EPSTEIN
page 2 / 36 . OCR, unverified
years old, were transported to Defendant's Palm Beach mansion by Defondant'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, escmi the underage girls to the massage room 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
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 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 4 of 19
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.
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),
agent(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 mans10n, 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 would 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 "lead 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 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
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 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 5 of 19
prostitution and/or enticing the then minor girl to engage in sexual acts with another female in
Defendant's presence. The exact degree of molestation and frequency with which the sexual
exploitations took place varied and is not yet completely known; however, Defendant committed
such acts regularly on a daily basis and, in most instances, several times 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 traveled out of Florida to Palm Beach for the purpose of luring
minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to contact
these minor girls for the purpose of coercing them into acts of prostitution and to enable himself
to commit sexual battery against them and/or acts of lewdness in their presence, and he conspired
with others, including his employee(s), assistant(s), driver(s), pilot(s), and/or agent(s), to
facilitate these acts and to avoid police detection. Defendant's systematic pattern of sexually
exploitative behavior described above also occurred in Defendant's other domestic and/or
international residences, places oflodging, and/or modes of transportation.
17.
Consistent with the foregoing plan and scheme, Defend.ant used his money,
wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff.
A vulnerable young girl, Plaintiff was merely a seventeen year old high school student when she
was first lured into Defendant's sexually exploitative world in or about January 2004. Plaintiff