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in the apartment at all times, and that he was able to know and monitor where she 
was going outside the apartment. 
96. 
Plaintiff, between 2006 and 2012, was trafficked to Jeffrey Epstein's 
Island on Little Saint James on more than twenty occasions. On each occasion she 
was forced to engage in commercial sex. 
97. 
On one occasion on the Island, Plaintiff posted a publicly readable 
social media post indicating that she was on the island. The next morning, Jeffrey 
Epstein woke her while holding her wrists tightly. He was in a state of great anger. 
His laptop computer was open. He began questioning her, stating, "Why did you 
make this post? Who has read it? What have you told them?" At the end of the 
angry conversation, Jeffrey Epstein threatened Plaintiff and commanded her never 
to tell anyone about the commercial sex acts in which he was making Plaintiff 
engage, and never to tell her mother of her activities with Jeffrey Epstein. As 
punishment for the post she had made, Jeffrey Epstein did not speak with Plaintiff 
for a month. 
98. 
Jeffrey Epstein sent Plaintiff back to New York without paying her for 
any of the commercial sex acts she had engaged in with him on the island on a daily 
basis over the course of approximately one week. 
99. 
Plaintiff, from that point forward in 2007, was in fear for her safety and 
her life and knew that strict compliance with the dictates of this very powerful man 
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was required as a condition of her maintaining her safety and her life. Epstein, in a 
show of his anger and power, kicked Plaintiff out of her living quarters, essentially 
rendering her homeless overnight. At the same time, Epstein informed Plaintiff that 
she was forbidden to tell anyone about him or the sexual activities he was engaging 
in with her. 
100. 
In order to cause Plaintiff to continue to engage in commercial sexual 
activity, Jeffrey Epstein made it known that he was close friends with other powerful 
and influential people. 
101. 
Jeffrey Epstein commonly bragged to Plaintiff that Bill Clinton, Donald 
Trump, Prince Andrew, and the Sultan of Dubai were among his closest friends. 
102. 
Plaintiff overhead Jeffrey Epstein talking with the Sultan of Dubai and 
on one occasion met him in person, supporting Jeffrey Epstein's statements that he 
was closely associated with this and other powerful friends. 
103. 
Plaintiff observed photographs of Jeffrey Epstein and Bill Clinton 
together and heard Jeffrey Epstein talk about times when Clinton was on his private 
island in Little Saint James. Plaintiff never saw Bill Clinton on the island. 
104. 
As Plaintiff was trying to distance herself from Jeffrey Epstein, he 
called her into his massage room and warned her not to lie to him or there would be 
serious repercussions. He threatened her with these repercussions in order to cause 
her to continue to engage in commercial sex. Epstein worked with the people and 
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resources of his vast enterprise, including Corporate Defendants, to ensure that 
Plaintiff would comply. 
105. 
On one occasion, Jeffrey Epstein forced Plaintiff to serve hors 
d'oeuvres at Epstein's private party with Woody Allen. This server's role was 
forced upon Plaintiff in order to demean her, frighten her, and impress upon her the 
need for her to conceal the commercial sex trafficking enterprise he was running. 
106. 
Jeffrey Epstein constantly told Plaintiff that her opportunities were 
endless as long as she complied with his dictates but that he could take it all away 
from her if she did not. 
107. 
There came a time when Jeffrey Epstein forced Plaintiff to give other 
powerful friends massages. During some of these massages she was sexually 
abused, by force, against her will, by the friends whom she had been required to 
massage. 
108. 
Plaintiff, trying desperately to leave the proximity and influence of 
Jeffrey Epstein, failed to show up for multiple appointments at his mansion. 
Associate 1 contacted Plaintiff on behalf of Epstein and told her that Jeffrey Epstein 
was very upset with Plaintiff's behavior. This warning caused Plaintiff to experience 
extreme fear and anxiety for her safety and her life. This fear and anxiety ultimately 
had its intended effect and Plaintiff returned to Jefferey Epstein's mansion to 
continue to engage in commercial sex acts. 
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109. 
Jeffrey Epstein informed Plaintiff again that her career opportunities 
were endless as long as she complied with his demands. 
110. 
