EFTA00296277.pdf

Document comparison by Workshare Compare on Monday. June 05. 2017 6:18:32 PM Input: Document 1 ID file://CAUsers\pparkerlDesktop101 Complaint.pdf Description 01 Complaint Document 2 ID file://CAUsers1pparkerlDesktoplFirst Amended Complaint.pdf Description First Amended Complaint Rendering set Steptoe - Standard Legend: Insertion Deletion- Moved to to Style change Format change Meved-deletion- Inserted cell Deleted cell Moved cell Split/Merged cell Padding cell Statistics: Count Insertions 333 Deletions 225 Moved from 0 Moved to 0 Style change 0 Format changed 16 Total changes 574 EFTA00296277 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page I of 31 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK COMPLAINT CASE NO.: 1:17-CV-00616 JANE DOE 43, U T 14 I A V WIC 3.- X ttel V Plaintiff xf, EFFREY EP TEIN HI LAINE MAXWELL AND Defendants. FIRST AMENDED COMPLAINT Plaintiff JANE DOE 43, by and through her undersigned counsel, for her EFTA00296278 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 2 of 31 claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, and alleges upon personal knowledge with respect to her own acts and status, and upon personal knowledge, 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. *section 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 andthe disclosure of name-publielsfrwillwhich, in association with her name, would cause further harm to her. 3. At all times material to the events alleged in this cause of action the Plaintiff was a citizen of South Africa residing in New York, New York. 4. At all times material to this cause of action Defendant Jeffrey Epstein had multiple residences, including in New York, New York (within the Southern District of New York) and the United States Virgin Islands. He is currently a citizen of the United States and claims to be a resident ofNew--Y-Ork—ancl the U.S. Virgin Islands. 5. At all times material to this cause of action Defendant Jeffrey Epstein was an adult male born in 1953. EFTA00296279 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 3 of 31 6. At all times material to this cause of action Defendant Ghislaine Maxwell was residing in in New York, New York and was a citizen of Great Britain and France. 7. At all times material to this cause of action was a United States citizen, residing in New York, New York, and, of eiti-zea-ef-the-14nite€1-States (within the Southern District of New York). 8. At all times material to this cause of action was residinga United States citizen, employed by New York based company and regularly conducting business in New York, New York and, on information and belief, was a citizen of the United States(within the Southern District of New York). 9.At all material times, n-was-resitling-in-New--Y-eFk r New YOFIreandr en-infennatien-and-beliefrwas-a-eitizell-ef-the-binited-States, 9. -1414neluding-bec-ausea 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 that District. 28 U.S.C. *section 1391(b)(2) 2 10. -1-lat all times material to this cause of action, Defendants Jeffrey Epstein, Ghislaine Maxwell, an —ann owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire to commit intentional, criminal, fraudulent, or tortious illegal acts against her, including any acts in violation of 18 U.S.C. §1595. FACTUAL ALLEGATIONS EFTA00296280 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 4 of 31 11. 4-2,At all times material to this cause of action, Defendant Jeffrey Epstein was an adult male over 50 years old. Defendant Epstein is knownwidely recognized as a billionaire who uses his extraordinary wealth to commit illegal sexual crimes in violation of federal and state statutes and to employ and conspire with a group of numerous others, including each of the named Defendants, to eenspir-e-and-assist in committing those crimes and additional torts as well as to preteet-and-conceal his crimes and torts of the Epstein sex trafficking group from being discovered. 12 44-Defendant Epstein displays his enormous wealth, power 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. For example, he owned and-ewns(directly or indirectly) a Boeing aircraft (of make and model B-727-31H with tail number N908JE) and a Gulfstream aircraft 3 of make and model G-1159B with tail number N909JE He also owned numerous properties and homes, including a 51,000-square-foot mansion in Manhattan; a $30 Million, 7,500-acre ranch in New Mexico; a 70-acre private island formerly known as Little St. James in or near St. Thomas, U.S. Virgin Islandsa EFTA00296281 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 5 of 31 mansion in London, England; a home ; 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 Virgin Islands. Epstein used all of the real and personal property described in this paragraph to facilitate the illegal sex trafficking venture and enterprise described in this Complaint and in furtherance of that venture and enterprise, a 4-4:Defendant Epstein has a compulsive sexual preference for young females as young as 13 and as told!: as 25. Through information and belief Defendant hed-see-with-yeung-fenieieeaaiFtueilygastein engages iusxual actsa range every day and accicted in the development and execution ofdeveloped, through the employment of and conspiracy with the other Defendants, a sex trafficking schemeventure and enterprise designed to fulfill his sexual desires: and conceal the operation of the venture and enterprise and conduct of its participants. As part of the venture and enterprise, Epstein also provided young females for sexual purposes to his friends in order to secure social, business, and other contacts as well as other things of value. 