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Case 1:19-cv-03377 Document1 Filed 04/16/19 Page 8 of 28 defamatory statements were made, and abuse occurred, within the Southern District of New York. 26. Venue is proper in this Court as (a) the cause of action arose within the jurisdiction of this Court and (b) Defendant resides within this District. PARTIES 27. Plaintiffis an individual who is a citizen of the State of Florida and a resident of Australia. 28. Defendant Dershowitz is an individual who resides in the Southern District of New York at 2 Tudor City Place Apt. IOEN, New York, New York 10017. 29. — Jeffrey Epstein is an individual who resides in the Southern District of New York at 9 East 71°' Street, New York, New York, 10021. FACTUAL ALLEGATIONS A. Epstein’s Sex Trafficking Enterprise 30. Plaintiff became a victim of sex trafficking and repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein when Plaintiff was under the age of eighteen. 31. Between 2000 and 2002, Epstein sexually abused Roberts at numerous locations including his mansions in West Palm Beach, Florida, New Mexico, the Virgin Islands, and this District. Epstein also flew Roberts on his plane nationally and internationally numerous times when she was under the age of 18. Only portions of the flight logs of Epstein’s private planes are yet known, and Epstein also flew Roberts frequently on commercial airlines to meet him and others. However, the chart below which shows Roberts’ flights on Epstein’s private plane from the limited logs that are available illustrates the international scope of Epstein’s sex trafficking. HOUSE_OVERSIGHT_017942