Court Records
EXHIBIT A
EFTA02738058
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
CASE NO.
JANE DOE 17,
Plaintiff,
v.
DARREN K. INDYKE AND
RICHARD D. KAHN, AS JOINT
PERSONAL REPRESENTATIVES OF
THE ESTATE OF JEFFREY E. EPSTEIN,
NINE EAST 7Ist STREET CORPORATION,
LAUREL, INC., FINANCIAL TRUST COMPANY,
INC., NES, LLC, MAPLE, INC., LSJE, LLC,
HBRK ASSOCIATES, INC., NAUTILUS, INC.,
CYPRESS, INC. and JEGE, INC.
Defendants.
COMPLAINT
Plaintiff, JANE DOE 17, by and through the undersigned counsel, in support of her
claims against Defendants, alleges and states as follows:
I. This action is brought, inter alia, pursuant to common law, statutory law and 18
U.S.C. §159I- § 1595. Therefore, jurisdiction is proper under 28 U.S.C. §1331 and the damages
sought exceed the jurisdictional requirements of this Court.
2. Plaintiff files this complaint under a pseudonym in order to protect her identity
because the Complaint makes allegations of a sensitive sexual nature the disclosure of which, in
association with her name, would cause further harm to her.
3. Plaintiff is currently a resident and domiciled in the State of Florida and over the
age of 18.
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4. At all times material, Jeffrey Epstein ("Epstein") was a citizen of the United
States and resident of the U.S. Virgin Islands. Epstein was a man of extreme wealth who
frequently travelled between and regularly stayed in his numerous residences, including in New
York (within the Southern District of New York) at 9 East 71" 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, in Paris, France at 22 Avenue Foch, Paris,
France 75116, and in the United States Virgin Islands at Little St. James Island No. 6B USVI
00802.
5. At all times material to this cause of action Epstein was an adult male born on
January 20, 1953, who died on August 10, 2019.
6. Defendant, Darren K. Indyke and Richard D. Kahn as Joint Personal
Representatives of the Estate of Jeffrey E. Epstein ("Estate of Jeffrey E. Epstein") was opened
and domiciled in the United States Virgin Islands, St. Division, and is the legal entity
responsible for intentional, criminal, or tortious conduct committed by Epstein as described in
this Complaint.
7. At all times material hereto, Defendant Nine East 71' Street, Corporation ("Nine
East"), was a domestic business corporation conducting business in New York with its principal
place of business located at 575 Lexington Avenue, Fourth Floor, New York 10022.
8. At all times material hereto, Defendant Laurel, Inc. ("Laurel") was and is a U.S.
Virgin Islands corporation conducting business in multiple locations including New York and
Florida.
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9. At all times material hereto, Defendant Financial Trust Company, Inc. ("Financial
Trust"), was and is a U.S. Virgin Islands corporation conducting business in multiple locations
including New York.
10. At all times material hereto, Defendant NES, LLC, ("NES"), was and is a
domestic limited liability company registered in and conducting business in multiple locations
including New York.
II. At all times material hereto, Defendant Maple, Inc., ("Maple"), was and is a U.S.
Virgin Islands corporation conducting business in New York.
12. At all times material hereto, LSJE., LLC, ("LSJ"), was and is a U. S. Virgin
Islands corporation conducting business in the United States Virgin Islands conducting business
in New York.
13. At all times material hereto, Defendant HBRK Associates, Inc., ("HBRK"), was
and is a domestic business corporation registered in and conducting business in multiple
locations including New York with a Registered Agent located at 1365 York Avenue, Apartment
28, New York 10021.
14. At all times material hereto, Defendant Nautilus, Inc., ("Nautilus"), was and is a
U.S. Virgin Islands corporation conducting business in New York.
15. At all times material hereto, Defendant Cypress, Inc., ("Cypress"), was and is a
U.S. Virgin Islands corporation conducting business in New York and New Mexico.
16. At all times material hereto, Defendant JEGE, Inc., ("JEGE"), is a U.S. Virgin
Islands corporation conducting business throughout the United States of America, including but
not limited to, Florida, New York and the United States Virgin Islands.
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17. Corporate Defendants Nine East, Laurel, Financial Trust, NES, Maple, LSJE,
HBRK, JEGE, Nautilus, and Cypress, referred to as "Corporate Defendants," each performed
business, in whole or in part, in New York.
18. Plaintiff intends to amend this complaint to add or substitute additional parties as
discovery reveals the identities of other tortious corporate or individual actors.
19. Epstein, the leader of a complex commercial sex trafficking and abuse ring, was
an officer, director, or employee of many corporate entities registered in various states
throughout the United States, one or more of which may also be legally responsible for the
crimes and torts he committed against young females, including Plaintiff.
20. Additionally, individuals who worked at the residences where sexual criminal acts
were committed, or friends or acquaintances who assisted Epstein in committing such violations
or those of his wealthy, famous, or socially powerful friends with whom Epstein caused Plaintiff
to be sexually abused by, or those who were employed through, or worked for, numerous other
corporate entities whose participation caused or contributed to causing the sexual violations that
caused harm to Plaintiff, may additionally be added as defendants.
