EPSTEIN
page 7 / 67 . OCR, unverified
forcible sexual intercourse with Plaintiff, and paid her $400 instead of the normal $300 after that
forcible sexual encounter.
47.
In addition to going to Jeffrey Epstein’s mansion where Jeffrey Epstein violated the
minor Plaintiff sexually, Jeffrey Epstein also encouraged Plaintiff to bring her high school friends
to him for sexual purposes as well.
48.
Jeffrey Epstein told Plaintiff he would pay her $300 for each friend she brought
him.
49.
Plaintiff did as she was instructed to do and brought Jeffrey Epstein other females
as young as 14 years old. Plaintiff was paid $300 for each she brought.
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50.
While Plaintiff was a minor child, beginning when she was 14 years old until
Plaintiff was 17 years old, Jeffrey Epstein repeatedly committed sexual acts against Plaintiff
constituting sexual offenses as defined in New York Penal Law § 130. On numerous occasions
during that period of time, Jeffrey Epstein sexually touched and penetrated Plaintiff’s vagina with
his fingers and sex toys, he masturbated in front of her, caused her to engage in sex acts with
another female, and on one occasion had sexual intercourse with Plaintiff when she was only 16
years old. All sexual acts were performed by Jeffrey Epstein intentionally and for no legitimate
purpose and for his own gratification when Plaintiff was a minor child less than seventeen years
of age.
51.
Pursuant to New York Penal Law § 130.05, a person is deemed incapable of consent
when she is less than seventeen years old.
52.
Jeffrey Epstein committed sexual misconduct against Plaintiff as defined in
§130.20 of the New York Penal Law, inasmuch as Jeffrey Epstein engaged in sexual intercourse
with Plaintiff without Plaintiff’s consent.
53.
Jeffrey Epstein committed rape in the third degree as defined in §130.25 inasmuch
as Jeffrey Epstein engaged in sexual intercourse with Plaintiff when Jeffrey Epstein was over 21
years old and Plaintiff was less than 17 years old.
54.
Jeffrey Epstein committed rape in the first degree as defined in §130.35 inasmuch
as Jeffrey Epstein engaged in sexual intercourse with Plaintiff by forcible compulsion;
55.
Jeffrey Epstein caused a Criminal sexual act in the third degree to be committed as
defined in §130.40 inasmuch as Jeffrey Epstein forced Plaintiff to be forcibly subjected to oral
sexual contact by his girlfriend against Plaintiff’s consent.
Case 1:19-cv-11869-MKV-DCF Document 1 Filed 12/27/19 Page 8 of 14
56.
Jeffrey Epstein committed a forcible touching against Plaintiff as defined in
§130.52 of the New York Penal Law, inasmuch as Jeffrey Epstein, intentionally and for no
legitimate purpose, engaged the forcible sexual touching of Plaintiff for the purpose of degrading
or abusing her or for the purpose of gratifying his sexual desire.
57.
Jeffrey Epstein committed sexual abuse in the third degree against Plaintiff as
defined in §130.55 of the New York Penal Law when he engaged in sexual contact with Plaintiff
beginning when she was 14 years old and including through a time when she was 17 years old and
when Jeffrey Epstein was greater than 5 years her elder.
58.
Jeffrey Epstein committed an aggravated sexual abuse in the third degree against
her as defined in §130.66 of the New York Penal Law, inasmuch as Jeffrey Epstein inserted a
foreign object into the vagina of Plaintiff by forcible compulsion.
COUNT I
BATTERY/VIOLATION OF SECTION 130
AGAINST THE ESTATE OF JEFFREY E. EPSTEIN
59.
Plaintiff incorporates by reference paragraphs 1-58 and re-alleges them as if set
forth fully herein.
60.
The intentional acts of Jeffrey Epstein against Plaintiff constitute a sexual offense
as defined in New York Penal Law § 130, including but not limited to the following:
a.
Sexual misconduct as defined in §130.20 inasmuch as Jeffrey
Epstein engaged in sexual intercourse with Plaintiff without Plaintiff’s consent;
b.
Rape in the third degree as defined in §130.25 inasmuch as Jeffrey
Epstein engaged in sexual intercourse with Plaintiff when Jeffrey Epstein was over
years old and Plaintiff was less than 17 years old.
c.
Rape in the first degree as defined in §130.35 inasmuch as Jeffrey
Epstein engaged in sexual intercourse with Plaintiff by forcible compulsion;
Case 1:19-cv-11869-MKV-DCF Document 1 Filed 12/27/19 Page 9 of 14
d.
Criminal Sexual Act in the third degree as defined in §130.40
inasmuch as Jeffrey Epstein forced Plaintiff to receive oral sexual contact by Jeffrey
Epstein’s girlfriend without Plaintiff’s consent;
e.
Forcible touching as defined in §130.52 inasmuch as Jeffrey
Epstein, intentionally and for no legitimate purpose, engaged the forcible sexual
touching of Plaintiff for the purpose of degrading or abusing her or for the purpose
of gratifying his own sexual desire; and
f.
Sexual abuse in the third degree as defined in §130.66 inasmuch as