EPSTEIN
page 6 / 149 . OCR, unverified
Defendants, substitution of parties shall be requested to ensure accuracy and
correctness of pleading.
Case 1:19-cv-07625-AJN-DCF Document 1 Filed 08/14/19 Page 3 of 26
15.
A substantial part of the acts, events, and omissions giving rise to this
cause of action occurred in the Southern District of New York; venue is proper in
this District. 28 U.S.C. section 1391(b)(2).
16.
At all times material to this cause of action, Jeffrey Epstein and
Defendants owed a duty to Plaintiff to treat her in a non-negligent manner and not
to commit or conspire to commit intentional, criminal, fraudulent, or tortious acts
against her, including any acts that would cause Plaintiff to be harmed through
conduct committed against her in violation of New York Penal Law section 214-G,
New York Penal Law section 130.20; or New York Penal Law 130.66; or New York
Penal Law 130.67; or New York Penal Law 130.52.
FACTUAL ALLEGATIONS
17.
At all times material to this cause of action, Jeffrey Epstein was an adult
male over 45 years old. Epstein was tremendously wealthy, widely recognized as a
billionaire, who used his wealth, power, resources, and connections to commit illegal
sexual crimes in violation of federal and state statutes and to employ and conspire
with other individuals and corporate entities to assist him in committing those crimes
or torts or to facilitate or enable those acts to occur.
18.
Epstein displayed his enormous wealth, power, and influence to his
employees; to the employees of the corporate or company entities who worked at his
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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.
19.
At all relevant times, Epstein had access to numerous mansions, a fleet
of airplanes, motor vehicles, boats and one or more helicopters. For example, he
regularly traveled by private jet aboard a Boeing aircraft (of make and model B-727-
31H with tail number N908JE) or a Gulfstream aircraft (of make and model G-
1159B with tail number N909JE).
20.
Jeffrey Epstein also 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;
an Island located at Great St. James Island No. 6A USVI 00802 (parcels A, B, C);
and an Island Little St. James Island No. 6B USVI 00802 (A, B, C). See Jeffrey
Epstein “Asset Summary – June 30, 2019” filed in Case 1:19-cr-00490-RMB on July
15, 2019 attached hereto as Exhibit A.
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21.
Jeffrey Epstein was otherwise affiliated with the corporations that
owned or controlled each of the real property listed in the preceding paragraph.
22.
The allegations herein primarily concern Jeffrey Epstein’s conduct
while at his townhouse in New York and concern the various corporate entities
which provided the opportunity for his illicit conduct to occur and remain concealed
for years.
23.
Epstein had a compulsive sexual preference for young females as young
as 14 years old.
24.
Epstein enjoyed sexual contact with young females, including minor
children, and took pleasure corrupting vulnerable young females, including minor
children, into engaging in sexual acts with him.
25.
Epstein directed a complex system of individuals, including employees
and associates of Defendant entities, to work in concert and at his direction, for the
purpose of harming teenage girls through sexual exploitation.
26.
It was widely known among individuals regularly in Epstein’s presence
that he got pleasure out of corrupting vulnerable young females into engaging in
uncomfortable and unwanted sexual acts for his own gratification.
27.
On July 2, 2019, the United States Attorney’s Office for the Southern
District of New York filed a Sealed Two Count Indictment inclusive of One Count
of Sex Trafficking Conspiracy and One Count of Sex Trafficking, in part due to
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Epstein’s criminal activities against children in the New York Mansion located at 9
East 71st Street.
28.
On July 8, 2019, Jeffrey Epstein was arrested pursuant to the
aforementioned Indictment, which is attached hereto as Exhibit B.
29.
The Indictment stated in part, and Plaintiff herein adopts as true, that