Jeffrey Epstein instructed Plaintiff in 2011 that he was putting her 
through massage school and she had no choice but to attend. 
111. 
While she was in massage school, Jeffrey Epstein constantly asked 
Plaintiff to recruit other young females from the massage school and became angry 
and threatening when she refused to do so. 
112. 
Jeffrey Epstein forced Plaintiff to wear certain color panties, remove 
certain body piercings, and undergo surgery by Jeffrey Epstein's doctors to remove 
body moles. Plaintiff complied with these demands with the understanding, 
conveyed to her by Epstein, that she had no other choice. . 
113. 
From 2006 through 2012, Jeffrey Epstein and his associates and 
employees recruited, enticed, harbored, transported, provided, obtained, maintained, 
and solicited Plaintiff knowing that force, threat of force, fraud or coercion would 
be used to compel Plaintiff to engage in commercial sex acts. 
114. 
The commercial sex acts included intercourse, the use of sex toys 
inserted inside Plaintiff, digital penetration, forcible touching and many other sexual 
acts. 
115. 
Plaintiff was made to engage in commercial sex acts in New York every 
year from 2006 to 2012 (except for a brief period of time in late 2008 through 2009 
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during which time Jeffrey Epstein was technically in jail in Florida); in the United 
States Virgin Islands from 2006 to 2012 (except, again, during a brief period of time 
during which Jeffrey Epstein was technically in jail in Florida); in Florida from 2007 
to 2012 (including, as noted, sexual activity while Jeffrey Epstein wore his ankle 
bracelet); and in in New Mexico between 2007 and 2010. 
116. 
There were sexual acts in addition to those described above which 
acts are too graphic and perverted to detail in the complaint. Each and all of such 
acts were required by Jeffrey Epstein and his Corporate Defendants, all of whom 
worked together to cause Plaintiff to engage in such acts, including Defendants' 
informing her that if she refused to engage in such acts she would suffer serious 
harm. 
117. 
In order to maintain Plaintiff's compliance, Defendant Jeffrey Epstein 
also informed Plaintiff that he would use his vast resources to get Plaintiff's relative 
the serious medical care she needed, further enticing Plaintiff through fraud to 
engage in commercial sex acts. 
118. 
Multiple associates, employees, and corporate entities assisted 
Defendants in causing Plaintiff to engage in commercial sex acts knowing fraud 
would be used to cause her to continue to engage in such acts. This assistance 
included making promises, scheduling medical appointments or promising to 
schedule medical appointments, promising medical care to Plaintiff's close relative, 
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and otherwise making representations about Epstein's ability to secure medical 
treatment for Plaintiff all while knowing that these representations were false and 
fraudulent and designed to entice and induce Plaintiff to commit commercial sex 
acts for Jeffrey Epstein. 
119. 
In order to cause Plaintiff to engage in each commercial sex act, Epstein 
and his co-conspirators, associates, employees and related corporate entities, 
including Corporate Defendants, used coercion, and knew that coercion would be 
used, in order to cause Plaintiff to engage in such acts. 
120. 
Epstein and various associates, employees, and related corporations and 
employees, including Corporate Defendants, worked in concert together as an 
enterprise with extraordinary power, wealth, and resources capable of affecting 
Plaintiff's life in positive or negative ways depending on her level of cooperation, 
all while knowingly conveying these promises and threats to Plaintiff. 
121. 
Epstein and others associated with Epstein, including employees of 
Defendant HBRK, bragged about Epstein's unusual political and powerful 
connections and his ability to obtain education, housing, or medical needs for young 
females who cooperated with Epstein's sexual demands. 
122. 
In addition to being explicitly reminded by Epstein, or one of his 
associates, of his extraordinary power to reward and punish Plaintiff, his power to 
do so was apparent to Plaintiff, inasmuch as: (I) she visited Epstein many times at 
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his New York mansion, located at 9 East 71 Street, New York, New York, where 
she knew that Jeffrey Epstein when in New York (The mansion was owned by 
Defendant, Nine East 71st Street, Corporation, from 1989 to 2011 until it was deeded 
to Defendant, Maple, Inc., on December 23, 2011, the entity that maintains lawful 
possession today); (2) she flew on the Boeing 747 jet owned by Defendant, JEGE, 
Inc., and controlled by Jeffrey Epstein and related companies; (3) she visited his 
Florida Mansion located at 358 Brillo Way, Palm Beach, Florida owned by Jeffrey 
E. Epstein from 1990 through December 23, 2011; and (4) she visited his private 
Island in the United States Virgin Islands, located at No. 6B Red Hook Quarter, U.S. 
