Pricilla Doe
Pricilla Doe
CASE NO.:
PRISCILLA DOE,
Plaintiff,
vs.
Defendants.
______________________________/
COMPLAINT
Plaintiff, PRISCILLA DOE, by and through her undersigned counsel, for her
identity because this Complaint makes allegations of a sensitive sexual nature the
disclosure of which, in association with her name, would cause further harm to her.
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York.
4. At all times material, Jeffrey Epstein was a citizen of the United States
and a resident of the U.S. Virgin Islands. Jeffrey Epstein was a man of extraordinary
wealth who travelled between and stayed regularly in multiple residences, including
in New York, New York (within the Southern District of New York) at 9 East 71st
Street, New York, NY 10021; in Palm Beach, Florida at 358 El Brillo Way, Palm
Beach, Florida 33480; in New Mexico at 49 Zorro Ranch Road, Stanley, New
Mexico 87056, and in the United States Virgin Islands at Island Little St. James
5. At all times material to this cause of action Jeffrey Epstein was an adult
the Estate of Jeffrey E. Epstein was opened and domiciled in the United States Virgin
Islands, St. Thomas Division, and is the legal entity responsible for intentional,
Complaint.
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in New York, with its principal place of business located at 575 Lexington Avenue,
9. At all times material hereto, Defendant NES, LLC, (“NES”) was and is
10. At all times material hereto, Defendant, Maple, Inc., (“Maple”) is and
was a U.S. Virgin Islands corporation which conducted business in New York.
11. At all times material hereto, Defendant L.S.J., LLC, (“LSJ”) was a
Delaware corporation conducting business in the United States Virgin Islands with
business in multiple locations including New York with a Registered Agent located
at 1365 York Avenue, Apartment 28, New York, New York 10021.
13. At all times material hereto, Defendant JEGE, Inc., (“JEGE”) was a
including but not limited to, Florida, New York, and the United States Virgin
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Delaware 19801.
14. Corporate Defendants NES, LLC; Financial Trust Company, Inc; Nine East
71st Street; Maple, Inc.; L.S.J., LLC; HBRK Associates, Inc.; and JEGE, Inc.,
New York.
actors.
16. Jeffrey Epstein, the leader of a complex commercial sex trafficking and
registered in various states throughout the United States, one or more of which may
also be legally responsible for the crimes he committed against young females,
including Plaintiff.
powerful friends with whom Jeffrey Epstein caused Plaintiff to be sexually abused
by, or those who were employed through, or worked for, numerous other corporate
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18. A 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
19. At all times material to this cause of action, Jeffrey Epstein (legally
represented now through Darren K. Indyke and Richard D. Kahn as Joint Personal
including any acts that would cause Plaintiff to be harmed through conduct
committed against her in violation of Common law battery, New York Penal Law
section 130.20; or New York Penal Law 130.35; or New York Penal Law 130.50; or
New York Penal Law 130.52; or New York Penal Law 130.66; or any violation of
FACTUAL ALLEGATIONS
20. At all times material to this cause of action, Jeffrey Epstein was an adult
male over 45 years old. Epstein was a tremendously wealthy individual, widely
recognized as a billionaire, who used his wealth, power, resources, and connections
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to commit illegal sexual crimes in violation of federal and state laws and who
employed or conspired with other individuals and corporate entities to assist him in
committing those crimes or torts or who facilitated or enabled those acts to occur.