14. 44:Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking venture and enterprise. She herself recruited young, including underage, females; oversaw and trained other recruiters on how best to recruit girls for sex; developed and executed schemes designed to recruit young females; and ensured that all participants of the Defendants' sex trafficking scheme EFTA00296282 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 6 of 31 acted in certain specific ways in order to advance the purposes of the scheme and eeneeal-4, including providing young females to Epstein for sexual purposes on a daily basis, and concealing these activities from law enforcement. 4-67Defendant recruited young females for Epstein for sexual purposes, brought gifts to females in order to entice those females to commit sex acts with Epstein and to assist in concealing the illegal sexual conduct of the venture and enterprise, and maintained sex schedule in order to ensure that he was not without the sexual favors of young females for any extended period of time. Defendant also handled travel arrangements for the-various females being exploited for sexual purposes. 4 Defendant n intend art f the sex traffi kin venture and enterprise and reported directly up the line of authority to DefendeetDefendants Maxwell and Epstein. -1-7,Defendant Epstein employed many recruiters of young females. The nature of the Defendants' sex trafficking schemeventure and enter ris enabled victims themselvesTsueh-as-Defendent to elevate their status to that of a paid recruiter of other victims. S Recruiters were taught by Defendants Epstein-and, Maxwell andM to inform targeted victims that Epstein possessed extraordinary wealth, power, resources and influence; that he was a philanthropist who would help female victims advance their EFTA00296283 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 7 of 31 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, however, these representations were fraudulent. The vast majority of girlsyoung females were actually required to perform intimate sexual acts at the Defendants' direction and the Defendants did not help efnor intend to help advance the victims' careers. Victims id t brin F stem other females for sex and were told by Defendants Epstein, Maxwell, and that those young females who brought other females would further benefit from bringing other girls, 17. -1-8,Defendant In was an integral part of the illegal venture and enterprise. =coordinated schedules between Defendant Epstein and the various young females used for sex; made travel arrangements for the girlsyoung females; tended to thcirthe living needsafid-eemmunieateci-with-fliemeerder-te-mainta - their of those females; communicated and coordinated with Defendants Epstein, Maxwell and to assist in facilitating young females being available in locations where the other Defendants were traveling; and she carried messages to the young females from the other Defendants including false representations in order to maintain the young females' compliance with the rules of beluwimsexual compliance imposed upon-them-by this structured sex-trafficking group. was aware of 6 EFTA00296284 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page $ of 31 the entewiseactivities of the venture and enterprise, including the fraudulent representations and other coercion that was being applied to secure the females' compliance with demands of sex. -IA The Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled Epstein!) compulsive need for sex with young females by preying on their personal, psychological, financial, and related vulnerabilities. The Defendants' tactics included promising the victims money, shelter, transportation, gifts., employment, admission into educational institutions, educational tuition, protection, and other things of value in exchange for sex. Defendants also took possession of the victims' passports to coerce compliance with their demands. Defendants also trafficked young females to Epstein's friends and acquaintances in order to secure financial and other benefits as well as social, educational, and business connections, 19. 2.0:Defendants' sex trafficking venture and enterprise operated in a hierarchal structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top-anil underlings-belew,Defendants Epstein and Maxwell operated the sex trafficking scheme dating back to at least the mid-nineties, and over the years perfected their roles and the roles of oth volume of young females recruited for sex and in insulating the enterprise from criminalLiniesligationorprosetation.Defendantas ith Defendant Epstein and Maxwell 7 since at least 2002 and continues to work for Defendant Epstein today. Defendant legatusarkingwiththelasteinrrasextraffickintyenture and enterprise as early as 2001 and her role in their venture and enterprise was EFTA00296285 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 9 of 31 well-defined and primarily consisted of conspiring in the commission an cover-up of sex crimes. Underlings included the other named Defendants as well as unnamed co- conspirators such as various housekeepers and butlers; an airplane pilot; and various employees, assistants and associates. Wittingly and unwittingly, such underlings performed their respective roles with the purpose and effect of insuring that the enterprise supplied young females to Defendant Epstein and others for sexual purposes. At all times materials to this complaint, the venture and enterprise was a group of two or more individuals associated in fact and deed. 20. 