Virgin Islands, previously owned by Defendant L.S.J., LLC prior to its having been 
deeded to Nautilus, Inc., a United States Virgin Islands corporation, on December 
23, 2011. 
123. 
Under Epstein's control were numerous companies with many 
employees and obvious resources, each of whom worked for the Epstein enterprise. 
While the individuals were employees of various Epstein related companies, 
including Defendant Corporations, it was clear through explicit words, actions and 
appearances that all such employees acted at Epstein's direction and for his 
protection. 
This team of individuals included chefs, butlers, receptionists, 
schedulers, secretaries, flight attendants, pilots, housekeepers, maids, sex recruiters, 
drivers and other staff members. 
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124. 
Each of the employees and associates were paid through companies 
believed to have been funded by Jeffrey Epstein and, regardless of such funding, 
were disciples of Jeffrey Epstein, constantly informing Plaintiff and other victims of 
Jeffrey Epstein's power and ability to improve or destroy a victim's life depending 
on her level of cooperation. 
125. 
The main and in many instances only function of each of the associates 
who acted at the instruction or direction of Epstein was to recruit, entice, harbor, 
transport, provide, obtain, maintain, or solicit young females, knowing that fraud or 
coercion would be used to cause each female, including Plaintiff, to engage in a 
commercial sex act. 
126. 
Each such associate described above was also employed to perform 
functions in order to avoid detection of the illegality of Epstein's commercial sex 
trafficking and to forever conceal the enterprise. 
127. 
One significant element of the sex trafficking scheme—a scheme used 
to compel commercial sex acts of young females, including Plaintiff—was its design 
and effort to avoid detection. This concealment was furthered by the enterprise's 
design, actions, and patterns of behavior which caused Plaintiff and others similarly 
situated to believe that failure to perform acts required by the scheme would result 
in serious psychological, financial, or reputational harm. 
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128. 
The scheme included frequent statements to Plaintiff and other victims 
by Jeffrey Epstein and his associates, including employees of Defendant HBRK, 
that: (1) Jeffery Epstein was of extraordinary wealth, power and influence; (2) 
Jeffrey Epstein's business and political friends, including world leaders, included 
some of the most powerful people in the world; (3) the scheme or plan was designed 
to constantly grow the number of victims through the recruitment of other victims; 
(4) Jeffrey Epstein had the ability to advance or destroy nearly anyone financially, 
reputationally, or otherwise; (5) medical and normal life necessities would be denied 
victims if they, including Plaintiff, failed to perform commercial sex acts for Epstein; 
and (6) Epstein could take away Plaintiff's and other victims' life needs such as 
shelter or housing if she or they failed to perform those acts. 
129. 
Jeffrey Epstein bragged about knowing some of the world's most 
powerful people; introduced some of them to Plaintiff; and required Plaintiff to 
perform sexual massages on some of them. These circumstances caused Plaintiff to 
believe that Jeffrey Epstein and his organization was powerful enough to cause her 
serious harm if she did not strictly follow his and their demands. 
COUNT I 
BATTERY AGAINST DARREN K. INDYKE AND RICHARD D. KAHN AS 
JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY 
E. EPSTEIN 
130. 
The Plaintiff adopts and realleges paragraphs 1 through 129 above. 
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131. 
Jeffrey Epstein committed a harmful or offensive touching against 
Plaintiff. 
132. 
As a direct and proximate result of Jeffrey Epstein's battery, the 
Plaintiff has in the past suffered and in the future will continue to suffer physical 
injury, pain, emotional distress, psychological trauma, mental anguish, humiliation, 
embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and a 
loss of her capacity to enjoy life, as well as other damages. Plaintiff incurred medical 
and psychological expenses and Plaintiff will in the future suffer additional medical 
and psychological expenses. These injuries are permanent in nature and Plaintiff 
will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. 