21. Epstein displayed his enormous wealth, power, and influence to his
employees; to the employees of the corporate or company entities who worked at his
direction; to the victims procured for sexual purposes; and to the public, in order to
22. At all relevant times, Epstein had access to numerous mansions, as well
as a fleet of airplanes, motor vehicles, boats and one or more helicopters. For
example, he regularly traveled by private jet aboard a Boeing aircraft (of make and
model B-727-31H with tail number N908JE) or a Gulfstream aircraft (of make and
a home located at 358 El Brillo Way, Palm Beach, Florida 33480 valued
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Island No. 6A USVI 00802 (parcels A, B, C); and an Island Little St. James Island
No. 6B USVI 00802 (A, B, C). See Jeffrey Epstein “Asset Summary – June 30,
2019” filed in Case 1:19-cr-00490-RMB on July 15, 2019 attached hereto as Exhibit
A.
corporation or business entities that owned, managed, or maintained each of the real
committed against Plaintiff; while at the residence owned by Defendant Nine East
and then Defendant Maple; or the residence located in the United States Virgin
Islands owned by LSJ. Many such acts were facilitated by Defendant NES, or
young as 14 years old, and acted on that sexual preference for decades.
27. Epstein enjoyed sexual contact with young females, including minor
children, and also took pleasure corrupting vulnerable and innocent young females,
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and associates of Defendant entities, to work in concert and at his direction, for the
trafficking.
that he obtained pleasure from corrupting and inducing vulnerable young females
into engaging in uncomfortable and unwanted sexual acts for his own gratification.
on at least two occasions, once in 2005-2008 by the United States Attorney for the
Southern District of Florida, and more recently by the United States Attorney for the
31. On July 2, 2019, the United States Attorney’s Office for the Southern
District of New York filed a Sealed Two Count Indictment including One Count of
Sex Trafficking Conspiracy and One Count of Sex Trafficking for violations of 18
U.S.C. §1591, in part due to Epstein’s criminal activities against children in the New
33. The Indictment stated in part, and Plaintiff herein adopts as true and
relevant to her Complaint, that “Jeffrey Epstein, the defendant, enticed and recruited,
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and caused to be enticed and recruited, minor girls to visit his mansion in Manhattan,
New York (the “New York Residence”) and his estate in Palm Beach, Florida (the
“Palm Beach Residence”) to engage in sex acts with him, after which the victims
34. “Moreover, and in order to maintain and increase his supply of victims,
Epstein also paid certain of his victims to recruit additional girls to be similarly
victims for him to sexually exploit in locations including New York and Palm
35. “The victims described herein were as young as 14 years old at the time
they were abused by Jeffrey Epstein, and were, for various reasons, often particularly
vulnerable to exploitation. Epstein intentionally sought out minors and knew that
many of his victims were in fact under the age of 18, including because, in some
instances, minor victims expressly told him their age.” Criminal Indictment at 2.
36. “In creating and maintaining this network of minor victims in multiple
states to sexually abuse and exploit, JEFFREY EPSTEIN … worked and conspired
with others, including employees and associates who facilitated his conduct by,
among other things, contacting victims and scheduling their sexual encounters with
EPSTEIN at the New York Residence and at the Palm Beach Residence.” Criminal
Indictment at 2.
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37. The indictment further explained, and Plaintiff adopts and alleges, that,
performed nude or partially nude, would become increasingly sexual in nature, and
38. “Epstein abused numerous minor victims at the New York Residence
by causing these victims to be recruited to engage in paid sex acts with him.”
Criminal Indictment at 3.
above, Epstein also utilized a similar, if not the same, scheme many years before the
time period that was charged and many years after, as well as in additional locations
massages from young females, often minors, who were not experienced in massage.
Rather than receive regular body massages, Epstein was predictably sexually
abusing the young females, including Plaintiff, in violation of New York Penal Law
Section 130.
actions or failed to perform actions that further placed victims, including Plaintiff,
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employees of his related companies, to recruit young females. In order to grow the
enterprise and satisfy his insatiable sexual desire, Epstein and those working at his
direction enabled victims themselves to elevate their status within the enterprise to
that of a paid recruiter of other victims, an elevation only made possible through the
assistance of Defendants.
who would help female victims advance their education, careers, and lives; and that
she only needed to provide Epstein with body massages in order to avail herself of
44. Epstein and Corporate Defendants and their many employees fulfilled
Epstein’s compulsive need for sex with young females by preying on their personal,
dated back to at least the mid-nineties and the number of victims increased
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employees.
and with help from assistants, associates and underlings, and even other victims,
employees, informed young females, including Plaintiff, that Jeffrey Epstein was
wealthy, well-connected, and had the power and ability to impact the life of any
allowed for Epstein to commit acts in violation of New York Penal Law section 130.