2-hDefendants Epstein and Maxwell, with help from assistants, associates and underlings, recruited and procured hundreds of girls over the decades of the operation of their scheme. Such recruitment and procurement included fraud, coercion, threats, intimidation, fear, the threat of coercion, and a combination of these and similar tactics. Following the Defendants' recruitment and procurement of the young females to join Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent 6 promises, coercion, and threats of coercion in order to entice yettegand coerce the females into sex and, once sexual activities ensued, to cause them to remain in the enterprise. The Defendants also transported females in A interstate and foreign commerce and in ways that affected interstate and foreign commerce. The sex acts were commercial in nature, because the Defendants promised to provide financial and other compensation to the females in EFTA00296286 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 10 of 31 exchange for providing sex acts to Epstein. 21Defendants specifically targeted underprivileged, emotionally vulnerable and/or economically disadvantaged young females to join the Defendants' entecpciseprovide sex for Epstein. 23.Additionally, Defendants always made clear to every you that they were wealthy, well-connected and could either help or hurt the females depending on their degree of cooperation. In fact, Defendants Epstein and Maxwell have been known to threaten young females with physical harm, It is unknown exactly how long Defendant Epstein and Maxwell's afecenwatienetithe Defendants' criminal and illegal venture and enterprise operated, 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 venture and enterprise and eeftspireey-up to the present time in some form or another and with additional co-conspirators and narticinant, . 24. 2-5,In 2005, Defendant Epstein and numerous co-conspirators within the venture and 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 school children. Each child identified in that particular investigation was lured into Defendant Epstein's Palm 2 EFTA00296287 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 10 of 31 Beach mansion with a promise that she would receive money for providing him with a body massage, although once there, each el young female was made to engage in a sex actsexual acts in order to receive the promised compensation. Several were also made to engage in sex with another of Defendant Epstein's female sexual-tfaveling-eempathenstraveling sex companions who Epstein referred to as his lesbian sex slave and bragged about purchasin her from her family when she herself was underage. 15, 2.-.67In 2006, the Palm Beach Police Department investigation was turned over to the FBI and the United States Attorney's Office for the Southern District of Florida. The United States Attorney's Office investigated Defendant Epstein and his co-conspirators for their violations of numerous federal statutes, including 18 U.S.C. *Section 1591, one of the statutory bases for this complaint. 26. 2-7-.The United States Attorneys investigation continued from 2006 through September 2007, at which time a Non-Prosecution Agreement was signed between Jeffrey Epstein and the United States Attorney's Office deferring federal prosecution of Defendant Epstein and his numerous co-conspirators, including Defendants and named by the Federal Government as co- conspirators, for identified federal sex crimes against more than 30 minors. 27. 28.From late 2006 through September 2007, Epstein's team of lawyers negotiated with the federal government in an effort to avoid the-filing-ef-thea fifty- three-page dra€tFederal felony indictment effrom being filed against Epstein. During these 14 EFTA00296288 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 11 of 31 negotiations, Defendant Epstein decamped from Palm Beach to New York and the U.S. Virgin Islands in order to convey an image to prosecutors that he and his co- conspirators had stopped committing sex crimes. 28. 24Remarkably, however—as this case will highlight—Defendant Epstein and his co-Defendants, including the other defendants named herein, did 8 not abandon their sex trafficking yenture and enterprise even while they were under state and federal investigation for crimes committed in violation of 18 U.S.C. *section 1591, among other laws, and even as Defendants and their attorneys were busy arguing Epstein!) innocence and publicly defaming his victims as liars. Rather, Defendants merely changed their stylciocation. Instead of targeting local Palm Beach Florida high-school girls, the Defendants transported young females from other places in the U.S. (including the Southern District of New York) and abroad and brought them to Defendant Epsteinl's mansion in New York City and his private island in the Virgin Islands. 29. 40,In June of 2008, Epstein pleaded guilty to Florida state felony sex offenses for procuring a minor for prostitution and soliciting prostitution by minors and reaistered as a Sex Offender for Life. 30. 3-1-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. 