EPSTEIN
page 8 / 67 . OCR, unverified
of gratifying his own sexual desire; and
f.
Sexual abuse in the third degree as defined in §130.66 inasmuch as
Jeffrey Epstein inserted a foreign object in the vagina of Plaintiff by forcible
compulsion.
g.
Aggravated sexual abuse in the second degree as defined in §130.67
inasmuch as Jeffrey Epstein caused physical injury to Plaintiff when he inserted a
finger into the vagina of Plaintiff by forcible compulsion.
61.
On numerous occasions as described in the complaint above, Epstein intentionally,
forcibly, violently, or invasively used his fingers, and foreign objects to make unwanted, unlawful,
harmful, and offensive physical contact with Plaintiff’s body.
62.
This conduct caused Plaintiff serious and persistent harm and contributed to injuries
that Plaintiff continues to suffer.
63.
This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g
(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
the New York Penal Law (“Article 130”). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
64.
As a direct and proximate result of Jeffrey Epstein’s violations of New York Penal
Law § 130, Plaintiff has in the past suffered and in the future will continue to suffer physical injury,
pain, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss
of self-esteem, loss of dignity, invasion of her privacy and a loss of her capacity to enjoy life, as
well as other damages. Plaintiff incurred medical and psychological expenses and Plaintiff will in
Case 1:19-cv-11869-MKV-DCF Document 1 Filed 12/27/19 Page 10 of 14
the future suffer additional medical and psychological expenses. These injuries are permanent in
nature and Plaintiff will continue to suffer these losses in the future.
WHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. Epstein for
compensatory and general damages, and such other and further relief as this Court deems just and
proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury.
COUNT TWO
SEXUAL ASSAULT
65.
Plaintiff incorporates by reference paragraphs 1-58 and re-alleges them as if set
forth fully herein.
66.
On numerous occasions over three years, Epstein made violent sexual demands on
Plaintiff while placing his hands on her body in a position of dominance and control and while
touching Plaintiff in violent and invasive ways.
67.
These demands, often made when Epstein and Plaintiff were alone, were intended
to frighten Plaintiff into submitting to Epstein’s sexual demands and placed Plaintiff in
apprehension of harm.
68.
This conduct caused Plaintiff serious and persistent harm and contributed to injuries
that Plaintiff continues to suffer.
69.
This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g
(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
the New York Penal Law (“Article 130”). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
70.
As a direct and proximate result of Jeffrey Epstein’s violations of New York Penal
Law § 130, Plaintiff has in the past suffered and in the future will continue to suffer physical injury,
Case 1:19-cv-11869-MKV-DCF Document 1 Filed 12/27/19 Page 11 of 14
pain, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss
of self-esteem, loss of dignity, invasion of her privacy and a loss of her capacity to enjoy life, as
well as other damages. Plaintiff incurred medical and psychological expenses and Plaintiff will in
the future suffer additional medical and psychological expenses. These injuries are permanent in
nature and Plaintiff will continue to suffer these losses in the future.
WHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. Epstein for
compensatory and general damages, and such other and further relief as this Court deems just and
proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury.
COUNT THREE
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
71.
Plaintiff incorporates by reference paragraphs 1-58 and re-alleges them as if set
forth fully herein.
72.
Epstein’s years long sexual abuse against a teenaged Plaintiff was extreme and
outrageous conduct that shocks the conscience.
73.
Epstein’s serial sexual assaults, committed during the course of a methodical plan
of recruitment, enticement, and attack, inflicted severe pain and anguish upon Plaintiff.
74.
Epstein directed this conduct at Plaintiff and knew that it would cause severe and
lasting emotional distress. Indeed, the conduct caused Plaintiff severe and lasting emotional
distress and serious injuries to her mental health.