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PRISCILLA DOE
51. Plaintiff was twenty years old when she met Jeffrey Epstein in 2006, at
a time when Jeffrey Epstein was under federal criminal investigation by the United
States Attorney for the Southern District of Florida in relation to his commission of
various federal crimes, including violations of 18 U.S.C. §1591, against more than
52. Plaintiff was a dancer in New York when she was recruited to meet
Jeffrey Epstein by another young female who had also fallen prey to Jeffrey
53. The recruiter asked Plaintiff if she wanted a job giving massages to a
54. Plaintiff agreed to meet Jeffrey Epstein, knowing that she would be
55. The first time to the Mansion at 9 East 71st Street, she was taken
upstairs and Jeffrey Epstein paid her hundreds of dollars to give him a massage. This
massage was not sexual and Jeffrey Epstein used the time to ask Plaintiff about her
life, during which he learned that Plaintiff was a virgin, she was economically very
poor, she loved and wanted to financially support her mother, and she was very
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56. Jeffrey Epstein paid Plaintiff for the massage, took her number and told
57. Associate 1 called Plaintiff and told her to come back for a second time.
58. Again, on a second visit, Plaintiff was taken to the massage room in the
Mansion and Jeffrey Epstein spent much of the time asking questions about Plaintiff,
learning what she cared about, what professional plans she had, and what problems
59. By the third visit, in 2006, Jeffrey Epstein informed Plaintiff that he had
resources that he would use to advance Plaintiff’s dance career if she would do what
60. Plaintiff started visiting Jeffrey Epstein more regularly and he began
making the massages more sexual, digitally penetrating Plaintiff, and using sexual
61. Jeffrey Epstein always reminded Plaintiff that because of the money he
was paying her for the commercial sex acts that he called “massage,” she was able,
for the first time, to pay for her mother’s rent and for her own groceries.
reminded him that she was a virgin, and that her religion would not allow her to have
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63. Despite the fact that he had assured Plaintiff he would not try to have
sexual intercourse with her, Jeffrey Epstein forced himself on Plaintiff and took her
64. In 2006, Jeffrey Epstein told Plaintiff she was going on a trip with him
65. On that trip was Jeffrey Epstein, Jean Luc Brunel, Ghislaine Maxwell,
66. It was there that Ghislaine Maxwell taught Plaintiff the “proper way to
give a blow job,” describing to her the exact way that Jeffrey Epstein liked to be
67. Ghislaine Maxwell explicitly told Plaintiff she needed to learn how to
properly sexually service Jeffrey Epstein in the exact way that he preferred.
68. Ghislaine Maxwell then taught Plaintiff step by step, using her own
pressure to apply, the location in which pressure should be applied, the location of
the various nerve endings that should be stimulated, and the areas of the penis that
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70. Ghislaine Maxwell made it clear to Plaintiff that it was very important
for her to understand and take this instruction seriously. The message delivered to
genuine fear in Plaintiff that her failure to comply would cause her serious harm.
71. When Plaintiff was called in to “massage” Jeffrey Epstein on the Island
after Ghislaine Maxwell’s instruction, he reiterated the same instruction that Plaintiff
made sure that Plaintiff and the other young females were constantly on call to
73. While on the Island, Associate 2 also made it clear to Plaintiff that when
Jeffrey Epstein asked her to engage in certain sexual behavior, she needed to comply.
activity with Associate 2 in his presence for his own sexual gratification. The
Plaintiff. Jeffrey Epstein directed Associate 2 to use force on Plaintiff even after
Plaintiff stated that she was uncomfortable and did not want to participate in the
sexual acts then underway. At one point during the encounter, Jeffrey Epstein put
his hands around Plaintiff’s neck, which caused her a great deal of fear and
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discomfort. Jeffrey Epstein then masturbated and instructed Plaintiff to leave the
room.