11 Defendants and adapted to the system and also carried it out for years in exchange for significant pay, benefits, and protection from EFTA00296289 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 12 of 31 prosecution. The system included requiring subordinates to sign confidentiality agreements evering-eivil-andbarring disclosure of criminal activity; maintaining records of underage females who were abused by Epstein; requiring subordinates and victims to refrain from speaking with law enforcement officials; requiring them to notify Defendant Epstein's lawyers in the event they (subordinates and victims) were contacted by law enforcement officials; requiring them to accept the representation of attorneys paid for by Defendant Epstein; requiring them to invoke the Fifth Amendment in 4 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. IL 32In 2005, Defendant Epstein and other co-conspirators, aware that law enforcement officials were preparing imminently to execute a search warrant effor his home, removed computer systems that logged information about Epstein and his co-conspirators' illegal and criminal conduct; the identities of witnesses; nude 12 photographs of young females; scheduling books; message pads; tangible items such as vibrators and toys; and other incriminating matter. 32. The sex recruiting and trafficking venture and enterprise designed to procure young females for sexual purposes and to conceal those activities was developed and fine-tuned over time, and each of the named Defendants had a well-defined role and improved in his/her role over time, with practice and EFTA00296290 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 13 of 31 experience. By the time Plaintiff was recruited into victimization, each Defendant had years of experience perfecting methods of coercion, understanding Epstein's requirements, and becoming more loyal to the continuance and survival of the venture and enterprise. All of the knew about the activities of the venture and enterprise and worked in concert for the goals of the venture and knowingly benefitted, financially and by receiving things of value, from their I articii ation in the venture and enterprise. E. A typical way the Defendants procured young females for sex with Defendant Epstein was to make false promises of a modeling opportunity, offer a better life, offer payment for a formal education, or offer other money or consideration. 34, ff eenfirnerkeingjlegim_g lin in approximately October 2006 and continuing through April 2007, Defendants recruited Plaintiff into their sexual enterprise by fraudulently U 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 W113 working as One of the enterprise's snafu recruiters-efaatilurkinglascruit young females_for Epstein for sex when she approached and recruited Plaintiff. EFTA00296291 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 14 of 31 44 4-5-,Defendana 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 Plaintiff achieve their personal and professional goals and aspirations. 37. 36.Defendant reported to her superiors, Defendants M, and Maxwell, and was paid for her recruitment of young females, including-the feeruitment-ef Plaintiff. 37.Defendant introduced Plaintiff to Defendant Epstein, who confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into The Fashion Institute of Technology; (known as "F.I.T."31 in New York City; or into a similar institute of higher learning offering a curriculum of fashion industry training. Between October 2006 and May 2007, Defendants Maxwell, and IM each also confirmed and reiterated this promise to Plaintiff many times t each telling Plaintiff that Epstein would use his wealth and connections to advance Plaintiff's education. More specifically, each of the Defendants last verified this information that Epstein was using his connections to ensure Plaintiff was admitted 14 into F.I.T. in exchange for Plaintiff's continued sexual cooperation with Epstein in March or April of 2007. 39. 38.Defendant Maxwell told Plaintiff she would need to provide Defendant EFTA00296292 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 15 of 31 Epstein with body massages in order to reap the benefits of his and' connections. 40. All Defendants, including Maxwell, Epstein, and M, knew that Plaintiff was actually being recruited for sexual purposes, and each knowingly and deliberately made false representations to ensure that Plaintiff would cooperate in fulfilling Epstein's sexual desires. These false and fraudulent representations included Defendants' telling Plaintiff that Epstein would use his connections to have her admitted into F.I.T. or a similar institute, college, universi y or school of higher learning and provide her with employment opportunities. Plaintiff reasonably relied on these representations and had a credible basis for such reliance, including the credible representations of Epstein and the other Defendants that they possessed extensive political, business, financial, social, and educational influence and connections. Epstein and the other Defendants represented to Plaintiff in manners that were persuasive, credible, and reasonable to Plaintiff, as they would have been to any other person similarly situated, that they had the political, business, financial, social, educational, and other influence and 15 connections sufficient to arrange for and insure her admission into F.I.T. or a similar school of higher learning. 