EFTA00296277

Case 1:17-cv-00616-JGK Document 45 Filed  06/05/17 Page 19 of 31 
18 
and commercial air travel on numerous occasions for the purpose of causing 
Plaintiff to commit commercial sex acts. These Defendants worked in concert 
with one another to recruit, procure, entice, and otherwise cause many other 
females to engage in commercial sex acts, through their use of threats, fraud, 
and coercion. Among these means of coercion were the Defendant's possession 
and control of the females' passports and other immigration documents. This 
coercion was most salient, and especially effective, while the females, including 
Plaintiff, were on Epstein's island. 
52. 4-9,1n furtherance of their venture and enterprise,  Defendants provided 
living quarters for Plaintiff at 301 East 66th Street, New York, in the Southern 
District of New York; a car service for Plaintiff to use as needed; a cell phone; and 
other valuable consideration in order to maintain Plaintiffs sexual compliance. Each 
of the Defendants told Plaintiff she would obtain the benefits of a place to live 
and phone and transportation as long as she remained compliant with their 
demands that she service Epstein sexually. Each of the Defendants also told her 
that if she was not compliant, these benefits would be taken from Plaintiff. 
53. 544,The relationship between Plaintiff and Defendants Epstein and Maxwell 
was defined and characterized by Defendant Epstein's and Defendant Maxwell's 
frequent and persistent fraudulent representations that they would provide Plaintiff 
with a formal education and career advancement if she provided sex to Defendant 
12 
EFTA00296297

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 20 of 31 
Epstein and others in the times, places and manners demanded by Defendants. 
Defendants 
and 
each also told Plaintiff that Defendant Epstein 
would advance Plaintiffs education and career in order to coerce Plaintiff into 
sex. Defendant 
told Plaintiff that Epstein had done the same for her 
career. As a result of these and other representations by Defendants,  Plaintiff 
reasonably relied on thestn 
representations. In fact, however, thosethese
representations were knowingly false, were not acted upon  by Defendants, and 
were made by Defendants Epstein 
a 
and Maxwell solely for the 
purpose of maintaining 
44 Plaintiffs financial dependence on, emotional vulnerability to, and sexual 
compliance with DefendantsDefendant Epstein4144-Ma*well-and-their:a demands. 
The other Defendants intentionally repeated thesethese representations and 
intentionally attetpteilmade statements designed to convince Plaintiff that the 
representations were true and could be relied upon. These representations and 
statements were made to Plaintiff in furtherance of the sex trafficking 
venture and enterprise for which they were each employed. 
54. As part of the venture and enterprise, Defendants Epstein, Maxwell, and 
took possession of Plaintiffs passport when she was being trafficked by 
them, including when she travelled to E stein's island in the U.S. Virgin 
Islands. 'The Defendants took possession of Plaintiffs passport in the course of 
sexually trafficking Plaintiff and with the intent to violate laws against sex 
trafficking, including 18 U.S.C. 1591 et. seq. The Defendants used their control 
of Plaintiffs 
20 
EFTA00296298

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 21 of 31 
passport in order to coerce compliance with their demands, including their 
demands that Plaintiff have sex with Epstein and others. 
$4-In January 2007 as part of their illegal venture and enterprise, 
Defendants sent Plaintiff from the-Uctited4takasNew York City, in the Southern 
District of New York, to South Africa-in-pact to recruit, for a promised fee, one or 
more aspiring female models supposedly for Defendant-Erstein-te-use-as-an-alleged 
per-sefial-assistant,Epstein to use as a personal assistant. The Defendants did not 
care whether the prospective female was qualified to work as a personal 
assistant because each knew that the female recruit would be immediately 
placed into the same sexually vulnerable position as Plaintiff (and the dozens of 
other victims of the sex trafficking enterprise) and would be induced and 
coerced into being used for sex through fraudulent representations and other 
means. 
56. Defendants Epstein and Maxwell continuously and frequently demanded that 
Plaintiff fulfill this task of bringing another female back to the United States and 
Defendants' control  as a condition of herPlaintiff's receiving the education, career 
and related benefits promised by Defendants Epstein and Maxwell. Based upon 
Plaintiff's experience with Defendants, however, she did-net-believeknew that the 
requested female  model would not be placed in a legitimate position of employment 
with Defendant Epstein but would, instead, be forced into sexual servitude. Plaintiff 
also knew that this objective was the only purpose of Defendants n 
EFTA00296299

