EPSTEIN
page 7 / 149 . OCR, unverified
29.
The Indictment stated in part, and Plaintiff herein adopts as true, that
“from at least in or about 2002, up to and including at least in or about 2005, Jeffrey
Epstein, the defendant, enticed and recruited, and caused to be enticed and recruited,
minor girls to visit his mansion in Manhattan, New York (the “New York
Residence”) and his estate in Palm Beach, Florida (the “Palm Beach Residence”) to
engage in sex acts with him, after which the victims were given hundreds of dollars
in cash.” Criminal Indictment at 1.
30.
“Moreover, and in order to maintain and increase his supply of victims,
Epstein also paid certain of his victims to recruit additional girls to be similarly
abused by EPSTEIN. In this way, EPSTEIN created a vast network of underage
victims for him to sexually exploit in locations including New York and Palm
Beach.” Criminal Indictment at 1-2.
31.
“The victims described herein were as young as 14 years old at the time
they were abused by Jeffrey Epstein, and were, for various reasons, often particularly
vulnerable to exploitation. Epstein intentionally sought out minors and knew that
Case 1:19-cv-07625-AJN-DCF Document 1 Filed 08/14/19 Page 7 of 26
many of his victims were in fact under the age of 18, including because, in some
instances, minor victims expressly told him their age.” Criminal Indictment at 2.
32.
“In creating and maintaining this network of minor victims in multiple
states to sexually abuse and exploit, JEFFREY EPSTEIN, … worked and conspired
with others, including employees and associates who facilitated his conduct by,
among other things, contacting victims and scheduling their sexual encounters with
EPSTEIN at the New York Residence and at the Palm Beach Residence.” Criminal
Indictment at 2.
33.
The indictment further explained, and Plaintiff adopts and alleges, that,
“[v]ictims were initially recruited to provide ‘massages’ to Epstein, which would be
performed nude or partially nude, would become increasingly sexual in nature, and
would typically include one or more sex acts.” Criminal Indictment at 3.
34.
“Between at least in or about 2002 and in or about 2005, Epstein abused
numerous minor victims at the New York Residence by causing these victims to be
recruited to engage in paid sex acts with him.” Criminal Indictment at 3.
35.
Defendants enabled Jeffrey Epstein to receive near daily massages from
young females, often minors, who were not experienced in massage. Rather than
receive regular body massages, Epstein was predictably sexually abusing the young
females in violation of New York Penal Law Section 130.
Case 1:19-cv-07625-AJN-DCF Document 1 Filed 08/14/19 Page 8 of 26
36.
Additionally, employees of the various Defendant corporations
performed actions or inactions that further placed victims, including Plaintiff, in
danger of being sexually abused by Epstein, and assisted in the concealment of his
sexually abusive acts.
37.
Defendants employed many recruiters of young females. The nature of
the Jeffrey Epstein’s sex trafficking venture and enterprise enabled victims
themselves to elevate their status to that of a paid recruiter of other victims, an
elevation only made possible through the negligence of Defendants.
38.
Recruiters were taught by employees of Defendants to inform targeted
victims that Epstein possessed extraordinary wealth, power, resources, and
influence; that he was a philanthropist who would help female victims advance their
careers and lives; and that she only needed to provide Epstein with body massages
in order to avail receive his assistance and influence.
39.
The collaboration from Defendants and the many employees fulfilled
Epstein’s compulsive need for sex with young females by preying on their personal,
psychological, financial, and related vulnerabilities. Defendants’ tactics included
promising the victims money, shelter, transportation, gifts, employment, admission
into educational institutions, educational tuition, protection, and other things of
value in exchange for sex and concealment of Jeffrey Epstein’s actions.
Case 1:19-cv-07625-AJN-DCF Document 1 Filed 08/14/19 Page 9 of 26
40.
Jeffrey Epstein’s sexual attraction to young, often underage, females,
dated back to at least the mid-nineties and the number of victims increased
substantially with the necessary assistance from Defendants and Defendants’
employees.
41.
Defendants, at the direction of Epstein or in furtherance of his demands,
and with help from assistants, associates and underlings, and even other victims,
recruited or procured dozens if not hundreds of young females, including minors,
for the purpose of Epstein’s sexual gratification.
42.
Jeffrey Epstein, and consequently Defendants, specifically targeted
underprivileged, emotionally vulnerable and/or economically disadvantaged young