EPSTEIN
page 4 / 31 . OCR, unverified
)
'
then minor Plaintiff and other minor girls, some as young as 14 years old, were
transported to Defendant's Palm Beach mansion by Defendant's employees, agents,
and/or assistants in order to provide Defendant with "massages."
12. Many of the instances of illegal sexual conduct committed by Defendant were perpetrated
with the assistance, support, and facilitation of at least three assistants who helped him
orchestrate this child exploitation enterprise. These assistants would arrange times for
underage girls to come to Defendant's residence, transport or cause the transportation of
underage girls to Defendant's residence, escort the underage girls to the massage room
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where Defendant would be waiting or would enter shortly thereafter, urge the underage
girls to remove their clothes, deliver cash from Defendant to the underage girls and/or
their procurers at the conclusion of each "massage appointment," and assist Defendant in
taking nude photographs and/or videos of the underage girls with and/or without their
knowledge. Defendant would pay the procurer of each girl's "appointment" hundreds of
dollars. 1
13. Defendant designed this scheme to secure a private place in Defendant's Palm Beach
mansion where only persons employed and invited by Defendant would be present, so as
to reduce the chance of detection of Defendant's sexual abuse and/or exploitation, as well
as to make it more difficult for the minor girls to flee the premises and/or to credibly
report his actions to law enforcement or other authorities. The girls were usually
transported by his employee(s), agen'.t(s), and/or assistant(s) and/or by taxicab(s) and/or
motor vehicle(s) paid for by Defendant, which also made it difficult for the girls to flee
his mansion.
14. Upon her initial arrival at Defendant's Palm Beach mansion, each underage victim would
generally be introduced to one of Defendant's assistants, who would gather the girl's
personal contact information. The minor girl w<;mld be led up a remote flight of stairs to a
room that contained a massage table and a large shower.
15. At times, if it was the girl's first "massage" appointment, another female would be in the
room to "lyad the way." Generally the other female would leave, or Defendant would
dismiss her. Often, Defendant would start his massage wearing only a small towel, which
eventually would be removed. Defendant and/or the other female would direct the girl to
massage him, giving the minor girl specific instructions as to where and how he wanted
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to be touched, and then direct her to remove her clothing. Defendant would then perform
one or more lewd, lascivious, and sexual acts, including masturbation; fondling the
minor's breasts and/or sexual organs; touching the minor's vulva, vagina, and/or anus
with a vibrator, back massager, his finger(s), and/or his penis; digitally penetrating her
vagina; performing intercourse, oral sex, and/or anal sex; and/or coercing or attempting to
coerce the girl to engage in lewd acts and/or prostitution and/or enticing the then minor
girls to engage in sexual acts with another female in Defendant's presence. The exact
degree of the molestation and frequency with which the sexual exploitations took placed
, varied and is not yet completely known; however, Defendant committed such acts
regularly on a daily basis and, in most instances, severalrtimes a day. In order to facilitate
the daily exchanges of money for sexual assault and abuse, Defendant kept U.S. currency
readily available.
16. Defendant was particularly skillful at discerning his minor victims' respective hopes,
dreams, and ambitions. As he did with many of his victims, Defendant and his associates
lured Plaintiff early-on with modeling opportunities, impressing her with his modeling
business and contacts with supermodels, indicating that they could help her with a
modeling career.
17. Consistent with the foregoing plan and scheme, Defendant used his money, wealth and
power to unduly and improperly manipulate and influence the then minor Plaintiff.
18. Plaintiff originally was introduced to Defendant whim-she was fifteen (15}years old. She
was approached by a friend of hers in High School, who was also a victim of Epstein's
scheme.
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19. Plaintiff was originally told that she would be going to Defendant's home to for a
potential modeling job. Plaintiff went to Defendant's Palm Beach mansion accompanied
by this other victim of Defendant. Upon arriving, Plaintiff~as led up a flight of stairs to
a room with a shower and a massage table. Defendant entered the room, instructed
Plaintiff to massage him and proceeded to sexually molest the then minor Plaintiff.