Case 1:17-cv-00616-JGK Document 45 Filed  06/05/17 Page 22 of 31 
Maxwell and Epstein's demand for rAjilies recruitment efforts.  As a result, 
Plaintiff deliberately refused to perform the recruitment assignment. 
57. 5-2,As part of their ongoing scheme, Defendants inflicted serious emotional 
and psychological harm on Plaintiff as a means of coercing her to continue engaging 
in commercial sex acts with Epstein and others. While Plaintiff was in South 
Africa, Defendants Epstein and Maxwell informed Plaintiff that she would not be 
permitted to return to the United States to receive her promised education unless she 
underwent a diet and lowered her body weight from 57 kilograms 
4-5 (approximately 125 pounds) to 52 kilograms (approximately 114 pounds). 
Epstein and Maxwell promised Plaintiff that if she complied, she would 
receive her promised education. Defendant 
monitored Plaintiffs 
progress in losing weight and continued to communicate with Plaintiff about 
Plaintiff's application to be admitted into F.I.T. as part of the Defendants' 
ruse to coerce Plaintiff to return to the United States for sex. Defendant = 
was aware of the coercion Epstein and Maxwell were applying to Plaintiff and 
acted to help further that coercion.  Believing she had no practical choice in the 
matter, Plaintiff attempted to comply with the order but, given her physical height 
and body  structure and her already  existing-lew body weight, the diet imposed 
upon her placed her in serious physical jeopardy, including kidney malfunction 
and extreme emotional and psychological distress. 
ha
a  53.As  part of their scheme,,Defendants Epstein and Maxwell called 
Plaintiff-'s parents in South Africa to tell them that DefendentsDefendant Epstein 
would take good care of Plaintiff when she returned to the United State; and that 
theyDefendants Maxwell and Epstein would use their connections and influence 
EFTA00296300

Case 1:17-cv-00616-JGK Document 45 Filed  06/05/17 Page 23 of 31 
to have her admitted to 
F.I.T. or another well-regarded fashion school or school of higher learning, 
59. 
As part of their scheme, Epstein and 
told Plaintiff that she should 
fill out an application for admission to F.I.T., and supporting essay_ and send it 
to Epstein for his review. Pursuant to these instructions, Plaintiff completed an 
armlication, and supporting essay, and sent it to Epstein. As part of his scheme, 
Epstein told Plaintiff that he had reviewed these materials. His statements were 
intended to convince Plaintiff and had the effect of convincing plaintiff (as they 
have convinced nri
)vomAl
maimul
ys
i that her 
 
admission 
F.I.T. was 
41. 
I" if she s ul c nt t with
i ns. 
also made the 
same representations to plaintiff on Epstein's behalf. Plaintiff reasonably 
relied on these representations by Epstein and =, 
60. As part of their scheme, Epstein and Maxwell told Plaintiff that they had 
contacts at F.LT. and at modeling agencies who could ensure her admission to 
F.I.T. and advance Plaintiff's career. As part of their scheme, Epstein and 
Maxwell told Plaintiff about Epstein's vast wealth and specifically identified 
him as a billionaire. Epstein and Maxwell told Plaintiff that they had extensive 
23 
contacts, in addition to those identified above, throughout New York City and 
elsewhere. 
61. 54,In February of 2007, in reliance on promises made by the Defendant; 
Plaintiff returned to New York City, in the Southern District of New York,  and 
EFTA00296301

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 24 of 31 
was promptly ordered by Defendant Maxwell to have sex with Defendant Epstein. 
Defendants Maxwell.
 and Epstein each fraudulently promised 
herPlaintiff again that her sexual compliance would be rewarded with admission to 
F.I.T. or a comparable college, a promise which they letew-te-be-faiseeach knew to 
be false. In fact all four Defendants had for years worked solely to recruit 
females for sex and to conceal the operation of the sex scheme, and in 2007 were 
under Federal investigation for their conspiracy to engage in Federal sexual 
crimes like those committed against Plaintiff. Plaintiff knew that if she did not 
comply, Defendants Maxwell and Epstein would use their power, influence and 
connections in order to ensure that Plaintiff was unable to gain admission to F.I.T. or 
a comparable school, and that they would destroy her career, just as they had 
destroyed the careers of others who had failed to comply with their demands. 
12a 5-SDefendants Epstein and Maxwell continued to provide Plaintiff with 
things of value in exchange for Plaintiff-:s continued compliance with Epsteie 
4-6 sexual demands; however, they failed and refused to perform their promises to 
help Plaintiff be admitted to F.I.T. or another school, or to provide financial 
support for 
24 
college admission or on-going education, false promises they repeatedly made in 
order to coerce her into commercial sex acts. 
13.. 5&Defendants Epstein and Maxwell':,_' sexual demands on Plaintiff 
continued while she was in New York or other gcographicCity, in the Southern 
District of New York, or in other locations in close proximity to the Defendants. 
EFTA00296302

