EFTA00313664.pdf

Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 19 of 21 property, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. 63. Additionally, Defendant Epstein's New York mansion, located at 9 East 71st street, New York, 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 forfeiture. 64. As a direct and proximate result of Defendants' commission of the aforementioned criminal offenses enumerated in Title 18 U.S.C. § 1591 et. seq. and the civil remedies provided in § 1595, Plaintiff has in the past suffered and will continue to suffer injury and pain; emotional distress; psychological and psychi- atric 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 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 do so in the future. 19 EFTA00313664