Murphy's Law - /page/epstein/read.mu

Micron Document

EPSTEIN

page 9 / 67 . OCR, unverified

75.

Epstein’s direction of his girlfriend to engage in unwanted oral sexual contact with

Plaintiff was done with knowledge that it would cause severe and lasting emotional distress.

76.

Epstein’s enticement and encouragement for Plaintiff to recruit other minor females

for Jeffrey Epstein to sexually assault was done with knowledge it would cause severe and lasting

emotional distress.

Case 1:19-cv-11869-MKV-DCF Document 1 Filed 12/27/19 Page 12 of 14

77.

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.

78.

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

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 FOUR

NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS

79.

Plaintiff incorporates by reference paragraphs 1-58 and re-alleges them as if set

forth fully herein.

80.

Epstein invited Plaintiff, then a teenaged girl, into his home for years. Once under

his supervision, Epstein proceeded methodically to sexually abuse Plaintiff.

81.

Epstein’s conduct was extreme and outrageous, breached a duty owed directly to

plaintiff, endangered her physical safety, and caused severe and lasting emotional distress and

serious injuries to Plaintiff’s mental health.

Case 1:19-cv-11869-MKV-DCF Document 1 Filed 12/27/19 Page 13 of 14

82.

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.

83.