Epstein for compensatory and general damages, attorney's 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. 
COUNT II 
BATTERY/VIOLATION OF SECTION 130 
AGAINST DARREN K. INDYICE AND RICHARD D. KAHN AS JOINT 
PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E. 
EPSTEIN 
133. 
The Plaimiff adopts and realleges paragraphs 1 through I29 above. 
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134. 
The intentional acts of Jeffrey Epstein against Plaintiff constitute a 
sexual offense as defined in New York Penal Law § 130, including but not limited 
to the following: 
a. Sexual misconduct as defined in §130.20 inasmuch as Jeffrey Epstein 
engaged in sexual intercourse with Plaintiff without Plaintiff's consent; 
b. Rape in the first degree as defined in §130.35 inasmuch as Jeffrey 
Epstein engaged in sexual intercourse with Plaintiff by forcible 
compulsion; 
c. Criminal sexual act in the first degree as defined in §130.50 inasmuch 
as Jeffrey Epstein engaged in oral sexual conduct with Plaintiff by 
forcible compulsion; 
d. Forcible touching as defined in §130.52 inasmuch as Jeffrey Epstein, 
intentionally and for no legitimate purpose, engaged the forcible sexual 
touching of Plaintiff for the purpose of degrading or abusing her or for 
the purpose of gratifying his own sexual desire; and 
e. Sexual abuse in the third degree as defined in §130.66 inasmuch as 
Jeffrey Epstein inserted a foreign object in the vagina of Plaintiff by 
forcible compulsion. 
135. 
As a direct and proximate result of Jeffrey Epstein's violation of New 
York Penal Law § 130, the Plaintiff has in the past suffered and in the future will 
continue to suffer physical injury, pain, emotional distress, psychological trauma, 
mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, 
invasion of her privacy and a loss of her capacity to enjoy life, as well as other 
damages. Plaintiff incurred medical and psychological expenses and Plaintiff will 
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in the future suffer additional medical and psychological expenses. These injuries 
are permanent in nature and Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. 
Epstein for compensatory and general damages, attorney's 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. 
COUNT III 
CAUSE OF ACTION AGAINST DARREN K. 'NOVICE AND RICHARD D. 
KAHN AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF 
JEFFREY E. EPSTEIN PURSUANT TO 18 U.S.C. 1595 
136. 
Plaintiff adopts and realleges paragraphs 1 through 129 above. 
137. 
Jeffrey Epstein, 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, obtained, maintained, patronized, solicited, threatened, forced, or coerced 
Plaintiff to engage in commercial sex acts. 
138. 
Such actions were undertaken knowing that his use of force, threats of 
force, fraud, coercion, and/or combinations of such means would be used, and were 
in fact used, in order to cause Plaintiff to engage in commercial sex acts. In doing 
so, Jeffrey Epstein violated 18 U.S.C. *1591. 
139. 
Furthermore, Jeffrey Epstein attempted to violate 18 U.S.C. § 1591. In 
so doing, violated 18 U.S.C. § 1594(a). 
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140. 
Jeffrey Epstein conspired with each member of the enterprise, and with 
other persons known and unknown, to violate 18 U.S.C. § 1591. In so doing, 
violated 18 U.S.C. § 1594(c). 
141. 
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). 
142. 
By virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, 
1593A, and 1594, Defendant Darren K. Indyke and Richard D. Kahn as Joint 
Personal Representatives of the Estate of Jeffrey E. Epstein is subject to civil causes 
of action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of the violations. 
143. 
Certain property of 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 Jeffrey Epstein's property, were used 
as means and instruments of Jeffrey Epstein's tortious and criminal offenses and, as 
such, are subject to forfeiture. 
144. 
Additionally, Jeffrey 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 
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instruments of Jeffrey Epstein's tortious and criminal offenses and, as such, are 
subject to forfeiture. 
145. 
As a direct and proximate result of Jeffrey Epstein's commission of the 
aforementioned criminal offenses enumerated in 18 U.S.C. § 1591, 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 psychiatric 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' 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 the Estate of Jeffrey E. 
