EPSTEIN
page 3 / 36 . OCR, unverified
was first lured into Defendant's sexually exploitative world in or about January 2004. Plaintiff
was recruited while at work by a co-worker, one of the minor victims Defendant paid to procure
underage females. Plaintiff went to Defendant's Palm Beach mansion accompanied by this co-
worker. Upon arriving, Plaintiff was led by one of Defendant's assistants up a flight of stairs to a
spa room with a shower and a massage table. Defendant entered this room wearing only a towel.
Defendant suddenly removed his towel, exposing his naked body, and then lay on the massage
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 6 of 19
table. Defendant told Plaintiff to massage his back and take off her clothing, which she refused
to do. Defendant then began to try to touch the minor Plaintiff and/or take off her clothing.
After Defendant's relentless pawing, she reluctantly removed some of her clothing. During this
encounter, Defendant turned over on his back and fondled Plaintiffs breasts, despite her
repeatedly telling him not to do so. As Plaintiff massaged Defendant, Defendant proceeded to
masturbate until ejaculation. Defendant then paid Plaintiff two hundred dollars, and Plaintiff
was escorted out of Defendant's mansion and left Defendant's property.
18.
A similar pattern of grooming continued, and the sexual exploitation
progressively escalated, over the course of approximately seventeen months during which
Defendant would often travel to Palm Beach. Prior to arriving and wf·,ile in Palm Beach,
Defendant and/or his agent(s) would frequently call Plaintiff at her home telephone number
and/or other telephone numbers, arranging for encounters with her for Defendant, sometimes
twice daily. While usually such contacts were made by his assistants, Defendant personally
called Plaintiff repeatedly, despite being told to leave Plaintiff alone. After the first few
encounters, Defendant coerced Plaintiff to remove all her clothing, and Defendant penetrated the
minor Plaintiffs vagina digitally. Defendant sexually abused and/or battered and/or exploited
Plaintiff at least a hundred times between approximately January 2004 and May 2005. Such
exploitation included, but was not limited to, Defendant's sexual abuse and battery of Plaintiff
with vibrator(s), back massager(s), his finger(s), and his penis. At times, Defendant manipulated
Plaintiff to interact sexually with another female. During one encounter, Dt!fendant penetrated
the minor Plaintiffs vagina with his penis, all the while narrating and demonstrating his sexual
battery of Plaintiff to another female present in the room. While some of the precise dates that
Defendant's acts of sexual exploitation occurred are unknown to Plaintiff, these dates are known
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 7 of 19
to Defendant, as he and/or his assistants kept written records, some of which are in the custody
of law enforcement, of each instance in which he committed lewd acts upon minor girls,
including the then minor Plaintiff.
19.
Defendant's preference for underage girls was well-known to those who regularly
procured them for him. The above-described acts of abuse began to occur during a time when
Defendant knew that Plaintiff was a minor. Defendant, at all times material to this cause of
action, knew and/or should have known of Plaintiff's age of minority. In fact, Defendant
repeatedly urged the minor Plaintiff to become legally emancipated in order to accompany him
as he traveled, both nationally and internationally. Additionally, Defendant, knowing that
Plaintiff was merely seventeen years old, lured her by inviting her to stay with him at his
mansion in Manhattan and arranging and/or paying for airplane tickets, theater tickets, and a
personal chauffeur as gifts for her upcoming birthday.
20.
As part of Defendant's persistent process of grooming Plaintiff and immersing her
in his lewd and abusive lifestyle, Defendant regularly showered the adoL~3cent Plaintiff with
gifts, including, but not limited to lingerie, flowers, bikini bathing suit(s), art book(s), purse(s),
envelopes of U.S. currency, use of a car, and/or other accoutrements.
21.
Defendant possessed photographs of nude underage girls, some of which may
have been taken with hidden cameras set up in his residence in Palm Beach. On the day of
Defendant's arrest, police found two hidden cameras and photographs of underage girls in
Defendant's mansion. Defendant took lewd photographs of Plaintiff with his hidden cameras
and transported lewd photographs of Plaintiff and other victims elsewhere using a facility or