EPSTEIN
page 8 / 149 . OCR, unverified
females to sexually molest and abuse.
43.
Additionally, Defendants through employees, informed young females
that Jeffrey Epstein was wealthy, well-connected, and could either advance or
destroy the career or education of any young female brought to provide Jeffrey
Epstein a massage, depending on her degree of cooperation.
VE
44.
Minor victim VE was subjected to the types of illegal sexual acts
detailed in the Criminal Indictment filed against Jeffrey Epstein by the Southern
District of New York.
Case 1:19-cv-07625-AJN-DCF Document 1 Filed 08/14/19 Page 10 of 26
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45.
Jeffrey Epstein committed abhorrent acts of sexual abuse against
Plaintiff in 2001 when she was only sixteen years old.
46.
In or about 2001, Plaintiff was recruited by another minor child to go
to Jeffrey Epstein’s mansion in Manhattan, New York to provide him with a
“massage.”
47.
The minor child who recruited Plaintiff (“Plaintiff’s friend”) informed
Plaintiff that she would be paid $300 to provide a massage to a man in Manhattan.
48.
Plaintiff was a minor female with no experience or training in massage.
49.
She was recruited under the false pretense that she would be providing
a legitimate body massage at the mansion owned or controlled by Defendant, Nine
East.
50.
In or about the Fall of 2001, Plaintiff’s friend brought Plaintiff to
Jeffrey Epstein’s home to provide him with a massage.
51.
Upon arrival to the mansion, the two minor children were escorted
inside by an employee of Defendant NES, LLC and taken to Jeffrey Epstein’s
massage room.
52.
Plaintiff’s friend entered the massage room and left Plaintiff outside the
door.
53.
Moments later, Plaintiff’s friend exited the room and instructed
Plaintiff to enter the room alone.
Case 1:19-cv-07625-AJN-DCF Document 1 Filed 08/14/19 Page 11 of 26
54.
Plaintiff walked into the dark room which contained a massage table,
various massage oils, and numerous photographs of nude girls.
55.
Unsure of what to expect, Plaintiff waited for the man to arrive for his
massage.
56.
Jeffrey Epstein entered the room and immediately removed his clothing
before positioning himself on the massage table.
57.
Jeffrey Epstein then provided Plaintiff with instruction on how to
massage his body.
58.
Jeffrey Epstein quickly turned the massage into a sexual encounter with
the then sixteen-year-old Plaintiff.
59.
During the sexual encounter, Plaintiff told Jeffrey Epstein that she did
not feel comfortable. Jeffrey Epstein ignored her and continued to engage in the
improper and illegal sexual contact until he was finished.
60.
The sexual encounter ended when Jeffrey Epstein masturbated to
climax.
61.
Plaintiff was paid $300 cash before being escorted out of his mansion,
all with assistance from Defendants; this payment was made to induce Plaintiff to
conceal the activities of Epstein and to entice her to return.
62.
Plaintiff observed the opulence of the mansion owned by Defendant,
Nine East, and the organization of Defendant, NES, Inc., which collectively
Case 1:19-cv-07625-AJN-DCF Document 1 Filed 08/14/19 Page 12 of 26
facilitated her further cooperation with Jeffrey Epstein, culminating in New York
Penal Law Section 130 crimes being committed against her by Jeffrey Epstein.
63.
Within days, Plaintiff returned to Jeffrey Epstein’s mansion wherein
she endured yet another sexual assault, this time more severe.
64.
Plaintiff was taken by elevator to the floor where Jeffrey Epstein’s
massage room was located.
65.
Similar to the first time, Jeffrey Epstein appeared wearing only a towel
and laid face down on the massage table. Within minutes, he again turned the
massage into a sexual encounter against the 16-year-old plaintiff. He instructed her
to take her clothes off this time.
66.
During the second encounter, in addition to harmful, forcible, physical
touching and sexual exploitation of Plaintiff, Jeffrey Epstein forcibly used a sex toy
on Plaintiff, forcibly pressing it onto and in Plaintiff’s vagina.
67.
Jeffrey Epstein then commanded Plaintiff to straddle him. Knowing
that she had no way out of the Mansion, she complied with Jeffrey Epstein’s orders.
68.
Jeffrey Epstein moved plaintiff’s panties aside and attempted to insert
his penis into her vagina, briefly penetrating her, while Plaintiff was resisting.
69.
During this encounter, Epstein digitally penetrated Plaintiff. The
encounter ended with Jeffrey Epstein masturbating to climax.
Case 1:19-cv-07625-AJN-DCF Document 1 Filed 08/14/19 Page 13 of 26
70.
Throughout the duration of the sexual encounter, Plaintiff found herself
trapped in Jeffrey Epstein’s large mansion under the impression that there was no
feasible or safe means of escape.
71.
All sexual acts were performed by Jeffrey Epstein intentionally and for
no legitimate purpose and for his own gratification when Plaintiff was a minor child