21. 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 this District. 28 U.S.C.
§139I(bX2).
22. At all times material to this cause of action, Epstein (legally represented now
through Darren K. Indyke and Richard D. Kahn as Joint Personal Representatives of the Estate
of Jeffrey E. Epstein (referred to herein as "Estate of Jeffrey E. Epstein") and Corporate
Defendants owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit, or
conspire to commit, or cause to be committed intentional, criminal, fraudulent, or tortious acts
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against Plaintiff, 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 §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 18 U.S.C. §159I- §1595.
FACTUAL ALLEGATIONS
23. At all times material to this cause of action, 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 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.
24. 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 advance, carry out, and conceal his
crimes and torts.
25. 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 model G-1159B with tail number N909JE).
26. Epstein also inhabited and frequently travelled between numerous properties and
homes, each of which he admitted to being owned or controlled by him, including a Manhattan
townhome located at 9 East 715' Street, New York, New York 10021 valued conservatively by
Epstein's own admission at $55,931,000.00 (but valued by the US Attorney's office for this
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District at $77,000,000); a ranch located at 49 Zorro Ranch Road, Stanley, New Mexico 87056
valued conservatively by Epstein's own admission at $17,246,208.00; a home located at 358 El
Brillo Way, Palm Beach, Florida 33480 valued conservatively by Epstein's own admission at
$12,380,209.00; an apartment located at 22 Avenue Foch, Paris, France 75116 valued
conservatively by Epstein's own admission at $8,672,820.00; an Island located at Great St.
James Island No. 6A USVI 00802 (parcels A, B, and C); and an Island Little St. James Island
No. 6B USVI 00802 (parcels A, B, and C). See Jeffrey Epstein "Asset Summary — June 30,
2019" filed in Case No. 1:19-cr-00490-RMB on July 15, 2019 attached hereto as Exhibit A.
27. Epstein controlled or was affiliated with the corporation or business entities that
owned, managed, or maintained each of the real properties listed in the preceding paragraph and
enumerated in Exhibit A.
28. The allegations herein concern Epstein's tortious conduct committed against
Plaintiff v, hi le at the residences owned by Defendant Nine East in New York, Defendant Laurel
in Florida, Defendant Cypress in New Mexico and Defendants LSJE and Nautilus in the U.S.
Virgin Islands. Many such acts were facilitated by Defendant NES or Defendant HBRK or
Defendant JEGE.
29. Epstein had a compulsive sexual preference for young females, as young as 14
years old, and acted on that sexual preference for decades.
30. Epstein enjoyed sexual contact with young females, including minor children, and
also took pleasure corrupting vulnerable and innocent young females, including minor children,
into engaging in sexual acts with him.
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31. Epstein directed a complex system of individuals, including employees and
associates of Defendant entities, to work in concert and at his direction, for the purpose of
harming young females through sexual exploitation, abuse and trafficking.
32. It was widely known among individuals regularly in Epstein's presence that he
obtained pleasure from corrupting and inducing vulnerable young females into engaging in
uncomfortable and unwanted sexual acts for his own gratification.
33. Epstein's illegal sexual activities were investigated by law enforcement 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 Southern District of New York.
34. 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 York Mansion located at 9 East 71'
Street.
35. In addition to the allegations in the criminal indictment referenced 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 nationally and internationally.
36. Corporate Defendants enabled Epstein to receive daily massages from young
females, often minors, who were not experienced in massage. Rather than receive regular body
massages, Epstein was predictably sexually abusing young females, including Plaintiff, in
violation of New York Penal Law §130.
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37. Additionally, employees of the various Corporate Defendants performed actions
or failed to perform actions that further placed victims, including Plaintiff, in danger of being
sexually abused by Epstein, and assisted in the concealment of his sexually abusive acts.
38. Defendants employed many recruiters of young females, or directed 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.
39. Recruiters were taught by Epstein or by employees of Corporate Defendants to
inform targeted young female victims that Epstein possessed extraordinary wealth, power,
resources, and influence; that he was a philanthropist 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 his nearly unlimited assistance and influence.
40. Epstein and Corporate Defendants and their many employees fulfilled Epstein's
compulsive need for sex with young females by preying on their personal, psychological,
financial, and related vulnerabilities. Epstein and Defendants' tactics included promising the
victims money, shelter, transportation, gifts, employment, admission into educational
institutions, education tuition, professional licensure, protection, healthcare and other things of
value.
41. Epstein's sexual attraction to young, often underage, females dated back to at
least the mid-nineties and the number of victims increased substantially with the necessary
assistance from Defendants and Defendants' employees.
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42. Defendants, at the direction of Epstein or in furtherance of his demands, and with
help from assistants, associates and underlings, and even other victims, recruited or procured
dozens if not hundreds of young females, including minors, for the purpose of Epstein's sexual
gratification.
43. Epstein, and employees of certain Corporate Defendants, including at least
Defendant HBRK, specifically targeted underprivileged, emotionally vulnerable and/or
economically disadvantaged young females to sexually molest and abuse.
