EPSTEIN
page 5 / 155 . OCR, unverified
distress and harm.
Case 1:19-cv-10577 Document 1 Filed 11/14/19 Page 11 of 14
FIRST CAUSE OF ACTION
(Battery)
49.
Plaintiff repeats and re-alleges the allegations stated above in paragraphs 1–48 as if fully
set forth herein.
50.
Epstein intentionally committed battery by sexually assaulting Plaintiff when she was a
young woman. As described above, on multiple occasions, Epstein intentionally sexually
assaulted and touched Plaintiff in an offensive and sexual manner without her consent.
51.
Epstein’s actions constitute sexual offenses as defined in New York Penal Law Article
130, including but not limited to Article 130.35, inasmuch as Epstein and Maxwell sexually
assaulted Plaintiff by forcible compulsion within 20 years of filing this Complaint. See N.Y.
C.P.L.R. § 213-C.
52.
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).
53.
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, psychological trauma,
loss of dignity and self-esteem, and invasion of her privacy.
SECOND CAUSE OF ACTION
(Intentional Infliction of Emotional Distress)
54.
Plaintiff repeats and re-alleges the allegations stated above in paragraphs 1–48 as if fully
set forth herein.
55.
As a direct result of these allegations as stated, Epstein committed intentional infliction of
emotional distress against Plaintiff.
Case 1:19-cv-10577 Document 1 Filed 11/14/19 Page 12 of 14
56.
Epstein’s actions, described above, constitute extreme and outrageous conduct that
shocks the conscience. Epstein’s plan to recruit, entice, and assault Plaintiff on multiple
occasions goes beyond all possible bounds of decency and is intolerable in a civilized
community.
57.
Epstein knew or disregarded the substantial likelihood that these actions would cause
Plaintiff severe emotional distress.
58.
A criminal action against Epstein with respect to the same sex trafficking enterprise from
which Plaintiff’s second 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).
59.
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, psychological trauma,
loss of dignity and self-esteem, and invasion of her privacy.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests judgment against Defendants, awarding
compensatory, consequential, exemplary, and punitive damages in an amount to be determined at
trial; costs of suit; attorneys’ fees; and such other and further relief as the Court may deem just
and proper.
JURY DEMAND
Plaintiff hereby demands a trial by jury on all causes of action asserted within this
pleading.
Case 1:19-cv-10577 Document 1 Filed 11/14/19 Page 13 of 14
Dated: November 14, 2019.
/s/ Joshua I. Schiller
David Boies
BOIES SCHILLER FLEXNER LLP
333 Main Street
Armonk, NY 10504
(914) 749-8200
Joshua I. Schiller
BOIES SCHILLER FLEXNER LLP
Hudson Yards
New York, NY 10001
(212) 446-2300
Sigrid McCawley
(Pro Hac Vice Pending)
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
(954) 356-0011
Case 1:19-cv-10577 Document 1 Filed 11/14/19 Page 14 of 14
Case 1:19-cv-10577 Document 1-1 Filed 11/14/19 Page 1 of 15
EXHIBIT A
Case 1:19-cv-10577 Document 1-1 Filed 11/14/19 Page 2 of 15
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
- v. -
X
SEALED
INDICTMENT
Cr.
JEFFREY EPSTEIN,
Defendant.
X
COUNT ONE
(Sex Trafficking Conspiracy)
The Grand Jury charges:
OVERVIEW
1.
As set forth herein, over the course of many
years, JEFFREY EPSTEIN, the defendant, sexually exploited and ·
abused dozens of minor girls at his homes in Manhattan, New
York, and Palm Beach, Florida, among other locations.
2.
In particular, from at least in or about 2002, up
to and including at least in or about 2005, JEFFREY EPSTEIN, the
defendant, enticed and recruited, and caused to be enticed and
recruited, minor girls to visit his mansion in Manhattan, New
York (the "New York Residence") and his estate in Palm Beach,
Florida (the "Palm Beach Residence") to engage in sex acts with
him, after which he would give the victims hundreds of dollars
.in cash.
Moreover, and in order to maintain and increase his
supply of victims, EPSTEIN also paid certain of his victims to
recruit additional girls to be similarly abused by EPSTEIN.
In
Case 1:19-cv-10577 Document 1-1 Filed 11/14/19 Page 3 of 15
this way, EPSTEIN created a vast network of underage victims for