EPSTEIN
page 2 / 43 . OCR, unverified
referred to herein as the “Estate of Jeffrey E. Epstein”), owed a duty to Plaintiff to treat her in a
non-negligent manner and not to commit, or conspire to commit, or cause to be committed,
intentional, criminal, fraudulent, or tortious acts against Plaintiff, including any acts that would
cause Plaintiff to be harmed through conduct committed against her in violation of the TVPRA.
Case 1:20-cv-02365 Document 1 Filed 03/17/20 Page 3 of 8
IV.
EPSTEIN’S SEX TRAFFICKING CRIMINAL ENTERPRISE
13.
At all times relevant herein, Jeffrey Epstein [“Epstein”] was an extremely wealthy
financier, who used his wealth, power, resources, and connections to commit illegal sexual
crimes in violation of the TVPRA, and to employ and conspire with other corporate entities,
private foundations and trusts, to assist him in committing those sexual crimes or torts or to
facilitate or enable those acts to occur.
14.
Epstein displayed his enormous wealth, power, and influence to his employees; to
the employees of the corporate entities, private foundations, and trusts, who worked at his
direction; to the victims procured for sexual purposes; and to the public, in order to advance and
carry out and conceal his crimes and torts.
15.
At all times relevant herein, Epstein had access to numerous mansions, a fleet of
airplanes, motor vehicles, boats and several helicopters.
16.
At all times relevant herein, Jeffrey Epstein travelled between and frequently
inhabited and travelled between numerous properties and homes, including a Manhattan
townhome located at 9 East 71st Street, New York, NY 10021 valued conservatively by Jeffrey
Epstein’s own admission at $55,931,000.00; a ranch located at 49 Zorro Ranch Road, Stanley,
New Mexico 87056 valued conservatively by Jeffrey Epstein’s own admission at
$17,246,208.00; a home located at 358 El Brillo Way, Palm Beach, Florida 33480 valued
conservatively by Jeffrey Epstein’s own admission at $12,380,209.00; an apartment located at 22
Avenue Foch, Paris, France 75116 valued conservatively by Jeffrey Epstein’s own admission at
$8,672,820.00; and an Island Little St. James Island No. 6B USVI 00802 (A, B, C).
17.
As has been publicly reported, Epstein had a compulsive sexual preference for
Case 1:20-cv-02365 Document 1 Filed 03/17/20 Page 4 of 8
young females and took pleasure in corrupting vulnerable young females into engaging in sexual
acts with him. The allegations herein primarily concern Jeffrey Epstein’s conduct while at his
NY, Virgin Islands, Florida, New Mexico, and Paris residences and other locations.
18.
Epstein fulfilled his compulsive need for sexual contact with and control over
young females by preying on their personal, psychological, financial, and related vulnerabilities.
Epstein’s tactics included promising the victims shelter, transportation, gifts, money and
employment, admission into educational institutions, educational tuition, protection, illusion of
family and other things of value in exchange for sex.
19.
Jeffrey Epstein specifically targeted underprivileged, emotionally vulnerable
and/or economically disadvantaged young females exactly like Plaintiff to sexually molest and
abuse.
20.
Epstein’s continuous psychological and physical control over Jane Doe facilitated
his sexual abuse of her on a relatively consistent basis for many years.
21.
The sexual abuse took many forms including Epstein’s rape of Plaintiff.
22.
He would also enter plaintiff’s room and get into her bed while she was sleeping
and then fondle or penetrate her with his fingers. This occurred often and repeatedly.
23.
He often directed her to undress and pose in certain ways and/or touch him and
herself while he masturbated. This occurred often and repeatedly.
24.
Epstein frequently directed Jane Doe to turn her head back during their sexual
encounters, telling her that he did not want to see her face.
25.
Epstein also repeatedly required Jane Doe to bathe with him and perform oral sex
on him.
26.
This occurred in New York, Palm Beach, New Mexico, London, Paris, on
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Epstein’s private island, on Epstein’s airplanes and other locations.
27.
Jane Doe was paid in part to be sexually available to Epstein.
28.
In or about January or February 2012, Epstein grabbed Plaintiff by the hand while
at his New York City Residence and took her to a small room on the third floor. It was a room
with two chairs in it. He sat her down, pulled her pants down, covered her eyes, and used a
vibrator on her. Epstein laughed afterwards.
CAUSE OF ACTION I AGAINST EPSTEIN
29.
Defendant, within the special maritime and territorial jurisdiction of the United
States, in interstate and foreign commerce, and/or affecting interstate and foreign commerce,
knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,