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TERSON to settle out of court with his a woman who went by the alias 1-dollar lawsuit against Epstein. te claimed, Epstein was fifty-two and her complaint, which was world an early glimpse of what of his secret world, looked like loney manager with a secret cli- llionaires,” the lawsuit alleged. adous wealth, power and influ- al home in New York and also o, St. Thomas and Palm Beach, “mn Epstein’s conduct while at his e complaint continued: Epstein has a sexual preference inor girls. He engaged ina plan d access to primarily economt- girls in his home, sexually n gave them money. In or about ipproximately 16 years old, fell ie one of his victims. slief, Jeffrey Epstein carried out rs in Florida, New York, and on Little St. James, in St. Thomas. 1 the use of young girls to recruit : 192 Firtuy Ricw underage girls. (Upon information and belief, the young girl who brought Jane Doe to Epstein was herself a minor victim of Epstein, and will therefore not be named in this Com- plaint.) Under Epstein’s plan, underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. The recruiter would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or someone on his behalf would direct the recruiter to bring one or more underage girls to the residence. The recruiter, upon information and belief, generally sought out economically disadvantaged underaged girls from western Palm Beach County who would be enticed by the money being offered—generally $200 to $300 per “massage” session —and who were perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made. This was an important element of Epstein’s plan. Epstein’s plan reflected a particular pattern and method. Upon arrival at Epstein’s mansion, the underaged victim would be introduced to Sarah Kellen, Epstein’s assistant, who gathered the girl’s personal information, including her name and telephone number. Ms. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. There were photo- graphs of nude women lining the stairway hall and in the bedroom. The girl would then find herself alone in the room with Epstein, who would be wearing only a towel. He would then remove his towel and lie naked on the massage table, and direct the girl to remove her clothes. Epstein would then 193 HOUSE_OVERSIGHT_010534