EPSTEIN
page 6 / 67 . OCR, unverified
sexually abuse and exploit, JEFFREY EPSTEIN, … worked and conspired with others, including
employees and associates who facilitated his conduct by, among other things, contacting victims
and scheduling their sexual encounters with EPSTEIN at the New York Residence and at the Palm
Beach Residence.” Criminal Indictment at 2.
21.
The indictment further explained, and Plaintiff adopts and alleges, that, “[v]ictims
were initially recruited to provide ‘massages’ to Epstein, which would be performed nude or
Case 1:19-cv-11869-MKV-DCF Document 1 Filed 12/27/19 Page 4 of 14
partially nude, would become increasingly sexual in nature, and would typically include one or
more sex acts.” Criminal Indictment at 3.
22.
“Between at least in or about 2002 and in or about 2005, Epstein abused numerous
minor victims at the New York Residence by causing these victims to be recruited to engage in
paid sex acts with him.” Criminal Indictment at 3.
23.
Jeffrey Epstein received near daily massages from young females, often minors,
who were not experienced in massage. Rather than receive regular body massages, Epstein was
predictably sexually abusing the young females in violation of New York Penal Law Section 130.
24.
Jeffrey Epstein, specifically targeted underprivileged, emotionally vulnerable
and/or economically disadvantaged young females to sexually molest and abuse.
ANASTASIA DOE
25.
Minor victim ANASTASIA DOE was subjected to the types of illegal sexual acts
detailed in the Criminal Indictment filed against Jeffrey Epstein by the Southern District of New
York and adopts herein the allegations above detailed in paragraphs 8-24.
26.
Jeffrey Epstein committed acts of sexual abuse against Plaintiff from 2003 through
2008, beginning when she was 14 years old.
27.
In or about 2003, Plaintiff was recruited by another minor child to go to Jeffrey
Epstein’s mansion in Manhattan, New York to provide him with a “massage.”
28.
The minor child who recruited Plaintiff informed Plaintiff that she would be paid
$300 to provide a massage to a rich man in Manhattan.
29.
Plaintiff was a minor female with no experience or training in massage.
30.
In 2003, Plaintiff’s friend brought Plaintiff to Jeffrey Epstein’s townhouse mansion
located at 9 East 71st Street, NY to provide him with a massage.
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31.
Upon arrival to the mansion, the two minor children were escorted inside by an
employee working at the mansion up to Jeffrey Epstein’s massage room.
32.
Plaintiff’s friend entered the massage room with Plaintiff where they met Jeffrey
Epstein.
33.
Jeffrey Epstein lay down naked on the massage table and instructed Plaintiff and
her friend to remove their clothes, and both complied.
34.
Plaintiff’s friend began instructing Plaintiff how to provide Jeffrey Epstein a
massage and Plaintiff began doing as told.
35.
During the massage, Jeffrey Epstein turned over and began touching Plaintiff’s
breasts, and vagina.
36.
Jeffrey Epstein then began masturbating in front of Plaintiff while instructing
Plaintiff to pinch his nipples.
37.
Jeffrey Epstein took out a vibrator sex toy and used it forcefully on Plaintiff’s
vagina.
38.
During this first encounter, Jeffrey Epstein penetrated Plaintiff’s vagina with his
finger and the sex toy.
39.
Jeffrey Epstein continued to masturbate until ejaculation, after which he paid
Plaintiff $300.
40.
After the first encounter, Plaintiff was asked for her telephone number which was
kept by Jeffrey Epstein or one of his employees who worked at his NY mansion.
41.
Plaintiff was contacted regularly beginning in 2003 while she was 14 years old to
schedule times for her to visit the mansion and engage in sexual acts with Jeffrey Epstein in his
massage room.
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42.
Lesley Groff, one of Jeffrey Epstein’s most trusted employees, would typically call
Plaintiff to schedule a time for her to visit Jeffrey Epstein at the mansion. Other times, Plaintiff
would be called by Jeffrey Epstein directly.
43.
Beginning in 2003 through 2006, Plaintiff visited Jeffrey Epstein at his mansion on
average once per week. During each visit, Jeffrey Epstein engaged in sexual contact with Plaintiff,
which often included touching her naked breasts and vagina and using sex toys on her vagina.
44.
On numerous occasions, Jeffrey Epstein would forcibly insert his finger or sex toy
into Plaintiff’s vagina.
45.
On one occasion when Plaintiff was 15 years old, Jeffrey Epstein’s girlfriend
entered the massage room while Plaintiff was in there. Jeffrey Epstein ordered his girlfriend to
engage in oral sex with Plaintiff during that occasion, which she did by force and against Plaintiff’s
will and consent.
46.
On another occasion, when Plaintiff was 16 years old, Jeffrey Epstein engaged in