuse all cooperation with law
enforcement officials or investigations.
32. In 2005, Defendant Epstein and other co-conspirators, aware that law
enforcement officials were preparing imminently to execute a search warrant of his
home, removed computer systems that logged information about Epstein and his
co-conspirators' illegal and criminal conduct; the identities of witnesses; nude
photographs of young females; scheduling books; message pads; tangible items
such as vibrators and toys; and other incriminating matter.
33. Commencing in approximately October 2006 and continuing through
April 2007, Defendants recruited Plaintiff into their sexual enterprise by
fraudulently promising to use their connections and resources to secure her
admission to an institution of higher education at the expense of Defendant
Epstein.
34. Defendant was working as one of the enterprise's recruiters
of young females when she approached and recruited Plaintiff.
It)
EFTA00313649