41, Maxwell and Epstein also threatened Plaintiff that, while they had the ability EFTA00296293 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 16 of 31 to advance her education and career, they also had the ability to make sure that shePlaintiff would not obtain ne-formal education or modeling agency contracts if she failed to provide the sexual favors desired by Defendant Epstein or abide by the instructions given her by Defendants Epstein and Maxwell. 44 42 3-9,Plaintiff reasonably believed that her compliance with Defendants' demands was crucial to her physical, psychological, financial, and reputational weiatingan_d_survival. 43. 4&Defendant Maxwell instructed Plaintiff how to massage Epstein using the techniques that heMaxwell knew that Epstein preferred. During Plaintiff's first massage, Defendant Epstein converted it into a sexual act and made it known to Plaintiff that further sex would be required in order for her to obtain the assistance he promised her and to avoid Defendants' threatened retaliation against her if Plaintiff did not perform as demanded. j4, 4-I,Defendants—Maxwell and Epstein informed Plaintiff that other young females in Defendant-Epstein's company were there net-enly-te-previde-massages3 but-also to perform sexual acts, for Epstein and his friendsnd !piped to secure the presence of the other young females for these purposes, 11 427Plaintiff was instructed dozens of times to provide body massages to Defendant Epstein, both at his townhouse in New York and on his private island in the U.S. Virgin Islands. Each time she was so instructed she was also required to EFTA00296294 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 17 of 31 perform a sexual act with-Defendant Epstein. The Defendants all participated in arranging for Plaintiff to be transported Plaintiff in interstate and foreign commerce, and affecting interstate and foreign commerce, for these sexual purposes. The Defendants Epstein, Maxwell, andased possession and control of Plaintiff's passport to induce and coerce Plaintiff into nerforminiz sexual acts with Epstein and others. 46. 43:During many sexual encounters, Defendant Epstein gave Plaintiff no option, opportunity, or choice not to participate in the prescribed sexual acts. 4-2 47. 44,Defendant Maxwell frequently controlled the assignment, or "rotation," of Plaintiff and the other young females concerning the time, place and manner of the sex acts they were told to provide to Defendant Epstein. Defendant Maxwell also gave instructions on how to perform certain sexual techniques on Epstein. Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with other females. 4-SDefendants Epstein and Maxwell intimidated, threatened, humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance. These Defendants threatened Plaintiff with serious harm, as well as serious psychological, financial, and reputational harm, with4hesufpese-and-OffeGt-eg EFTA00296295 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 1$ of 31 compelling Plaintiff to perform and continue performing the demanded-commercial sexual activity demanded by Defendants. 49_, 46,On one occasion, after suffering verbal abuse and threats by Defendants Epstein, Maxwell, and M, Plaintiff attempted to escape from Defendant Epstein's private island. A search party led by DcfcndantDefendants Epstein and Maxwell 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 cause, 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, employability, and stable state of mind. Defendants further used possession and control of Plaintiff's passport, without lawful consent or authority, to restrict Plaintifralikertismiiherthilorethenforayidtienniaskins 50. 4-7,Defendant Epstein's wealth, influence, power and connections were used by Defendants Maxwell, and both as an inducement to provide sex (in exchange for promises of support to Plaintiff}, and as a means of threatening punishment (sheuldin the event Plaintiff fecuserefused to comply with Defendants' instructions to provide sex to Epstein and others). a 48,In addition to Plaintiff's being trafficked on Defendant-Epstein!:s private planeairplane, Defendants =, Maxwell and with the knowledge of and instruction by Defendant Epstein, arranged Plaintiffs living accommodations, private car travel, EFTA00296296 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 19 of 31 18 and commercial air travel on numerous occasions for the purpose of causing Plaintiff to commit commercial sex acts. These Defendants worked in concert with one another to recruit, procure, entice, and otherwise cause many other females to engage in commercial sex acts, through their use of threats, fraud, and coercion. Among these means of coercion were the Defendant's possession and control of the females' passports and other immigration documents. This coercion was most salient, and especially effective, while the females, including Plaintiff, were on Epstein's island. 52. 4-9,1n furtherance of their venture and enterprise, Defendants provided living quarters for Plaintiff at 301 East 66th Street, New York, in the Southern District of 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. Each of the Defendants told Plaintiff she would obtain the benefits of a place to live and phone and transportation as long as she remained compliant with their demands that she service Epstein sexually. Each of the Defendants also told her that if she was not compliant, these benefits would be taken from Plaintiff. 