44. Additionally, Epstein and Corporate Defendants, through employees, informed
young females, including Plaintiff that Epstein was wealthy, well-connected, and had the power
and ability to impact the life of any young female recruited or obtained to provide a massage.
45. Each of the Corporate Defendants committed acts of negligence that allowed for
Epstein to commit acts in violation of New York Penal Law §130.
46. Each of the Defendants committed acts against Plaintiff in violation of 18 U.S.C.
§159I — §I595.
ANE DOE 17
47. Consistent with Epstein's foregoing plan, scheme/enterprise, the Plaintiff was
recruited to provide Epstein with massages for monetary compensation. These massages
provided to Epstein by Plaintiff progressed to instances of inappropriate sexual contact with the
Plaintiff by Epstein in touching, inappropriate vaginal penetration, and outright rape. Plaintiff
was sexually assaulted, violated, and otherwise degraded, injured, victimized, and subjected to
outrageous, reckless abuse and insult.
48. In this regard, the Defendants willingly participated, contributed, cooperated, and
assisted the inappropriate and illegal scheme by facilitating such scheme by and through the
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employees of the Corporate Defendants such that the Corporate Defendants were acting jointly
and in concert with the illegal scheme with the goal designed to produce corrupt sexual
gratification for Epstein and degradation for the targets and victims of the corrupt scheme set in
motion with the active involvement of the Corporate Defendants and their employees.
49. Epstein's abuse of the Plaintiff was not incidental or fleeting but rather was born
out of a pathological desire to achieve, corrupt and deviate sexual gratification through the
subjugation and abuse of Epstein's targeted victims. The actions on behalf of the Corporate
Defendants by and through its employees enhanced, facilitated, and promoted the deviate sexual
acts of Epstein and contributed a corrupting influence which ensnared unsuspecting women and
girls in its reach.
50. Epstein, by acting singularly and in concert with the Corporate Defendants,
devised a sophisticated plan and a modus operandi which subtly and pervasively over time
connived to influence the victims and subjects of the corrupt and deviant sexual scheme to
influence the will to resist the temptations both actual and promised on behalf of the scheme and
thereby manipulate the victims into acceptance of the scheme as being one that was acceptable
and appropriate by virtue of communications and representations made on behalf of Epstein by
the Corporate Defendants and in fact Epstein himself. The scheme utilized a gradual wearing
down of the victim's will to resist and did so by virtue of offering positive and negative rewards
for compliance with the scheme's overall deviant methodology and goals.
51. Once Epstein and the Corporate Defendants' victims were entrapped and the
scheme's methodologies enabled, Epstein and the corporate defendants through its employees
utilized techniques to further inhibit, indoctrinate, and threaten Epstein's victims such that
compliance with the deviant scheme's goals could be further obtained.
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52. The deviant scheme was perpetuated over years by the actions of Epstein and the
Corporate Defendants such that victims were caught up in the scheme, pressure, threats, and
indoctrination techniques utilized to bring the victims to heel.
53. For victims young, vulnerable, and struggling financially, the scheme's
methodology was particularly effective.
54. As part and parcel of the scheme's goals, Epstein's colleagues and acquaintances
were involved in the scheme and benefited from the scheme by virtue of receiving sexual favors
and inappropriate, illegal, and otherwise commercial sexual services provided by Epstein's
victims such that the corrupt intent of this scheme involved males other than Epstein himself.
As a direct and proximate result of the methodology of the deviant scheme and the goals of
sexual exploitation of the women recruited and victimized, Plaintiff was subject to unwanted
touching of her breasts and genitals, other sensitive areas of her body, required to perform acts
of a sexual nature against her will and subjected to genital penetration and otherwise sexually
degraded, abused, insulted, coerced, and injured, experience resulting in confusion, emotional
distress, mental pain and suffering, shame, humiliation, loss of the enjoyment of life,
inconvenience, and other injuries to body, mind and soul.
55. Epstein and the Corporate Defendants by and through their employees and agents
substantially contributed to proximately cause injury to the Plaintiff as aforementioned.
56. Over a course of years, Epstein and the Corporate Defendants, by and through its
employees and agents, facilitated the multiple rapes conducted on the Plaintiff in addition to
other deviant sexual acts against her will. Furthermore, the plaintiff's virginity was forcefully
taken from her against her will.
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57. This fraudulent scheme of Epstein's constituted acts of coercion from beginning
to end, from 2001 through mid-2006, inasmuch as the scheme was designed to and in fact,
caused Plaintiff to believe that her failure to perform any sex act required by Epstein would
result in serious financial, reputational, physical and emotional harm to her.
COUNT I
(BATTERY AGAINST DARREN K. INDYKE AND RICHARD D. KAHN AS JOINT
PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN)
58. The Plaintiff adopts and realleges paragraphs 1 through 57 above.
59. Epstein committed a harmful or offensive touching against Plaintiff.
60. As a direct and proximate result of Epstein's battery, the Plaintiff has in the past
suffered and in the future will continue to suffer physical injury, pain, emotional distress,
psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of
dignity, 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 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.
WHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. 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 demands trial by jury on all issues
triable as of right by a jury.