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 25 of 31 
In addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, 
each of the  Defendants continued to pressure her to lose excessive amounts of body 
weight and offered her no opportunity to decline or resist their instructions. 
5-77In May, 2007, Plaintiff left the United States and did not return. Between 
returtaSouth 
Africa 
Min 
in May 2007.
Defendants M,a, 
and Maxwell each continued to repeatedly make 
false 
representations 
to 
Plaintiff, 
including 
false 
and 
fraudulent 
representations that she would be admitted to F.I.T. if she continued to engage 
in sex with Epstein. Defendant Epstein continued to make similar false and 
fraudulent promises in order to have sex with Plaintiff. 
65. In and after May 2007, Defendants actively concealed and covered up 
what they had done to Plaintiff and other similarly situated females. 
Defendant's cover- up included efforts to intimidate witnesses who might 
provide corroborating testimony to Plaintiff as well as destruction of 
documents and other evidence regarding what they had done. 
25 
66. 5-8,Unknown to Plaintiff,  Defendants' representations and promises to 
Plaintiff were all false and fraudulent. Their—threats-,were-considered-byPlaintiff 
reasonably relied on the representations and promises of the Defendants. 
Plaintiff also considered the Defendants' threats against the current and future 
well-being and safety of Plaintiff to be real and credible. All such representations, 
promisesa and threats were made solely for the purpose of coercing and otherwise 
EFTA00296303

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 26 of 31 
inducing Plaintiff into prolonged sexual compliance. Defendants knowingly 
benefitted financially and received things of value as a result of their-coercing and 
inducing Plaintiff into sexual compliance and otherwise participating in their 
illegal venture and  enterprise. 
COUNT I CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 
18 U.S.C. 
§ 1595 
76 . 49,Plaintiff adopts and realleges paragraphs 1 through 5-86.§ above. 
4-7 
68, 60,Defendants individually and together, 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, maintained, patronized, solicited, threatened, 
forced, and coerced Plaintiff to engage in commercial sex acts. Such actions by 
Defendants were undertaken with knowledge and/or reckless disregard of the fact 
that their threats of force, fraud, coercion, and combinations of such means would 
21
be used, and were in fact used, in order to cause Plaintiff to engage in commercial 
sex acts. In so doing, Defendants violated 18 U.S.C. §§1591 through 1594 
andW91, 
A' 
'onallv. Defendants Enstein. Maxwell. and ainatithalLyand 
EFTA00296304

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 27 of 31 
together, knowingly concealed, removed, confiscated, and possessed Plaintiff's 
passport and associated immieratioulocuments, in the course of violating 18 
U.S.C. § 1591, and with the intent of violating 18 U.S.C. § 1591, and to prevent, 
restrict, attempt to restrict, without lawful authority, Plaintiff's liberty to move 
or travel, in order to maintain the sexual services of Plaintiff, while Plaintiff 
was a victim of a severe form of sex trafficking, as defined in section 103 of the 
Trafficking Victims Pi ted
0,
cgd
2
I
/0
se
lat 
in 22 U.S.C.. 
1 2. In 
doing, Defendants violated 18 U.S.C. § 1592. These Defendants also obstructed, 
and attempted to obstruct and to interfere with the enforcement of 18 U.S.C. 
1592. 
70. Additionally, Defendants knowingly benefitted, financially and by 
receiving things of value, from participating in a venture (the Epstein sex 
trafficking venture enterprise) which had engaged in acts in violation of 18 
U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in such 
violations. In so doing, Defendants violated 18 U.S.C. § 1593A. 
71. Additionally, Defendants attempted to violate 18 U.S.C. § 1591. In so 
dokg,
1 Defendants violated 18 U.S.C. § 1594(a). 
27 
72. Additionally, Defendants conspired with each other, and with other 
persons known and unknown, to violate 18 U.S.C. § 1592. In so doing, 
Defendants violated 18 U.S.C. § 1594(b), 
73. Additionally, Defendants conspired with each other, and with other 
EFTA00296305