75. Knowing that Jeffrey Epstein and his associates had confiscated her
passport to prevent her from having the ability to leave the Island voluntarily,
Plaintiff feared for her safety and felt forced into engaging in these sexual acts
76. It was clear by this trip that Jeffrey Epstein was extremely powerful and
77. Jeffrey Epstein learned in 2007 that Plaintiff’s 17 year old relative had
serious medical conditions and informed Plaintiff that he would use his resources to
cure them.
78. Plaintiff and Epstein talked numerous times about the fact that Plaintiff
would only introduce him to her relative if he promised not to engage in any sexual
79. Jeffrey Epstein constantly reminded Plaintiff that he was going to help
sex acts.
80. While Plaintiff was giving sexual massages, Jeffrey Epstein would
always answer the phone if someone called. Important Business Person 1, Important
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were regular callers and people with whom Jeffrey Epstein would have telephone
calls during sexual massages. Plaintiff does not want to reveal the identities of these
81. There were also times when Jeffrey Epstein, during sexual massages,
would be on the verge of ejaculating and would stop in order to make a phone call,
at times saying that nearing sexual climax evoked certain important thoughts in
Jeffrey Epstein’s mind. Jeffrey Epstein would then take or initiate up to four
82. During these phone calls, Jeffrey Epstein would seem to be advising
83. On numerous calls, Plaintiff heard Jeffrey Epstein using a very angry
and threatening tone and voice, making it known to the other party, and to Plaintiff,
that he had the ability to cause serious harm to powerful people and anyone who did
84. The reasonable impression that Plaintiff had from overhearing his
phone calls and listening to what he told her was that Jeffrey Epstein controlled very
powerful and influential people and that disobeying him would cause serious
85. Plaintiff spent considerable time with Jeffrey Epstein and overheard
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someone Jeffrey Epstein spoke to frequently, not only about business matters but
conversations she heard, and the manner and style of voice Epstein used, Plaintiff
controlling her even more to a point where she felt she had no choice but to engage
87. Jeffrey Epstein would demand that Plaintiff massage him and if he went
to sleep she was told she had to continue to massage him knowing that he would
88. From 2006, when Jeffrey Epstein first forced himself on her and took
her virginity, until 2012, he forced her to engage in commercial sex with him—sex
89. During that time, Jeffrey Epstein controlled nearly every aspect of
Plaintiff’s life from the clothing and jewelry she was permitted to wear to the career
path she was permitted to followed, to the food she was allowed to consumed.
90. When Jeffrey Epstein went to jail for sex offenses in Florida, he
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order to engage in commercial sex with Jeffrey Epstein in his Florida residence while
on so-called “work release” from jail, while he was still wearing his ankle monitor.
91. After Jeffrey Epstein was no longer in “jail” or on “work release” and
came back to New York, Plaintiff attempted to discontinue seeing Jeffrey Epstein.
92. There came a time when Plaintiff, on her own, took a trip to Montreal
and Jeffrey Epstein immediately knew that she was gone from New York and
summoned her back to his New York Mansion. He told her she was not permitted
to leave New York without his permission and that she was required at all time to
caused Plaintiff great fear that if she failed to engage in commercial sex on the terms
and conditions set by Epstein, he or the Corporate Defendants would cause her
serious harm.
95. There it became obvious to her that she was under constant
surveillance; that Jeffrey Epstein was able to monitor and know what she was doing
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in the apartment at all times, and that he was able to know and monitor where she
96. Plaintiff, between 2006 and 2012, was trafficked to Jeffrey Epstein’s
Island on Little Saint James on more than twenty occasions. On each occasion she
social media post indicating that she was on the island. The next morning, Jeffrey
Epstein woke her while holding her wrists tightly. He was in a state of great anger.