COUNT II
(BATTERYNIOLATION OF SECTION 130 AGAINST DARKEN K. INDYKE AND
RICHARD D. KAHN AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE
OF JEFFREY E. EPSTEIN)
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61. The Plaintiff adopts and realleges paragraphs 1 through 57 above.
62. The intentional acts of Epstein against Plaintiff constitute a sexual offense as
defined in New York Penal Law §130, including but not limited to the following:
a. Sexual misconduct as defined in §130.20 inasmuch as Epstein engaged in
sexual intercourse with Plaintiff without Plaintiff's consent;
b. Rape in the first degree as defined in §130.35 inasmuch as Epstein engaged in
sexual intercourse with Plaintiff by forcible compulsion;
c. Criminal sexual act in the first degree as defined in §130.50 inasmuch as
Epstein engaged in oral sexual conduct with Plaintiff by forcible compulsion;
d. Forcible touching as defined in §130.52 inasmuch as Epstein, intentionally
and for no legitimate purpose, engaged the forcible sexual touching of
Plaintiff for the purpose of degrading or abusing her or for the purpose of
gratifying his own sexual desire; and,
e. Aggravated sexual abuse in the third degree as defined in §130.66 inasmuch
as Epstein inserted a foreign object in the vagina of Plaintiff by forcible
compulsion.
63. As a direct and proximate result of Epstein's violations of New York Penal Law
§130, Plaintiff has in the past suffered and in the future will continue to suffer physical injury,
pain, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss
of self-esteem, loss of dignity, 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
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.
WHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. 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 demands trial by jury on all issues
triable as of right by a jury.
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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)
64. Plaintiff adopts and realleges paragraphs I through 57 above.
65. Epstein, 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, obtained, maintained, patronized,
solicited, threatened, forced, or coerced Plaintiff to engage in commercial sex acts.
66. 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 so, Epstein violated 18
U.S.C. §1591.
67. Furthermore, Epstein attempted to violate 18 U.S.C. § 1591. In so doing, violated
18 U.S.C. § 1594(a).
68. Epstein conspired with each member of the enterprise, and with other persons
known and unknown, to violate 18 U.S.C. § 1591. In so doing, violated 18 U.S.C. § 1594(c).
69. By virtue of Epstein's violations of 18 U.S.C. §§ 1591, I593A, and 1594,
Defendants Darren K. Indyke and Richard D. Kahn as Joint Personal Representatives of the
Estate of Jeffrey E. Epstein ("Estate of Jeffrey E. Epstein") is subject to civil causes of action
under 18 U.S.C. § 1595 by Plaintiff, who is a victim of the violations.
70. Certain property of Epstein's was essential to the commission of the federal
crimes and torts described herein, including the Palm Beach, Florida estate located at 358 El
Brillo Way, Palm Beach, Florida 33480, the use of multiple private aircraft including a Boeing
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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 real property and aircraft, along with
other of Epstein's property, were used as means and instruments of Epstein's tortious and
criminal offenses and, as such, are subject to forfeiture.
71. Additionally, Epstein's New York townhouse, located at 9 East 71st Street, New
York, New York, in the Southern District of New York, Epstein's private island located in the
United States Virgin Islands and Epstein's New Mexico estate, were used as means and
instruments of Epstein's tortious and criminal offenses as they relate to Plaintiff and, as such, are
subject to forfeiture.
72. As a direct and proximate result of Epstein's commission of the aforementioned
criminal offenses enumerated in 18 U.S.C. § 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, emotional distress, psychological and psychiatric 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 Epstein's 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 which Epstein is liable pursuant to 18
U.S.C. §1595.
WHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. Epstein for
compensatory and general damages, attorney's fees pursuant to 18 U.S.C. §1595, punitive
damages, forfeiture of Epstein's assets 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.
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COUNT IV
(CAUSE OF ACTION AGAINST NINE EAST 71ST STREET, CORPORATION
PURSUANT TO 18 U.S.C. $1595)
73. Plaintiff adopts and realleges paragraphs 1 through 57 above.
74. Defendant, by and through its management and personnel, 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, obtained, maintained, patronized, solicited by any means Plaintiff from
2001 through 2006.
75. 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 doing so, Defendant corporation
violated 18 U.S.C. §1591.
76. Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 1591. In so
doing, violated 18 U.S.C. § 1594(a).
77. Defendant, by and through its management and personnel, conspired with other
members of the enterprise, and with other persons and companies, known and unknown, to
violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 U.S.C. § 1594(c).
78. By virtue of its violations of 18 U.S.C. §§ 1591, 1593A, and 1594, Defendant is
subject to civil causes of action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of their
violations.
79. Defendant, by and through its management and personnel, participated in a
venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
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maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
a commercial sex act.
80. As a direct and proximate result of Defendant corporation's commission of the
aforementioned criminal offenses enumerated in 18 U.S.C. §§ 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, emotional distress, psychological and psychiatric 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 Defendant's actions.
81. 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 continue to do so in the future for
which Defendant is liable pursuant to 18 U.S.C. §1595.
