EPSTEIN
page 5 / 149 . OCR, unverified
it is the intent of the United States, pursuant to 21 U.S.C.
§ 853(p) and 28 U.S.C. § 246l(c), to seek forfeiture of any
other property of the defendant up to the value of the above
forfeitable property.
(Title 18, United States Code, Section 1594; Title 21,
United States Code, Section 853(p); and
Title 28, United States Code, Section 2461.)
~d.~
GEOFFRY~ BERMAN
United States Attorney
Case 1:19-cv-07625-AJN-DCF Document 1-2 Filed 08/14/19 Page 15 of 15
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
v.
JEFFREY EPSTEIN,
Defendant.
'INDICTMENT
(18 U.S.C. §§ 371, 1591(a), (b) (2),
and 2)
GEOFFREY S. BERMAN
United States Attorney
I
1.:V.L C .t-1C.LUV.l.L
==================== END OF Court Records__VE v. Nine East 71st Street, No. 119-cv-07625 (S.D.N.Y. 2019)__001-02.txt ====================
==================== DOCUMENT: Court Records__VE v. Nine East 71st Street, No. 119-cv-07625 (S.D.N.Y. 2019)__001.txt ====================
METADATA_SOURCE: Court RecordsVE v. Nine East 71st Street, No. 119-cv-07625 (S.D.N.Y. 2019)
METADATA_FILENAME: 001.pdf
----------------------------------------
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
CASE NO.:
VE
Plaintiff,
vs.
NINE EAST 71ST STREET, CORPORATION,
FINANCIAL TRUST COMPANY, INC.,
NES, LLC,
Defendant.
______________________________/
COMPLAINT
Plaintiff, VE, by and through her undersigned counsel, for her claims against
Defendants, alleges as follows:
1.
The controversy in this cause of action exceeds the sum or value of
$75,000, exclusive of interest and costs, and is between citizens of different States.
Therefore, jurisdiction is proper under 28 U.S.C. section 1332.
2.
Plaintiff files this Complaint under a pseudonym in order to protect her
identity because this Complaint makes allegations of a sensitive sexual nature the
disclosure of which, in association with her name, would cause further harm to her.
3.
Plaintiff is currently a resident of and domiciled in the state of Florida.
4.
At all times material to this cause of action, Jeffrey Epstein travelled
between and stayed regularly in multiple residences, including in New York, New
York (within the Southern District of New York) and the United States Virgin
Case 1:19-cv-07625-AJN-DCF Document 1 Filed 08/14/19 Page 1 of 26
Islands. He was a citizen of the United States and a resident of the U.S. Virgin
Islands.
5.
At all times material to this cause of action Jeffrey Epstein was an adult
male born in 1953, who died on August 10, 2019.
6.
At all times material hereto, Defendant Nine East 71st Street,
Corporation was a domestic business corporation conducting business in New York,
with its principal place of business located at 575 Lexington Avenue, Fourth Floor,
New York, NY 10022.
7.
At all times material hereto, Defendant Financial Trust Company, Inc.
was a U.S. Virgin Islands corporation conducting business in New York.
8.
At all times material hereto, Defendant NES, LLC, was and is a
domestic limited liability company registered in and conducting business in New
York.
9.
Corporate Defendants NES, LLC; Financial Trust Company, Inc; Nine
East 71st Street, referred to as “Defendants,” each performed substantial business in
New York.
10.
Plaintiff intends to amend this complaint to add or substitute additional
parties as discovery reveals the identities of other negligent corporate or individual
actors. In that regard, through information and belief, the Estate of Jeffrey Epstein
Case 1:19-cv-07625-AJN-DCF Document 1 Filed 08/14/19 Page 2 of 26
has not been properly established although if and when it is, Plaintiff intends to
amend to add the Estate as a party.
11.
Jeffrey Epstein was an officer, director, or employee of many corporate
entities registered in various states throughout the United States, any one of which
may also bear legal responsibility for the crimes he committed against young
females, including minors such as Plaintiff.
12.
Additionally, individuals who worked at the residences where he
committed sexual violations, as well as others who assisted him in committing such
violations, were employed through, or worked for, numerous other corporate entities
whose negligence likely caused or contributed to the sexual violations that caused
harm to Plaintiff.
13.
The complete universe of those individuals and companies whose
negligence contributed to the crimes committed by Epstein are currently unknown.
14.
As Plaintiff learns through discovery the identities of additional
individual or corporate entities and the manner in which those others caused or
contributed to causing harm to Plaintiff through negligence, Plaintiff intends to
amend to add those parties as well. Should discovery reveal that any of the currently
named Defendants are not the proper identity of the Companies identified as current