Epstein for compensatory and general damages, attorney's 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. 
COUNT IV 
CAUSE OF ACTION AGAINST 
NINE EAST 71ST STREET. CORPROATION 
PURSUANT TO 18 U.S.C. § 1595 
146. 
Plaintiff adopts and realleges paragraphs 1 through 129 above. 
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147. 
Defendant, by and through its management and personnel, 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, obtained, maintained, 
patronized, solicited by any means Plaintiff from 2006 through 2011. 
148. 
Defendant, by and through its management and personnel, knew that 
means of fraud or coercion, and/or combinations of such means, would be used, and 
were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In 
doing so, Defendant corporation violated 18 U.S.C. §1591. 
149. 
Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 
1591. In so doing, violated 18 U.S.C. § 1594(a). 
150. 
Defendant, by and through its management and personnel, conspired 
with other members of the enterprise, and with other persons and companies, known 
and unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 
U.S.C. § 1594(c). 
151. 
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). 
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152. 
By virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, 
1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. § 
1595 by Plaintiff, who is a victim of the violations. 
153. 
Defendant, by and through its management and personnel, participated 
in a venture with Jeffrey Epstein's enterprise by knowingly recruiting, transporting, 
soliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would 
be used to cause Plaintiff to commit a commercial sex act. 
154. 
As a direct and proximate result of Defendant corporation's 
commission of the aforementioned criminal offenses enumerated in 18 U.S.C. § 
1591, 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 psychiatric 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' 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 Nine East 71st Street, 
Corporation for compensatory and general damages, attorney's fees, punitive 
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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. 
COUNT V 
CAUSE OF ACTION AGAINST MAPLE, INC. 
PURSUANT TO 18 U.S.C. & 1595 
155. 
Plaintiff adopts and realleges paragraphs 1 through 129 above. 
156. 
Defendant, by and through its management and personnel, 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, obtained, maintained, 
patronized, solicited by any means Plaintiff beginning in 2011. 
157. 
Defendant, by and through its management and personnel, knew that 
means of fraud or coercion, and/or combinations of such means, would be used, and 
were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In 
doing so, Defendant corporation violated 18 U.S.C. §1591. 
158. 
Defendant, by and through its management and personnel 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, Defendant corporation violated 18 U.S.C. § 1593A. 
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159. 
Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 
1591. In so doing, violated 18 U.S.C. § 1594(a). 
160. 
Defendant, by and through its management and personnel, conspired 
with other members of the enterprise, and with other persons and companies, known 
and unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 
U.S.C. § 1594(c). 
161. 
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). 
162. 
By virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, 
1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. § 
1595 by Plaintiff, who is a victim of the violations. 
163. 
Defendant, by and through its management and personnel, participated 
in a venture with Jeffrey Epstein's enterprise by knowingly recruiting, transporting, 
soliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would 
be used to cause Plaintiff to commit a commercial sex act. 
164. 
As a direct and proximate result of Defendant corporation's 
commission of the aforementioned criminal offenses enumerated in 18 U.S.C. § 
1591, 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; 
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emotional distress; psychological and psychiatric 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 ' 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 Defendant, MAPLE, 
INC., for compensatory and general damages, attorney's 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. 
COUNT VI 
CAUSE OF ACTION AGAINST L.S.J., LLC 
PURSUANT TO 18 U.S.C. § 1595 
165. 
Plaintiff adopts and realleges paragraphs 1 through 129 above. 
166. 
Defendant, by and through its management and personnel, 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, obtained, maintained, 
patronized, solicited by any means Plaintiff. 
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167. 
Defendant, by and through its management and personnel, knew that 
means of fraud or coercion, and/or combinations of such means, would be used, and 
were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In 
doing so, Defendant corporation violated 18 U.S.C. §1591. 
168. 
Defendant, by and through its management and personnel 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, Defendant corporation violated 18 U.S.C. § 1593A. 
169. 
Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 
1591. In so doing, violated 18 U.S.C. § 1594(a). 
170. 
Defendant, by and through its management and personnel, conspired 
with other members of the enterprise, and with other persons and companies, known 
and unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 
U.S.C. § 1594(c). 
171. 
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). 
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