EPSTEIN
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my last illness, my funeral and burial expenses, the administration expenses of my estate and all
of my debts duly proven and allowed against my estate.” The Will further directs that “after the
payments and distributions provided in Article FIRST,” Epstein “give[s] all of my property, real
and personal, wherever situated . . . to the then acting Trustees of The 1953 Trust.”
36.
Following Epstein’s death, SDNY submitted a proposed nolle prosequi order in the
criminal matter against him because it was required by law to do so after Epstein was deceased.
On August 29, 2019, U.S. District Judge Richard Berman formally dismissed SDNY’s
indictment against Epstein, terminating the criminal action against him. Plaintiff’s claims are
therefore timely under N.Y. C.P.L.R. § 215(8)(a).
C.
Juliette Bryant
37.
Plaintiff Juliette Bryant was born on July 23, 1982, in South Africa.
38.
In 2002, Juliette was 20 years old and an aspiring model. In Cape Town, Naja Hill, an
American model, approached Juliette in an attempt to befriend her. Hill asked Juliette if she
would like to meet Epstein, who she called the “King of America.” Hill described Epstein as a
well-connected billionaire who could help her with her modeling career and explained that he
was visiting Africa with a former high U.S. Government official, a famous actor, and a
well- known comedian.
Case 1:19-cv-10479-ALC-DCF Document 1 Filed 11/14/19 Page 9 of 16
39.
Juliette considered meeting Epstein an amazing opportunity because modeling in New
York City had always been one of her biggest dreams. Hill brought Juliette to a restaurant to
meet Epstein, who at the time was dining with the former high U.S. Government official, the
famous actor, and the well-known comedian. Juliette had never met a celebrity before. She was
invited to attend a speech the former high U.S. Government official was giving in Cape Town
the next day, and was escorted to the speech by police cars with individuals associated with the
former official.
40.
Later, Epstein asked Juliette to bring her modeling portfolio to his hotel for “casting.”
Epstein told Juliette that he owned a modeling agency and would get her an agent in New York.
He also mentioned that his good friend, Les Wexner, owned Victoria’s Secret, a lingerie
conglomerate.
41.
Within a few days, Leslie Groff began calling Juliette. Groff told Juliette that Epstein
wanted to bring her to New York City to model. Groff, who was in New York at the time,
helped Juliette get a visa, passport, and airline tickets. It was Juliette’s first time traveling
overseas, so she was nervous. Epstein called Juliette’s mother from New York to assure her that
Juliette would be safe with him in New York.
42.
Within two weeks, Juliette arrived in New York. A car picked her up from the airport
and brought her to an apartment building on 66th Street, where Epstein housed some of the other
models who he was abusing. But Juliette was not there for long. Shortly after arriving at the
apartment, Sarah Kellen, another one of Epstein’s co-conspirators, called and told Juliette that
Juliette was going to the Caribbean. Juliette did not understand why she was traveling to the
Caribbean so soon after arriving in New York City, but hoped it was for a modeling job.
Case 1:19-cv-10479-ALC-DCF Document 1 Filed 11/14/19 Page 10 of 16
43.
Juliette was taken on Epstein’s private plane. During the flight, Epstein began sexually
touching Juliette’s leg. She felt trapped and terrified, and feared that she would be killed.
44.
They arrived at Epstein’s home in the Virgin Islands. Epstein’s abuse of Juliette there
began when Kellen sent Juliette to Epstein’s room to massage him. For the rest of the trip,
Epstein repeatedly raped Juliette by forcible compulsion. Kellen repeatedly sent Juliette to
Epstein’s room, where he would touch her, use massage devices on her, force her to perform oral
sex on him, and sexually force himself on her. Juliette also witnessed another young girl
performing oral sex on Epstein in front of Juliette while they were watching a movie. Juliette
was terrified of Epstein and his power. No one knew where she was and she believed that if
anything happened to her, no one would ever know.
45.
Instead of fulfilling her dreams of becoming a model in New York City, Juliette was
subject to extreme and repeated sexual abuse. Epstein’s sexual abuse of Juliette was humiliating
and degrading, and caused Juliette to cry herself to sleep each night. She felt trapped and alone
on Epstein’s private island. Juliette learned very quickly that Epstein was incredibly powerful
and that she should not disobey his demands.
46.
Epstein’s abuse of Juliette lasted for years. Epstein forced her to travel to the United
States many times to see Epstein and be subjected to repeated sexual abuse for one to two weeks