His laptop computer was open. He began questioning her, stating, “Why did you
make this post? Who has read it? What have you told them?” At the end of the
angry conversation, Jeffrey Epstein threatened Plaintiff and commanded her never
to tell anyone about the commercial sex acts in which he was making Plaintiff
engage, and never to tell her mother of her activities with Jeffrey Epstein. As
punishment for the post she had made, Jeffrey Epstein did not speak with Plaintiff
for a month.
98. Jeffrey Epstein sent Plaintiff back to New York without paying her for
any of the commercial sex acts she had engaged in with him on the island on a daily
99. Plaintiff, from that point forward in 2007, was in fear for her safety and
her life and knew that strict compliance with the dictates of this very powerful man
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was required as a condition of her maintaining her safety and her life. Epstein, in a
show of his anger and power, kicked Plaintiff out of her living quarters, essentially
rendering her homeless overnight. At the same time, Epstein informed Plaintiff that
she was forbidden to tell anyone about him or the sexual activities he was engaging
in with her.
activity, Jeffrey Epstein made it known that he was close friends with other powerful
101. Jeffrey Epstein commonly bragged to Plaintiff that Bill Clinton, Donald
Trump, Prince Andrew, and the Sultan of Dubai were among his closest friends.
102. Plaintiff overhead Jeffrey Epstein talking with the Sultan of Dubai and
on one occasion met him in person, supporting Jeffrey Epstein’s statements that he
together and heard Jeffrey Epstein talk about times when Clinton was on his private
island in Little Saint James. Plaintiff never saw Bill Clinton on the island.
called her into his massage room and warned her not to lie to him or there would be
her to continue to engage in commercial sex. Epstein worked with the people and
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d’oeuvres at Epstein’s private party with Woody Allen. This server’s role was
forced upon Plaintiff in order to demean her, frighten her, and impress upon her the
need for her to conceal the commercial sex trafficking enterprise he was running.
106. Jeffrey Epstein constantly told Plaintiff that her opportunities were
endless as long as she complied with his dictates but that he could take it all away
107. There came a time when Jeffrey Epstein forced Plaintiff to give other
powerful friends massages. During some of these massages she was sexually
abused, by force, against her will, by the friends whom she had been required to
massage.
Associate 1 contacted Plaintiff on behalf of Epstein and told her that Jeffrey Epstein
was very upset with Plaintiff’s behavior. This warning caused Plaintiff to experience
extreme fear and anxiety for her safety and her life. This fear and anxiety ultimately
had its intended effect and Plaintiff returned to Jefferey Epstein’s mansion to
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109. Jeffrey Epstein informed Plaintiff again that her career opportunities
110. Jeffrey Epstein instructed Plaintiff in 2011 that he was putting her
111. While she was in massage school, Jeffrey Epstein constantly asked
Plaintiff to recruit other young females from the massage school and became angry
112. Jeffrey Epstein forced Plaintiff to wear certain color panties, remove
certain body piercings, and undergo surgery by Jeffrey Epstein’s doctors to remove
body moles. Plaintiff complied with these demands with the understanding,
113. From 2006 through 2012, Jeffrey Epstein and his associates and
and solicited Plaintiff knowing that force, threat of force, fraud or coercion would
114. The commercial sex acts included intercourse, the use of sex toys
inserted inside Plaintiff, digital penetration, forcible touching and many other sexual
acts.
115. Plaintiff was made to engage in commercial sex acts in New York every
year from 2006 to 2012 (except for a brief period of time in late 2008 through 2009
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during which time Jeffrey Epstein was technically in jail in Florida); in the United
States Virgin Islands from 2006 to 2012 (except, again, during a brief period of time
during which Jeffrey Epstein was technically in jail in Florida); in Florida from 2007
to 2012 (including, as noted, sexual activity while Jeffrey Epstein wore his ankle
116. There were sexual acts in addition to those described above which
acts are too graphic and perverted to detail in the complaint. Each and all of such
acts were required by Jeffrey Epstein and his Corporate Defendants, all of whom
informing her that if she refused to engage in such acts she would suffer serious
harm.
