EPSTEIN
page 3 / 129 . OCR, unverified
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.
A vulnerable young girl, Plaintiff was working as a changing room assistant at The Mar-A-Lago
Club in Palm Beach making approximately $9 an hour when she was first lured into Defendant's
sexually exploitative world. In or about the summer of 1998, when Plaintiff was merely fifteen
years old while attending to her duties at Mar-A-Lago, Plaintiff was recruited by Ghislaine
Maxwell, who lived, traveled, socialized, and worked with Defendant. Ms. Maxwell asked
Plaintiff if she was interested in learning massage therapy and earning a great deal of money
while learning the profession. Plaintiffs father, who was a maintenance manager at The Mar-A-
Podhurst Orseck, P.A.
West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
www.podhurst.com
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 6 of 27
Lago Club, was not apprehensive because he felt comforted that an older woman had approached
Plaintiff with this opportunity. As a result, Plaintiffs father dropped off Plaintiff at Defendant's
mansion that same day. Ms. Maxwell met Plaintiff and her father outside of Defendant's Palm
Beach mansion, where Ms. Maxwell assured the minor girl's father that Ms. Maxwell would
provide transportation home for his teenaged daughter. Ghislaine Maxwell led Plaintiff up a
flight of stairs to a spa room with a shower and a massage table. Defendant was lying naked on
the massage table. Plaintiff was shocked, but, with no experience with massages, thought this
could be massage therapy protocol. Ms. Maxwell then took off her own shirt and left on her
underwear and started rubbing her breasts across Defendant's body, impliedly showing Plaintiff
what she was expected to do. Ms. Maxwell then told Plaintiff to take off her clothes. The minor
girl was apprehensive about doing this, but, in fear, proceeded to follow Ms. Maxwell by
removing everything but her underwear. She was then ordered to remove her underwear and to
straddle Defendant.
The encounter escalated, with Defendant and Ms. Maxwell sexually
assaulting, battering, exploiting, and abusing Plaintiff in various ways and in various locations,
including the steam room and shower. At the end of this sexually exploitive abuse, Defendant
and Ms. Maxwell giddily told Plaintiff to return the following day and told her she had "lots of
potential." Defendant paid Plaintiff hundreds of dollars, told her it was for two hours of work,
and directed one of his employees to drive her home.
18.
Defendant and/or his procurers thereafter lured the then minor Plaintiff to his
Palm Beach mansion every day for the next two weeks in order to engage in a similar pattern of
sexual exploitation. Defendant and/or his procurers arranged at the end of each incident the
transportation and scheduling for the following day's appointment. Additionally, Defendant
telephoned the minor Plaintiff himself and/or had Ms. Maxwell telephone Plaintiff to make
arrangements.
Plaintiff was often times driven to and from Epstein's mansion by Epstein
Podhurst Orseck, P.A.
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 7 of 27
himself or his driver. Alternatively, Defendant or Ms. Maxwell would arrange and pay for
Plaintiffs transportation home by taxicab.
19.
During Plaintiffs second incident of being sexually exploited and assaulted by
Defendant at Defendant's Palm Beach mansion, Defendant asked Plaintiff to quit her job at The
Mar-A-Lago Club and travel with him to earn much more money while learning the massage
profession. Thus, Plaintiff, an impressionable and vulnerable young girl of modest means, quit
her job as a changing room assistant, was lured by Defendant, and continued to be victimized by
Defendant, who immersed the minor Plaintiff into Defendant's lewd and abusive lifestyle.
Under Defendant's dominion and control, Defendant continuously "groomed" the minor
adolescent.
Defendant's daily routine required the minor Plaintiff to perform sexually on
Defendant multiple times per day and to provide Defendant massages multiple times per day.
Plaintiff had absolutely no say as to when, how many times, or what was done during each
sexual encounter. Often, Plaintiff was joined by Ms. Maxwell, Ms. Maxwell's assistant, and/or a
countless array of young women who would be brought to one of Defendant's homes for the
sexual trysts and then be sexually exploited by Defendant.
20.
The first time that Defendant transported Plaintiff to another state in order to
engage in sexual acts with her occurred when she was merely fifteen years old and after only two
weeks of daily sexually abusive encounters with Defendant. Defendant used his private jet to
transport the minor Plaintiff to Manhattan, where he provided her with spending money and