EPSTEIN
page 2 / 67 . OCR, unverified
genitals.
EPSTEIN typically would also masturbate during these
sexualized encounters, ask victims to touch him while he
masturbated, and touch victims' genitals with his hands or with
sex toys.
10.
In connection with each sexual encounter, JEFFREY
EPSTEIN, the defendant, or one of his employees or associates,
paid the victim in cash.
Victims typically were paid hundreds
of dollars in cash for each encounter.
11.
JEFFREY EPSTEIN, the defendant, knew that many of
his New York victims were underage, including because certain
victims told him their age.
Further, once these minor victims
were recruited, many were abused by EPSTEIN on multiple
subsequent occasioni at the New York Residence.
EPSTEIN
sometimes personally contacted victims to schedule appointments
at the New York Residence.
In other instances, EPSTEIN directed
Case 1:19-cv-11869-MKV-DCF Document 1-1 Filed 12/27/19 Page 6 of 15
employees and associates, including a New York-based employee
("Employee-1"), to communicate with victims via phone to arrange
for these victims to return to the New York Residence for
additional sexual encounters with EPSTEIN.
12.
Additionally, and to further facilitate his
ability to abuse minor girls in New York, JEFFREY EPSTEIN, the
defendant, asked and enticed certain of his victims to recruit
additional girls to perform "massages" and similarly engage in
sex acts with EPSTEIN.
When a victim would recruit another girl
for EPSTEIN, he paid both the victim-recruiter and the new
victim hundreds of dollars in cash.
Through these victim-
recruiters, EPSTEIN gained access to and was able to abuse
dozens of additional minor girls.
13.
In particular, certain recruiters brought dozens
of additional minor girls to the New York Residence to give
massages to and engage in sex acts with JEFFREY EPSTEIN, the
defendant.
EPSTEIN encouraged victims to recruit additional
girls by offering to pay these victim-recruiters for every
additional girl they brought to EPSTEIN.
When a victim-
recruiter accompanied a new minor victim to the New York
Residence, both the victim-recruiter and the new minor victim
were paid hundreds of dollars by EPSTEIN for each encounter.
In
addition, certain victim-recruiters routinely scheduled these
Case 1:19-cv-11869-MKV-DCF Document 1-1 Filed 12/27/19 Page 7 of 15
encounters through Employee-1, who sometimes asked the
recruite~s to bring a specific minor girl fo~ EPSTEIN.
The Palm Beach Residence
14.
In addition to recruiting and abusing minor girls
in New York, JEFFREY EPSTEIN, the defendant, created a similar
network of minor girls to victimize in Palm Beach, Florida,
where EPSTEIN owned, possessed and controlled another large
residence, i.e., the Palm Beach Residence.
EPSTEIN frequently
traveled from New York to Palm Beach by private jet, before
which an employee or associate would ensure that minor victims
were available for encounters upon his arrival in Florida.
15.
At the Palm Beach Residence, JEFFREY EPSTEIN, the
defendant, engaged in a similar course of abusive conduct.
When a victim initially arrived at the Palm Beach Residence, she
would be escorted to a room, sometimes by an employee of
EPSTEIN's, including, at times, two assistants ("Employee-2" and'
"Employee-3") who, as described herein, were also responsible
for scheduling sexual encounters with minor victims.
Once
inside, the victim would provide a nude or semi-nude massage for
EPSTEIN, who would himself typically be naked.
During these
encounters, EPSTEIN would escalate the nature and scope of the
physical contact to include sex acts such as groping and direct
and indirect contact with the victim's genitals.
EPSTEIN would
also typically masturbate during these encounters, ask victims
Case 1:19-cv-11869-MKV-DCF Document 1-1 Filed 12/27/19 Page 8 of 15
to touch him while he masturbated, and touch victims' genitals
with his hands or with sex toys.
16.
In connection with each sexual encounter, JEFFREY
EPSTEIN, the defendant, or one of his employees or associates,
paid the victim in cash.
Victims typically were paid hundreds
of dollars for each encounter.
17.
JEFFREY EPSTEIN, the defendant, knew that certain
of his victims were underage, including because certain victims
told him their age.
In addition, as with New York-based
victims, many Florida victims, once recruited, were abused by
JEFFREY EPSTEIN, the defendant, on multiple additional
occasions.
18.
JEFFREY EPSTEIN, the defendant, who during the
relevant time period was frequently in New York, would arrange
for Employee-2 or other employees to contact victims by phone in
advance of EPSTEIN's travel to Florida to ensure appointments
were scheduled for when he arrived.
In particular, in certain
instances, Employee-2 placed phone calls to minor victims in
Florida to schedule encounters at the Palm Beach Residence.
At
the time of certain of those phone calls, EPSTEIN and Employee-2