53. 544,The relationship between Plaintiff and Defendants Epstein and Maxwell was defined and characterized by Defendant Epstein's and Defendant Maxwell's frequent and persistent fraudulent representations that they would provide Plaintiff with a formal education and career advancement if she provided sex to Defendant 12 EFTA00296297 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 20 of 31 Epstein and others in the times, places and manners demanded by Defendants. Defendants and each also told Plaintiff that Defendant Epstein would advance Plaintiffs education and career in order to coerce Plaintiff into sex. Defendant told Plaintiff that Epstein had done the same for her career. As a result of these and other representations by Defendants, Plaintiff reasonably relied on thestn representations. In fact, however, thosethese representations were knowingly false, were not acted upon by Defendants, and were made by Defendants Epstein a and Maxwell solely for the purpose of maintaining 44 Plaintiffs financial dependence on, emotional vulnerability to, and sexual compliance with DefendantsDefendant Epstein4144-Ma*well-and-their:a demands. The other Defendants intentionally repeated thesethese representations and intentionally attetpteilmade statements designed to convince Plaintiff that the representations were true and could be relied upon. These representations and statements were made to Plaintiff in furtherance of the sex trafficking venture and enterprise for which they were each employed. 54. As part of the venture and enterprise, Defendants Epstein, Maxwell, and took possession of Plaintiffs passport when she was being trafficked by them, including when she travelled to E stein's island in the U.S. Virgin Islands. 'The Defendants took possession of Plaintiffs passport in the course of sexually trafficking Plaintiff and with the intent to violate laws against sex trafficking, including 18 U.S.C. 1591 et. seq. The Defendants used their control of Plaintiffs 20 EFTA00296298 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 21 of 31 passport in order to coerce compliance with their demands, including their demands that Plaintiff have sex with Epstein and others. $4-In January 2007 as part of their illegal venture and enterprise, Defendants sent Plaintiff from the-Uctited4takasNew York City, in the Southern District of New York, to South Africa-in-pact to recruit, for a promised fee, one or more aspiring female models supposedly for Defendant-Erstein-te-use-as-an-alleged per-sefial-assistant,Epstein to use as a personal assistant. The Defendants did not care whether the prospective female was qualified to work as a personal assistant because each knew that the female recruit would be immediately placed into the same sexually vulnerable position as Plaintiff (and the dozens of other victims of the sex trafficking enterprise) and would be induced and coerced into being used for sex through fraudulent representations and other means. 56. Defendants Epstein and Maxwell continuously and frequently demanded that Plaintiff fulfill this task of bringing another female back to the United States and Defendants' control as a condition of herPlaintiff's receiving the education, career and related benefits promised by Defendants Epstein and Maxwell. Based upon Plaintiff's experience with Defendants, however, she did-net-believeknew that the requested female model would not be placed in a legitimate position of employment with Defendant Epstein but would, instead, be forced into sexual servitude. Plaintiff also knew that this objective was the only purpose of Defendants n EFTA00296299 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 22 of 31 Maxwell and Epstein's demand for rAjilies recruitment efforts. As a result, Plaintiff deliberately refused to perform the recruitment assignment. 57. 5-2,As part of their ongoing scheme, Defendants inflicted serious emotional and psychological harm on Plaintiff as a means of coercing her to continue engaging in commercial sex acts with Epstein and others. While Plaintiff was in South Africa, Defendants Epstein and Maxwell informed Plaintiff that she would not be permitted to return to the United States to receive her promised education unless she underwent a diet and lowered her body weight from 57 kilograms 4-5 (approximately 125 pounds) to 52 kilograms (approximately 114 pounds). Epstein and Maxwell promised Plaintiff that if she complied, she would receive her promised education. Defendant monitored Plaintiffs progress in losing weight and continued to communicate with Plaintiff about Plaintiff's application to be admitted into F.I.T. as part of the Defendants' ruse to coerce Plaintiff to return to the United States for sex. Defendant = was aware of the coercion Epstein and Maxwell were applying to Plaintiff and acted to help further that coercion. Believing she had no practical choice in the matter, Plaintiff attempted to comply with the order but, given her physical height and body structure and her already existing-lew body weight, the diet imposed upon her placed her in serious physical jeopardy, including kidney malfunction and extreme emotional and psychological distress. ha a 53.As part of their scheme,,Defendants Epstein and Maxwell called Plaintiff-'s parents in South Africa to tell them that DefendentsDefendant Epstein would take good care of Plaintiff when she returned to the United State; and that theyDefendants