also informed Plaintiff that he would use his vast resources to get Plaintiff’s relative
the serious medical care she needed, further enticing Plaintiff through fraud to
would be used to cause her to continue to engage in such acts. This assistance
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treatment for Plaintiff all while knowing that these representations were false and
fraudulent and designed to entice and induce Plaintiff to commit commercial sex
119. In order to cause Plaintiff to engage in each commercial sex act, Epstein
including Corporate Defendants, used coercion, and knew that coercion would be
120. Epstein and various associates, employees, and related corporations and
connections and his ability to obtain education, housing, or medical needs for young
associates, of his extraordinary power to reward and punish Plaintiff, his power to
do so was apparent to Plaintiff, inasmuch as: (1) she visited Epstein many times at
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his New York mansion, located at 9 East 71 Street, New York, New York, , where
she knew that Jeffrey Epstein when in New York (The mansion was owned by
Defendant, Nine East 71st Street, Corporation, from 1989 to 2011 until it was deeded
to Defendant, Maple, Inc., on December 23, 2011, the entity that maintains lawful
possession today); (2) she flew on the Boeing 747 jet owned by Defendant, JEGE,
Inc., and controlled by Jeffrey Epstein and related companies; (3) she visited his
Florida Mansion located at 358 Brillo Way, Palm Beach, Florida owned by Jeffrey
E. Epstein from 1990 through December 23, 2011; and (4) she visited his private
Island in the United States Virgin Islands, located at No. 6B Red Hook Quarter, U.S.
Virgin Islands, previously owned by Defendant L.S.J., LLC prior to its having been
23, 2011.
employees and obvious resources, each of whom worked for the Epstein enterprise.
including Defendant Corporations, it was clear through explicit words, actions and
appearances that all such employees acted at Epstein’s direction and for his
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124. Each of the employees and associates were paid through companies
believed to have been funded by Jeffrey Epstein and, regardless of such funding,
were disciples of Jeffrey Epstein, constantly informing Plaintiff and other victims of
Jeffrey Epstein’s power and ability to improve or destroy a victim’s life depending
125. The main and in many instances only function of each of the associates
who acted at the instruction or direction of Epstein was to recruit, entice, harbor,
transport, provide, obtain, maintain, or solicit young females, knowing that fraud or
126. Each such associate described above was also employed to perform
127. One significant element of the sex trafficking scheme—a scheme used
to compel commercial sex acts of young females, including Plaintiff—was its design
and effort to avoid detection. This concealment was furthered by the enterprise’s
design, actions, and patterns of behavior which caused Plaintiff and others similarly
situated to believe that failure to perform acts required by the scheme would result
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128. The scheme included frequent statements to Plaintiff and other victims
that: (1) Jeffery Epstein was of extraordinary wealth, power and influence; (2)
Jeffrey Epstein’s business and political friends, including world leaders, included
some of the most powerful people in the world; (3) the scheme or plan was designed
to constantly grow the number of victims through the recruitment of other victims;
(4) Jeffrey Epstein had the ability to advance or destroy nearly anyone financially,
reputationally, or otherwise; (5) medical and normal life necessities would be denied
victims if they, including Plaintiff, failed to perform commercial sex acts for Epstein;
and (6) Epstein could take away Plaintiff’s and other victims’ life needs such as
129. Jeffrey Epstein bragged about knowing some of the world’s most
believe that Jeffrey Epstein and his organization was powerful enough to cause her
serious harm if she did not strictly follow his and their demands.
COUNT I
BATTERY AGAINST DARREN K. INDYKE AND RICHARD D. KAHN AS
JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY
E. EPSTEIN
130. The Plaintiff adopts and realleges paragraphs 1 through 129 above.
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Plaintiff.