WHEREFORE, Plaintiff demands judgment against Nine East 71st Street, Corporation for
compensatory and general damages, attorney's fees pursuant to 18 U.S.C. §I595, forfeiture of
Defendant's assets, 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 V
(CAUSE OF ACTION AGAINST LAUREL, INC. PURSUANT TO 18 U.S.C. *1595)
82. Plaintiff adopts and realleges paragraphs I through 57 above.
83. Defendant, by and through its management and personnel, 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,
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EFTA02738075
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transported, provided, obtained, maintained, patronized, solicited by any means Plaintiff from
2001 through 2006.
84. 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 doing so, Defendant corporation
violated 18 U.S.C. §1591.
85. Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 1591. In so
doing, violated 18 U.S.C. § 1594(a).
86. Defendant, by and through its management and personnel, conspired with other
members of the enterprise, and with other persons and companies, known and unknown, to
violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 U.S.C. § 1594(c).
87. By virtue of its violations of 18 U.S.C. §§ 1591, 1593A, and 1594, Defendant is
subject to civil causes of action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of their
violations.
88. Defendant, by and through its management and personnel, participated in a
venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
a commercial sex act.
89. As a direct and proximate result of Defendant corporation's commission of the
aforementioned criminal offenses enumerated in 18 U.S.C. §§ 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, emotional distress, psychological and psychiatric trauma, mental
Page 18 of 34
EFTA02738076
CasgA49:92944r4§ 16R6FRPcbCFNITtlentiffle41311 Fithtienin9 1119PanSP3 ,21137
anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of
enjoyment of life, invasion of privacy, and other damages associated with Defendant's actions.
90. 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 continue to do so in the future for
which Defendant is liable pursuant to 18 U.S.C. §1595.
WHEREFORE, Plaintiff demands judgment against Laurel, Inc. for compensatory and
general damages, attorney's fees pursuant to 18 U.S.C. *1595, forfeiture of Defendant's assets,
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 VI
(CAUSE OF ACTION AGAINST FINANCIAL TRUST COMPANY, INC.
PURSUANT TO 18 U.S.C. §1595)
91. Plaintiff adopts and realleges paragraphs 1 through 57 above.
92. Defendant, by and through its management and personnel, 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, obtained, maintained, patronized, solicited by any means Plaintiff.
93. 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 doing so, Defendant corporation
violated 18 U.S.C. §1591.
94. Defendant, by and through its management and personnel knowingly benefitted,
financially and by receiving things of value, from participating in a venture (the Epstein sex
Page 19 of 34
EFTA02738077
CasLeth49.-9,3124634€136-4>NE-bc FD qgtiEnuffle F 16 tleitAing*adiag, 611320 37
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, Defendant
corporation violated 18 U.S.C. § 1593A.
95. Furthermore, Defendant corporation attempted to violate 18 U.S.C. §1591. In so
doing, violated 18 U.S.C. § 1594(a).
96. Defendant, by and through its management and personnel, conspired with other
members of the enterprise, and with other persons and companies, known and unknown, to
violate 18 U.S.C. §1591. In so doing, Defendant violated 18 U.S.C. §1594(c).
97. By virtue of their violations of 18 U.S.C. §§ 1591, 1593A, and 1594, Defendant is
subject to civil causes of action under 18 U.S.C. §1595 by Plaintiff, who is a victim of their
violations.
98. Defendant, by and through its management and personnel, participated in a
venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
a commercial sex act.
99. As a direct and proximate result of Defendant corporation's commission of the
aforementioned criminal offenses enumerated in 18 U.S.C. §§ 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, emotional distress, psychological and psychiatric 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 Defendant's actions.
100. 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
Page 20 of 34
EFTA02738078
casgth49.-T449/44€136-EPALcbcPcNtiEre#44‘611 RIEtheitil-fing*.adikiZir SRO 37
these losses, Plaintiff has incurred attorneys' fees and will continue to do so in the future for
which Defendant is liable pursuant to 18 U.S.C. §1595.
WHEREFORE, Plaintiff demands judgment against Defendant, Financial Trust Company,
Inc., For compensatory and general damages, attorney's fees pursuant to 18 U.S.C. §1595,
forfeiture of Defendant's assets, 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 VII
(CAUSE OF ACTION AGAINST NES, LLC PURSUANT TO 18 U.S.C. §1595)
101. Plaintiff adopts and realleges paragraphs I through 57 above.
102. Defendant, by and through its management and personnel, 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, obtained, maintained, patronized, solicited by any means Plaintiff.
103. 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 doing so, Defendant corporation
violated 18 U.S.C. §1591.
104. Furthermore, Defendant corporation attempted to violate 18 U.S.C. §1591. In so
doing, violated 18 U.S.C. §I594(a).
105. Defendant, by and through its management and personnel, conspired with other
members of the enterprise, and with other persons and companies, known and unknown, to
violate 18 U.S.C. §1591. In so doing, Defendant violated 18 U.S.C. §1594(c).