Maxwell and Epstein would use their connections and influence EFTA00296300 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 23 of 31 to have her admitted to F.I.T. or another well-regarded fashion school or school of higher learning, 59. As part of their scheme, Epstein and told Plaintiff that she should fill out an application for admission to F.I.T., and supporting essay_ and send it to Epstein for his review. Pursuant to these instructions, Plaintiff completed an armlication, and supporting essay, and sent it to Epstein. As part of his scheme, Epstein told Plaintiff that he had reviewed these materials. His statements were intended to convince Plaintiff and had the effect of convincing plaintiff (as they have convinced nri )vomAl maimul ys i that her admission F.I.T. was 41. I" if she s ul c nt t with i ns. also made the same representations to plaintiff on Epstein's behalf. Plaintiff reasonably relied on these representations by Epstein and =, 60. As part of their scheme, Epstein and Maxwell told Plaintiff that they had contacts at F.LT. and at modeling agencies who could ensure her admission to F.I.T. and advance Plaintiff's career. As part of their scheme, Epstein and Maxwell told Plaintiff about Epstein's vast wealth and specifically identified him as a billionaire. Epstein and Maxwell told Plaintiff that they had extensive 23 contacts, in addition to those identified above, throughout New York City and elsewhere. 61. 54,In February of 2007, in reliance on promises made by the Defendant; Plaintiff returned to New York City, in the Southern District of New York, and EFTA00296301 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 24 of 31 was promptly ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants Maxwell. and Epstein each fraudulently promised herPlaintiff again that her sexual compliance would be rewarded with admission to F.I.T. or a comparable college, a promise which they letew-te-be-faiseeach knew to be false. In fact all four Defendants had for years worked solely to recruit females for sex and to conceal the operation of the sex scheme, and in 2007 were under Federal investigation for their conspiracy to engage in Federal sexual crimes like those committed against Plaintiff. Plaintiff knew that if she did not comply, Defendants Maxwell and Epstein would use their power, influence and connections in order to ensure that Plaintiff was unable to gain admission to F.I.T. or a comparable school, and that they would destroy her career, just as they had destroyed the careers of others who had failed to comply with their demands. 12a 5-SDefendants Epstein and Maxwell continued to provide Plaintiff with things of value in exchange for Plaintiff-:s continued compliance with Epsteie 4-6 sexual demands; however, they failed and refused to perform their promises to help Plaintiff be admitted to F.I.T. or another school, or to provide financial support for 24 college admission or on-going education, false promises they repeatedly made in order to coerce her into commercial sex acts. 13.. 5&Defendants Epstein and Maxwell':,_' sexual demands on Plaintiff continued while she was in New York or other gcographicCity, in the Southern District of New York, or in other locations in close proximity to the Defendants. EFTA00296302 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 25 of 31 In addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, each of the Defendants continued to pressure her to lose excessive amounts of body weight and offered her no opportunity to decline or resist their instructions. 5-77In May, 2007, Plaintiff left the United States and did not return. Between returtaSouth Africa Min in May 2007. Defendants M,a, and Maxwell each continued to repeatedly make false representations to Plaintiff, including false and fraudulent representations that she would be admitted to F.I.T. if she continued to engage in sex with Epstein. Defendant Epstein continued to make similar false and fraudulent promises in order to have sex with Plaintiff. 65. In and after May 2007, Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females. Defendant's cover- up included efforts to intimidate witnesses who might provide corroborating testimony to Plaintiff as well as destruction of documents and other evidence regarding what they had done. 25 66. 5-8,Unknown to Plaintiff, Defendants' representations and promises to Plaintiff were all false and fraudulent. Their—threats-,were-considered-byPlaintiff reasonably relied on the representations and promises of the Defendants. Plaintiff also considered the Defendants' threats against the current and future well-being and safety of Plaintiff to be real and credible. All such representations, promisesa and threats were made solely for the purpose of coercing and otherwise EFTA00296303 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 26 of 31 inducing Plaintiff into prolonged sexual compliance. Defendants knowingly benefitted financially and received things of value as a result of their-coercing and inducing Plaintiff into sexual compliance and otherwise participating in their illegal venture and enterprise. COUNT I CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 18 U.S.C. § 1595 76 . 49,Plaintiff adopts and realleges paragraphs 1 through 5-86.§ above. 