Plaintiff has in the past suffered and in the future will continue to suffer physical
loss of her capacity to enjoy life, as well as other damages. Plaintiff incurred medical
and psychological expenses and Plaintiff will in the future suffer additional medical
and psychological expenses. These injuries are permanent in nature and Plaintiff
Epstein for compensatory and general damages, attorney’s fees, punitive damages
and such other and further relief as this Court deems just and proper. Plaintiff hereby
COUNT II
BATTERY/VIOLATION OF SECTION 130
AGAINST DARREN K. INDYKE AND RICHARD D. KAHN AS JOINT
PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E.
EPSTEIN
133. The Plaintiff adopts and realleges paragraphs 1 through 129 above.
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sexual offense as defined in New York Penal Law § 130, including but not limited
to the following:
York Penal Law § 130, the Plaintiff has in the past suffered and in the future will
invasion of her privacy and a loss of her capacity to enjoy life, as well as other
damages. Plaintiff incurred medical and psychological expenses and Plaintiff will
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in the future suffer additional medical and psychological expenses. These injuries
are permanent in nature and Plaintiff will continue to suffer these losses in the future.
Epstein for compensatory and general damages, attorney’s fees, punitive damages
and such other and further relief as this Court deems just and proper. Plaintiff hereby
COUNT III
CAUSE OF ACTION AGAINST DARREN K. INDYKE AND RICHARD D.
KAHN AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF
JEFFREY E. EPSTEIN PURSUANT TO 18 U.S.C. § 1595
137. Jeffrey Epstein, within the special maritime and territorial jurisdiction
of the United States, in interstate and foreign commerce, and/or affecting interstate
138. Such actions were undertaken knowing that his use of force, threats of
force, fraud, coercion, and/or combinations of such means would be used, and were
in fact used, in order to cause Plaintiff to engage in commercial sex acts. In doing
140. Jeffrey Epstein conspired with each member of the enterprise, and with
141. Additionally, Defendants conspired with each other, and with other
1593A, and 1594, Defendant Darren K. Indyke and Richard D. Kahn as Joint
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 Jeffrey Epstein’s property, were used
as means and instruments of Jeffrey Epstein’s tortious and criminal offenses and, as
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
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instruments of Jeffrey Epstein’s tortious and criminal offenses and, as such, are
subject to forfeiture.
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;
invasion of privacy; and other damages associated with ' 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.
Epstein for compensatory and general damages, attorney’s fees, punitive damages
and such other and further relief as this Court deems just and proper. Plaintiff hereby
COUNT IV
CAUSE OF ACTION AGAINST
NINE EAST 71ST STREET, CORPROATION
PURSUANT TO 18 U.S.C. § 1595
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147. Defendant, by and through its management and personnel, within the
special maritime and territorial jurisdiction of the United States, in interstate and
148. Defendant, by and through its management and personnel, knew that
means of fraud or coercion, and/or combinations of such means, would be used, and
were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In
with other members of the enterprise, and with other persons and companies, known
U.S.C. § 1594(c).
151. Additionally, Defendants conspired with each other, and with other
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1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. §
soliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would
1591, 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;
enjoyment of life; invasion of privacy; and other damages associated with ' 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.
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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.
COUNT V
CAUSE OF ACTION AGAINST MAPLE, INC.
PURSUANT TO 18 U.S.C. § 1595
156. Defendant, by and through its management and personnel, within the
special maritime and territorial jurisdiction of the United States, in interstate and
157. Defendant, by and through its management and personnel, knew that
means of fraud or coercion, and/or combinations of such means, would be used, and
were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In
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
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with other members of the enterprise, and with other persons and companies, known
U.S.C. § 1594(c).
161. Additionally, Defendants conspired with each other, and with other
1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. §
soliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would
1591, 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;
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enjoyment of life; invasion of privacy; and other damages associated with ' 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.
INC., for compensatory and general damages, attorney’s fees, punitive damages and
such other and further relief as this Court deems just and proper. Plaintiff hereby
COUNT VI
CAUSE OF ACTION AGAINST L.S.J., LLC
PURSUANT TO 18 U.S.C. § 1595
166. Defendant, by and through its management and personnel, within the
special maritime and territorial jurisdiction of the United States, in interstate and
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167. Defendant, by and through its management and personnel, knew that
means of fraud or coercion, and/or combinations of such means, would be used, and
were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In
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
with other members of the enterprise, and with other persons and companies, known
U.S.C. § 1594(c).
