EPSTEIN
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at a time, sometimes staying in his New York apartment. Epstein never introduced Juliette to a
modeling agent, and she was never hired for a modeling job.
47.
For those years, Juliette felt like a prisoner and was afraid of betraying Epstein because of
his money and power. She was afraid he would hurt her or her family. In fact, the very first time
Epstein brought Juliette to the United States, in order to scare her, he told her that when another
woman had accused him of rape, he planted drugs in the woman’s apartment and had her sent to
prison.
48.
Epstein made very clear to Juliette that he was incredibly wealthy, powerful, and
regularly in contact with world leaders. In fact, in his New York mansion he had photographs
displayed of significant political figures to ensure that any young female entering the home
would know that he had extensive government connections. Epstein was not to be disobeyed and
he made clear by his words and actions that there would be consequences if Juliette did not
comply with his demands.
49.
Juliette was also forced to travel to Epstein’s home in Paris where she had to stay with
Ghislaine Maxwell, one of Epstein’s main recruiters of young females, and where Sarah Kellen
forced her to be photographed nude for Epstein. During that trip, Juliette witnessed that young
females were on call to sexually pleasure Epstein.
50.
Juliette’s final trip to the United States was in 2004. She flew to see Epstein at his New
Mexico ranch, called “Zorro Ranch.” Epstein abused Juliette at Zorro Ranch. During that trip,
Epstein took Juliette with him to meet another important government official. Juliette complied
and went with Epstein. At the meeting, Juliette believed that Epstein had brought her there so
that the official could look her over. Juliette felt very uncomfortable and she and Epstein began
to fight because he claimed she was not being obedient. Epstein then informed Juliette that he
Case 1:19-cv-10479-ALC-DCF Document 1 Filed 11/14/19 Page 12 of 16
wanted her to travel with him on his plane to California and serve drinks to some of his scientist
friends who were going to be flying with him to California. But before the flight, after an
argument with Epstein, Juliette flew home to South Africa. This was the last time Juliette visited
Epstein.
51.
Epstein attempted to keep in contact with Juliette through e-mail over the years. For
example, in 2016, Epstein e-mailed Juliette to ask if she knew Sarah Ransome, another woman
who was a victim of Epstein’s sex trafficking scheme. In June 2019, only two months before his
death, Epstein sent Juliette an e-mail asking her to send him nude photographs.
52.
Juliette was deeply affected by her harrowing experiences at the hands of Epstein. She
developed eating disorders that affected her for years afterwards. She also suffered from
substance abuse, debilitating panic attacks, and severe anxiety.
53.
Epstein’s sexual assault and battery of Juliette continues to cause her significant distress
and harm.
FIRST CAUSE OF ACTION
(Battery)
54.
Plaintiff repeats and re-alleges the allegations stated above in paragraphs 1–53 as if fully
set forth herein.
55.
Epstein intentionally committed battery by sexually assaulting Plaintiff on numerous
occasions at his homes in New York, New Mexico, Florida, France, and the U.S. Virgin Islands.
As described above, on multiple occasions over a years-long period, Epstein raped Plaintiff and
intentionally touched intimate parts of her body in an offensive and sexual manner without her
consent.
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56.
Epstein’s actions constitute sexual offenses as defined in New York Penal Law Article
130, including but not limited to rape in the first degree as defined in Article 130.35, inasmuch as
Epstein engaged in sexual intercourse with Plaintiff by forcible compulsion. See N.Y. C.P.L.R.
§ 213-C.
57.
A criminal action against Epstein with respect to the same sex trafficking enterprise from
which Plaintiff’s first cause of action arises was terminated on August 29, 2019, less than one
year prior to the filing of this Complaint. See N.Y. C.P.L.R. § 215(8)(a).
58.
As a direct and proximate result of Epstein’s conduct, Plaintiff has in the past and will in
the future continue to suffer extreme emotional distress, humiliation, fear, anxiety, panic attacks,
psychological trauma, loss of dignity and self-esteem, and invasion of her privacy.
SECOND CAUSE OF ACTION
(Intentional Infliction of Emotional Distress)
59.
Plaintiff repeats and re-alleges the allegations stated above in paragraphs 1–53 as if fully
set forth herein.
60.
As a direct result of these allegations as stated, Epstein committed intentional infliction of
emotional distress against Plaintiff.