EPSTEIN
page 4 / 155 . OCR, unverified
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.
Jane Doe 1000
37.
Jane Doe 1000 grew up in extreme poverty. At various times throughout her childhood,
her mother had been homeless. Jane Doe was unable to enroll in high school because she did not
have a residence and often lived without running water or electricity.
38.
In late 1999, Jane Doe made a modeling appearance. A man called her and told her that
Jeffrey Epstein had connections to various modeling jobs and asked her if she would like to meet
with Epstein to discuss opportunities. The opportunity sounded enticing to Jane Doe, so she
agreed and met Epstein at his New York City mansion on 71st Street.
39.
Upon meeting Jane Doe, Epstein offered her a position modeling with Victoria’s Secret, a
lingerie retailer. He explained that he was friends with Les Wexner, the chief executive of
Case 1:19-cv-10577 Document 1 Filed 11/14/19 Page 9 of 14
Victoria’s Secret’s parent company. Epstein reiterated his connection to Victoria’s Secret each
time he saw and spoke with Jane Doe.
40.
Eventually, Epstein moved Jane Doe into his apartment building on 66th Street, where he
housed other models and young women that he sexually abused, so that he could have complete
control over her life. Her relationship with Epstein quickly turned into one of sexual abuse.
Ghislaine Maxwell, one of Epstein’s main “recruiters,” along with additional unidentified
co-conspirators, would call Jane Doe and direct her to go to Epstein’s mansion to give him a
massage. The massages quickly escalated into Epstein forcing himself on Jane Doe against her
will and engaging in one or more sex act with her for his own sexual gratification. Jane Doe was
terrified of Epstein, who repeatedly threatened her and made representations about his wealth,
power, and connections.
41.
During Jane Doe’s time with Epstein, he forced her to give him sexual massages and
made her use sex toys.
42.
Epstein also flew Jane Doe to his residence in Palm Beach, Florida, where she was also
forced to give Epstein sexual massages.
43.
On one occasion, Epstein forced Jane Doe to meet with a lawyer, even though she did not
express any need for a lawyer to Epstein. The lawyer she met with was a prominent attorney and
a law professor who was described to Jane Doe as Epstein’s close friend and lawyer. The
lawyer appeared to be interviewing her, asking personal questions about her family’s financial
situation. The meeting had no legal purpose, and Epstein later used the information that the
lawyer had obtained through his meeting with Jane Doe to intimidate her and to keep her
compliant in his sex-trafficking scheme.
Case 1:19-cv-10577 Document 1 Filed 11/14/19 Page 10 of 14
44.
Epstein made very clear to Jane Doe 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 Jane Doe did not
comply with his demands.
45.
Epstein constantly promised Jane Doe modeling opportunities with Victoria’s Secret each
time she saw him. He continued to make that promise for years, up until the last time Jane Doe
saw Epstein.
46.
One day, Epstein had someone call Jane Doe to his mansion. When Jane Doe arrived,
Maxwell was waiting for her and led her upstairs to Epstein’s master bedroom. When they got to
the bedroom, sex toys were laid out on the bed. Epstein and Maxwell proceeded to sexually
assault Jane Doe simultaneously and by forcible compulsion. Maxwell forcibly penetrated Jane
Doe with a sex toy. She was horrified and terrified by the experience and knew she had to try to
get away from Epstein even though she risked harm to herself by disobeying Epstein. She
proceeded to move out of the 66th Street apartment building and, having nowhere else to go,
found shelter at the Salvation Army housing facility.
47.
Jane Doe was deeply affected by her harrowing experiences at the hands of Epstein. She
suffers extreme emotional distress from an experience that has affected her for her entire life.
48.
Epstein’s sexual assault and battery of Jane Doe continues to cause her significant