171. Additionally, Defendants conspired with each other, and with other
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1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. §
soliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would
1591, 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;
enjoyment of life; invasion of privacy; and other damages associated with ' 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.
for compensatory and general damages, attorney’s fees, punitive damages and such
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other and further relief as this Court deems just and proper. Plaintiff hereby demands
COUNT VII
CAUSE OF ACTION AGAINST
FINANCIAL TRUST COMPANY, INC.
PURSUANT TO 18 U.S.C. § 1595
176. Defendant, by and through its management and personnel, within the
special maritime and territorial jurisdiction of the United States, in interstate and
177. Defendant, by and through its management and personnel, knew that
means of fraud or coercion, and/or combinations of such means, would be used, and
were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In
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
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with other members of the enterprise, and with other persons and companies, known
U.S.C. § 1594(c).
181. Additionally, Defendants conspired with each other, and with other
1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. §
soliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would
1591, 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;
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enjoyment of life; invasion of privacy; and other damages associated with ' 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.
Trust Company, Inc., For compensatory and general damages, attorney’s 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.
COUNT VIII
CAUSE OF ACTION AGAINST NES, LLC
PURSUANT TO 18 U.S.C. § 1595
186. Defendant, by and through its management and personnel, within the
special maritime and territorial jurisdiction of the United States, in interstate and
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187. Defendant, by and through its management and personnel, knew that
means of fraud or coercion, and/or combinations of such means, would be used, and
were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In
with other members of the enterprise, and with other persons and companies, known
U.S.C. § 1594(c).
190. Additionally, Defendants conspired with each other, and with other
1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. §
soliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would
45
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1591, 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;
enjoyment of life; invasion of privacy; and other damages associated with ' 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.
compensatory and general damages, attorney’s fees, punitive damages and such
other and further relief as this Court deems just and proper. Plaintiff hereby demands
COUNT IX
CAUSE OF ACTION AGAINST
HBRK ASSOCIATES, INC. PURSUANT TO 18 U.S.C. § 1595
195. Defendant, by and through its management and personnel, within the
special maritime and territorial jurisdiction of the United States, in interstate and
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196. Defendant, by and through its management and personnel, knew that
means of fraud or coercion, and/or combinations of such means, would be used, and
were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In
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
with other members of the enterprise, and with other persons and companies, known
U.S.C. § 1594(c).
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200. Additionally, Defendants conspired with each other, and with other
1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. §
soliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would
1591, 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;
enjoyment of life; invasion of privacy; and other damages associated with ' 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
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addition to these losses, Plaintiff has incurred attorneys’ fees and will be required do
so in the future.
Associates, Inc., for compensatory and general damages, attorney’s 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.
COUNT X
CAUSE OF ACTION AGAINST JEGE, INC.
PURSUANT TO 18 U.S.C. § 1595
205. Defendant, by and through its management and personnel, within the
special maritime and territorial jurisdiction of the United States, in interstate and
206. Defendant, by and through its management and personnel, knew that
means of fraud or coercion, and/or combinations of such means, would be used, and
were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In
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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
with other members of the enterprise, and with other persons and companies, known
U.S.C. § 1594(c).
210. Additionally, Defendants conspired with each other, and with other
1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. §
soliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would
50
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1591, 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;
enjoyment of life; invasion of privacy; and other damages associated with ' 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.
for compensatory and general damages, attorney’s fees, punitive damages and such
other and further relief as this Court deems just and proper. Plaintiff hereby demands
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Respectfully Submitted,
Bradley J. Edwards
Brittany N. Henderson
425 N. Andrews Ave., Suite 2
Fort Lauderdale, FL 33301
(954)-524-2820
Fax: (954)-524-2822
Email: [email protected]
[email protected]
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