4-7 68, 60,Defendants individually and together, within the special maritime and territorial jurisdiction of the United States, in interstate and foreign commerce, and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, maintained, patronized, solicited, threatened, forced, and coerced Plaintiff to engage in commercial sex acts. Such actions by Defendants were undertaken with knowledge and/or reckless disregard of the fact that their threats of force, fraud, coercion, and combinations of such means would 21 be used, and were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In so doing, Defendants violated 18 U.S.C. §§1591 through 1594 andW91, A' 'onallv. Defendants Enstein. Maxwell. and ainatithalLyand EFTA00296304 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 27 of 31 together, knowingly concealed, removed, confiscated, and possessed Plaintiff's passport and associated immieratioulocuments, in the course of violating 18 U.S.C. § 1591, and with the intent of violating 18 U.S.C. § 1591, and to prevent, restrict, attempt to restrict, without lawful authority, Plaintiff's liberty to move or travel, in order to maintain the sexual services of Plaintiff, while Plaintiff was a victim of a severe form of sex trafficking, as defined in section 103 of the Trafficking Victims Pi ted 0, cgd 2 I /0 se lat in 22 U.S.C.. 1 2. In doing, Defendants violated 18 U.S.C. § 1592. These Defendants also obstructed, and attempted to obstruct and to interfere with the enforcement of 18 U.S.C. 1592. 70. Additionally, Defendants knowingly benefitted, financially and by receiving things of value, from participating in a venture (the Epstein sex trafficking venture enterprise) which had engaged in acts in violation of 18 U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in such violations. In so doing, Defendants violated 18 U.S.C. § 1593A. 71. Additionally, Defendants attempted to violate 18 U.S.C. § 1591. In so dokg, 1 Defendants violated 18 U.S.C. § 1594(a). 27 72. Additionally, Defendants conspired with each other, and with other persons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants violated 18 U.S.C. § 1594(b), 73. Additionally, Defendants conspired with each other, and with other EFTA00296305 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 2N of 31 persons known and unknown, to violate 18 U.S.C. § 1591. In so doing, Defendants violated 18 U.S.C. 8 1594(c). 74. By virtue of their violations of 18 U.S.C. §§ 1591, 1592, 1593A, and 1594, Defendants are subject to civil causes of action under 18 U.S.C. § -1-59576-1,Defendatits-additionetly-prefited-from-the-sex-tr-efftelEing-ef-Plein ebstrueted4nvestigatiens-ef-the-vielatiensauerapted-and-eenspiced-te-vielate,and suseeeded-in-vielatiugr i-8-1447C-4*-1-541-threugh-1445,by-the-Gemmissien-ecthe tofts-and-efimes-deser-ibed-iii-this-sernplaiiii1595 by Plaintiff, who is a victim of their violations. 75. 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 B-727- 31H with tail number N908JE) and a Gulfstream aircraft (of make and model G- 1159B with tail number N909JE). Such aircraft, along with other of Defendants' 4S property, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. 76. (Additionally, Defendant Epstein's New York mansion, located at 9 East 71st Street, New York, New York, in the Southern District of New York, and his private island located in the United States Virgin Islands, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to EFTA00296306 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 29 of 31 forfeiture. 77. 4zhAs a direct and proximate result of Defendants' commission of the aforementioned criminal offenses enumerated in Title 18 U.S.C. § 1591 ct. scq.1591, 1592. 1593A. and 1594, and the associated civil remedies provided in § 1595, Plaintiff has in the past suffered and will continue to suffer injury and pain; emotional distress; psychological and pcychi atricpsychiatric trauma; mental anguish; humiliation; confusion; embarrassment; loss of self- esteem; loss of dignity; loss of enjoyment of life; invasion of privacy; and other damages associated with Defendants' actions. Plaintiff will incur further medical and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to these losses, Plaintiff has incurred attorneys' fees and will be required do so in the future. WHEREFORE, Plaintiff demands judgment against Defendants for compensatory and general damages, attorneys fees, punitive damages and such other and further relief as this Court deems just and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury. Dated: kinitacy46r 20-1-7June 5, 2017. Respectfully Submitted, rimlali5a. EFTA00296307 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 29 EFTA00296308 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 By: /s/ Bradley J. Edwards Bradley J. Edwards BOLES, SCHILLER & FLEXNER LLPPry4 David Boies_ David Boies- Boies Schiller & Flexner LLP Sigrid McCawley Meredith Schultz Boies Schiller & Flexner LLP Paul C Cassell • Quinney College of Law at the University of Utah EFTA00296309 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 20 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation EFTA00296310 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 31 of 31 CERTIFICATE OF SERVICE, I HEREBY CERTIFY that on the 5t day of J 2017 I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF $TEPTOE & JOHNSON, LLP Michael C. Miller Justin Y.K. Chu Attorneys for Defendants UCat ,LE SM ALSTON & BIRD. LLP 1Wini—Steohenson._,Lt. Alexander S. Lorenzo Attorneys for Defendant EFTA00296311 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 31 of 31 31 EFTA00296312