Page 21 of 34
EFTA02738079
casgal-,d 9.-q9J49/40636-EPNE-bc rootiEreiNA 41611 FnEtiettfing*.adiaigg St3320 37
106. By virtue of their violations of 18 U.S.C. §§ 1591, 1593A, and 1594, Defendant is
subject to civil causes of action under 18 U.S.C. §1595 by Plaintiff, who is a victim of their
violations.
107. Defendant, by and through its management and personnel, participated in a
venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
a commercial sex act.
108. As a direct and proximate result of Defendant corporation's commission of the
aforementioned criminal offenses enumerated in 18 U.S.C. §§ 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, emotional distress, psychological and psychiatric 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 Defendant's actions.
109. 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 continue to do so in the future for
which Defendant is liable pursuant to 18 U.S.C. *1595.
WHEREFORE, Plaintiff demands judgment against Defendant, NES, Inc., for
compensatory and general damages, attorney's fees pursuant to 18 U.S.C. §1595, forfeiture of
Defendant's assets, 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.
Page 22 of 34
EFTA02738080
Casgabd 9.-Tgqic4061M-EPALcbcroligtium44ft1 RIEt4eitil-fintl aitanSf43Q1f 37
COUNT VIII
(CAUSE OF ACTION AGAINST MAPLE, INC. PURSUANT TO 18 U.S.C. §1595)
110. Plaintiff adopts and realleges paragraphs 1 through 57 above.
1 1 l. Defendant, by and through its management and personnel, 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, obtained, maintained, patronized, solicited by any means Plaintiff from
2001 through 2006.
112. 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 doing so, Defendant corporation
violated 18 U.S.C. §1591.
113. Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 1591. In so
doing, violated 18 U.S.C. § 1594(a).
114. Defendant, by and through its management and personnel, conspired with other
members of the enterprise, and with other persons and companies, known and unknown, to
violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 U.S.C. § 1594(c).
115. By virtue of its violations of 18 U.S.C. §§ 1591, 1593A, and 1594, Defendant is
subject to civil causes of action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of their
violations.
116. Defendant, by and through its management and personnel, participated in a
venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
Page 23 of 34
EFTA02738081
casga1,49.-TeJ49faigrnif8-PNE-bcFpotitro#044k1 niEtleib)-fing*.adLlazit St5320 37
maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
a commercial sex act.
117. As a direct and proximate result of Defendant corporation's commission of the
aforementioned criminal offenses enumerated in 18 U.S.C. §§ 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, emotional distress, psychological and psychiatric 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 Defendant's actions.
118. 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 continue to do so in the future for
which Defendant is liable pursuant to 18 U.S.C. §1595.
WHEREFORE, Plaintiff demands judgment against Maple, Inc. for compensatory and
general damages, attorney's fees pursuant to 18 U.S.C. *1595, forfeiture of Defendant's assets,
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 IX
(CAUSE OF ACTION AGAINST LSJE, LLC PURSUANT TO 18 U.S.C. §1595)
119. Plaintiff adopts and realleges paragraphs I through 57 above.
120. Defendant, by and through its management and personnel, 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,
Page 24 of 34
EFTA02738082
C asgal-,d 9.-TgQ9/49613A-FPNE-bc rootierem44ftl Fithtietl-fing*.atfeda& Steg 37
transported, provided, obtained, maintained, patronized, solicited by any means Plaintiff from
2001 through 2006.
121. 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 doing so, Defendant corporation
violated 18 U.S.C. §1591.
122. Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 1591. In so
doing, violated 18 U.S.C. § 1594(a).
123. Defendant, by and through its management and personnel, conspired with other
members of the enterprise, and with other persons and companies, known and unknown, to
violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 U.S.C. § 1594(c).
124. By virtue of its violations of 18 U.S.C. §§ 1591, 1593A, and 1594, Defendant is
subject to civil causes of action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of their
violations.
125. Defendant, by and through its management and personnel, participated in a
venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
a commercial sex act.
126. As a direct and proximate result of Defendant corporation's commission of the
aforementioned criminal offenses enumerated in 18 U.S.C. §§ 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, emotional distress, psychological and psychiatric trauma, mental
Page 25 of 34
EFTA02738083
casgabd 9.1.9349/406if &FF.-NElb c Focainffffie41311 Fil6t4eth,l-W9A9PadLlaze Ent* 37
anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of
enjoyment of life, invasion of privacy, and other damages associated with Defendant's actions.
127. 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 continue to do so in the future for
which Defendant is liable pursuant to 18 U.S.C. §1595.
WHEREFORE, Plaintiff demands judgment against LSJE, LLC for compensatory and
general damages, attorney's fees pursuant to 18 U.S.C. *1595, forfeiture of Defendant's assets,
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 HBRK ASSOCIATES, INC.
PURSUANT TO 18 U.S.C. §1595)
128. Plaintiff adopts and realleges paragraphs 1 through 57 above.
129. Defendant, by and through its management and personnel, 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, obtained, maintained, patronized, solicited by any means Plaintiff.
130. 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 doing so, Defendant corporation
violated 18 U.S.C. §1591.