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 2N of 31 
persons known and unknown, to violate 18 U.S.C. § 1591. In so doing, 
Defendants violated 18 U.S.C. 8 1594(c). 
74. By virtue of their violations of 18 U.S.C. §§ 1591, 1592, 1593A, and 1594, 
Defendants are subject to civil causes of action under 18 U.S.C. § 
-1-59576-1,Defendatits-additionetly-prefited-from-the-sex-tr-efftelEing-ef-Plein 
ebstrueted4nvestigatiens-ef-the-vielatiensauerapted-and-eenspiced-te-vielate,and 
suseeeded-in-vielatiugr i-8-1447C-4*-1-541-threugh-1445,by-the-Gemmissien-ecthe 
tofts-and-efimes-deser-ibed-iii-this-sernplaiiii1595 by Plaintiff, who is a victim of 
their violations. 
75. 62.Certain property of Defendant Epstein's was essential to the commission of 
the federal crimes and torts described herein, including the use of multiple private 
aircraft including a Boeing aircraft (of make and model B-727- 31H with tail number 
N908JE) and a Gulfstream aircraft (of make and model G- 1159B with tail number 
N909JE). Such aircraft, along with other of Defendants' 
4S property, were used as means and instruments of Defendants' tortious and 
criminal offenses and, as such, are subject to forfeiture. 
76. (Additionally, Defendant Epstein's New York mansion, located at 9 East 
71st Street, New York, New York, in the Southern District of New York,  and his 
private island located in the United States Virgin Islands, were used as means and 
instruments of Defendants' tortious and criminal offenses and, as such, are subject to 
EFTA00296306

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 29 of 31 
forfeiture. 
77. 4zhAs a direct and proximate result of Defendants' commission of the 
aforementioned criminal offenses enumerated in Title 18 U.S.C. § 1591 ct. scq.1591, 
1592. 1593A. and 1594, and the associated civil remedies provided in § 1595, 
Plaintiff has in the past suffered and will continue to suffer injury and pain; 
emotional distress; psychological and pcychi atricpsychiatric trauma; mental 
anguish; humiliation; confusion; embarrassment; loss of self- esteem; loss of 
dignity; loss of enjoyment of life; invasion of privacy; and other damages associated 
with Defendants' actions. Plaintiff will incur further medical and psychological 
expenses. These injuries are permanent in nature and Plaintiff will continue to suffer 
from them in the future. In addition to these losses, Plaintiff has incurred attorneys' 
fees and will be required  do so in the future. 
WHEREFORE, Plaintiff demands judgment against Defendants for 
compensatory and general  damages, attorneys fees, punitive damages and such 
other and further relief as this Court deems just and proper. Plaintiff hereby demands 
trial by jury on all issues triable as of right by a jury. 
Dated: kinitacy46r 20-1-7June 5, 2017. 
Respectfully Submitted, 
rimlali5a. 
EFTA00296307

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 
29 
EFTA00296308

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 
By: /s/ Bradley J. Edwards Bradley J. 
Edwards 
BOLES, SCHILLER & FLEXNER 
LLPPry4 David Boies_ David 
Boies-
Boies Schiller & Flexner LLP 
Sigrid McCawley 
Meredith Schultz 
Boies Schiller & Flexner LLP 
Paul C Cassell 
•  Quinney College of Law at the University of 
Utah 
EFTA00296309

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30  of 31 
20 
This daytime business address is provided for identification and correspondence purposes only 
and is not intended to imply institutional endorsement by the University of Utah for this private 
representation
EFTA00296310

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 31 of 31 
CERTIFICATE OF SERVICE, 
I HEREBY CERTIFY that on the 5t day of J 
2017 I electronically filed the 
foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that 
the foregoing document is being served this day on the individuals identified below via 
transmission of Notices of Electronic Filing generated by CM/ECF 
$TEPTOE & JOHNSON, LLP Michael C. Miller Justin Y.K. Chu 
Attorneys for Defendants 
UCat ,LE
SM 
ALSTON & BIRD. LLP 1Wini—Steohenson._,Lt. 
Alexander S. Lorenzo 
Attorneys for Defendant 
EFTA00296311

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 31 of 31 
31 
EFTA00296312