131. Defendant, by and through its management and personnel knowingly benefitted,
financially and by receiving things of value, from participating in a venture (the Epstein sex
Page 26 of 34
EFTA02738084
casgth49.-Wliedgrolf6-Wire-bc Fp cOtiEndffierail Fithtiethtlini 31 4DadL1327e7183211 37
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, Defendant
corporation violated 18 U.S.C. §1593k
132. Furthermore, Defendant corporation attempted to violate 18 U.S.C. §1591. In so
doing, Defendant violated 18 U.S.C. §1594(a).
133. Defendant, by and through its management and personnel, conspired with other
members of the enterprise, and with other persons and companies, known and unknown, to
violate 18 U.S.C. §1591. In so doing, Defendant violated 18 U.S.C. §1594(c).
134. By virtue of their violations of 18 U.S.C. §§ 1591, 1593A, and 1594, Defendant is
subject to civil causes of action under 18 U.S.C. §1595 by Plaintiff, who is a victim of their
violations.
135. Defendant, by and through its management and personnel, participated in a
venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
a commercial sex act.
136. As a direct and proximate result of Defendant corporation's commission of the
aforementioned criminal offenses enumerated in 18 U.S.C. §§ 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, emotional distress, psychological and psychiatric 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 Defendant's actions.
137. 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
Page 27 of 34
EFTA02738085
C asgaIld 9.-AvJfe9faigieif ArPfir—bc rootiEnan% 41611 FilbilerbtlfRA 19PaigaZIN St93211 37
these losses, Plaintiff has incurred attorneys' fees and will continue to do so in the future for
which Defendant is liable pursuant to 18 U.S.C. §1595.
138. WHEREFORE, Plaintiff demands judgment against Defendant, HBRK
Associates, Inc., for compensatory and general damages, attomey's fees pursuant to 18 U.S.C.
§ 1595, forfeiture of Defendant's assets, 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 XI
(CAUSE OF ACTION AGAINST NAUTILUS, INC. PURSUANT TO 18 U.S.C. $1595)
139. Plaintiff adopts and realleges paragraphs I through 57 above.
140. Defendant, by and through its management and personnel, 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, obtained, maintained, patronized, solicited by any means Plaintiff.
141. 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 doing so, Defendant corporation
violated 18 U.S.C. §1591.
142. Defendant, by and through its management and personnel 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, Defendant
corporation violated 18 U.S.C. §1593A.
Page 28 of 34
EFTA02738086
casgA:49.-.92igaraMitcpPcbcFpcodenfrfie4k1 FliEtierbWhill*aedioAf 37
143. Furthermore, Defendant corporation attempted to violate 18 U.S.C. §1591. In so
doing, Defendant violated 18 U.S.C. §1594(a).
144. Defendant, by and through its management and personnel, conspired with other
members of the enterprise, and with other persons and companies, known and unknown, to
violate 18 U.S.C. §1591. In so doing, Defendant violated 18 U.S.C. §1594(c).
145. By virtue of their violations of 18 U.S.C. §§ 1591, 1593A, and 1594, Defendant is
subject to civil causes of action under 18 U.S.C. §1595 by Plaintiff, who is a victim of their
violations.
146. Defendant, by and through its management and personnel, participated in a
venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
a commercial sex act.
147. As a direct and proximate result of Defendant corporation's commission of the
aforementioned criminal offenses enumerated in 18 U.S.C. §§ 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, emotional distress, psychological and psychiatric 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 Defendant's actions.
148. 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 continue to do so in the future for
which Defendant is liable pursuant to 18 U.S.C. §1595.
Page 29 of 34
EFTA02738087
Cas&g:49. -.92eaegti6@figt/Calgtlelfrfle4k 1 FilEtiegliging*tadea3Wg dtiaat 37
149. WHEREFORE, Plaintiff demands judgment against Defendant, Nautilus, Inc., for
compensatory and general damages, attorney's fees pursuant to 18 U.S.C. §1595, forfeiture of
Defendant's assets, 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 XII
(CAUSE OF ACTION AGAINST CYPRESS, INC. PURSUANT TO 18 U.S.C. §1595)
150. Plaintiff adopts and realleges paragraphs 1 through 57 above.
151. Defendant, by and through its management and personnel, 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, obtained, maintained, patronized, solicited by any means Plaintiff.
152. 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 doing so, Defendant corporation
violated 18 U.S.C. §1591.
153. Defendant, by and through its management and personnel 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, Defendant
corporation violated 18 U.S.C. §1593A.
154. Furthermore, Defendant corporation attempted to violate 18 U.S.C. §1591. In so
doing, Defendant violated 18 U.S.C. §1594(a).
Page 30 of 34
EFTA02738088
caseA:49:92igaralkii6FRPcbcFpcodeumt4ft1 (Waal 37
155. Defendant, by and through its management and personnel, conspired with other
members of the enterprise, and with other persons and companies, known and unknown, to
violate 18 U.S.C. §1591. In so doing, Defendant violated 18 U.S.C. § 1594(c).
156. By virtue of their violations of 18 U.S.C. §§ 1591, 1593A, and 1594, Defendant is
subject to civil causes of action under 18 U.S.C. §1595 by Plaintiff, who is a victim of their
violations.
157. Defendant, by and through its management and personnel, participated in a
venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
a commercial sex act.
158. As a direct and proximate result of Defendant corporation's commission of the
aforementioned criminal offenses enumerated in 18 U.S.C. §§ 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, emotional distress, psychological and psychiatric 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 Defendant's actions.
159. 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 continue to do so in the future for
which Defendant is liable pursuant to 18 U.S.C. §I595.
160. WHEREFORE, Plaintiff demands judgment against Defendant, Cypress, Inc., for
compensatory and general damages, attorney's fees pursuant to 18 U.S.C. §1595, forfeiture of
Page 31 of 34
EFTA02738089
Cavg49.1104461§0i6FRPcbCPcnItillititii311 RI tleittfing*.adiaiNg ai33211 37
Defendant's assets, 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 July.
COUNT XIII
(CAUSE OF ACTION AGAINST JEGE, INC. PURSUANT TO 18 U.S.C. §1595)
161. Plaintiff adopts and realleges paragraphs I through 57 above.
162. Defendant, by and through its management and personnel, 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, obtained, maintained, patronized, solicited by any means Plaintiff from
2001 through 2006.
163. 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 doing so, Defendant corporation
violated 18 U.S.C. §1591.
164. Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 1591. In so
doing, violated 18 U.S.C. § 1594(a).
165. Defendant, by and through its management and personnel, conspired with other
members of the enterprise, and with other persons and companies, known and unknown, to
violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 U.S.C. § 1594(c).
166. By virtue of its violations of 18 U.S.C. §§ 1591, 1593A, and 1594, Defendant is
subject to civil causes of action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of their
violations.
Page 32 of 34
EFTA02738090
casgabd 9.-TeJ49/44eif6-EPALebcrocotiEnivrA4e1.1 RIE*.ibXfing*.atfeagig ditqf 37
167. Defendant, by and through its management and personnel, participated in a
venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
a commercial sex act.
168. As a direct and proximate result of Defendant corporation's commission of the
aforementioned criminal offenses enumerated in 18 U.S.C. §§ 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, emotional distress, psychological and psychiatric 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 Defendant's actions.
169. 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 continue to do so in the future for
which Defendant is liable pursuant to 18 U.S.C. *1595.
WHEREFORE, Plaintiff demands judgment against JEGE, INC. for compensatory and
general damages, attorney's fees pursuant to 18 U.S.C. *1595, forfeiture of Defendant's assets,
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: October 17, 2019
Respectfully Submitted,
By: /s/ Andrew S. Buzin
Andrew S. Buzin
BUZIN LAW, P.C.
III Broadway, Suite 1204
New York, NY 10006
Tel: ([Phone Redacted]
Page 33 of 34
EFTA02738091
Casgabd a-T449/4063A-EFM-bc FootiEreffineatGi1 Fithtlerbginvil9padLlassedt534/ 37
Fax: ([Phone Redacted]
Email: [Email Redacted]
Attorney for Plaintiff
By: /s/ David H. Brodie
David H. Brodie, Esq., FBN 0813168
Laura J. Starr, Esq., FBN 0491888
WEISMAN, BRODIE, STARR
& MARGOLIES, P.A.
1301 N. Federal Highway
Lake Worth, FL 33460
Telephone: ([Phone Redacted]
Facsimile: ([Phone Redacted]
Email: [Email Redacted]
Email: [Email Redacted]
Attorneys for Plaintiff
(SEEKING ADMISSION PRO HAC VICE)
Page 34 of 34
EFTA02738092
Castae*WARAMIWPACMCPMelftflhaPili EMI@ Piipei 37
Exhibit A
EFTA02738093
Casealg 9V21049$69EFMEPACtCPcgtitrifffibaOili fril@d 1W2Mg PEINE2V 2f 37
Ilaal zna-tivar.a, t U.S. v. Jeffrey Epstein, 19-cr-490 (RMB)
ASSET SUMMARY - JUNE 30, 2019
6/30/19
Asset Value
Cash $ 56,547,773
' Fixed Income $ 14,304,679
* Equities $ 112,679,138
* Hedge Funds & Private Equity $ 194,986,301
** Properties
*** 9 East 71st Street, New York, NY 10021 $ 55,931,000
49 ZOIM Ranch Road, Stanley New Mexico 87056 $ 17,246,208
358 El Brillo Way, Palm Beach, FL 33480 $ 12,380,209
22 Avenue Foch, Paris France 75116 $ 8,672,823
Great St James Island No. 6A USVI 00802 (parcels A,B,C) $ 22,498,600
**** Little St James Island No. 6B USVI 00802 (parcels Ara,C) $ 63,874,223
Total Assets $ 559,120,954
" Values reflect gross numbers that are not net of tax
a All properties are valued at assessed values as per the most recent
property tax bills
*** Note the United States Attorney's office for the Southern District of New York
has stated that the value of this home is $77,000,000 as compared to the
market value shown above per the June 1, 2019 property tax bill
I
**** Note this property is valued at cost basis, however the assessment on
the most recent tax bill is $4,857,500 I
EFTA02738094