EFTA00023301

Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 10 of 14
Victoria's Secret's parent company. Epstein reiterated his connection to Victoria's Secret each
time he saw and spoke with Jane Doe.
40. Eventually, Epstein moved Jane Doe into his apartment building on 66'h Street, where he
housed other models and young women that he sexually abused, so that he could have complete
control over her life. Her relationship with Epstein quickly turned into one of sexual abuse.
Ghislaine Maxwell, one of Epstein's main "recruiters," along with additional unidentified
co-conspirators, would call Jane Doe and direct her to go to Epstein's mansion to give him a
massage. The massages quickly escalated into Epstein forcing himself on Jane Doe against her
will and engaging in one or more sex act with her for his own sexual gratification. Jane Doe was
terrified of Epstein, who repeatedly threatened her and made representations about his wealth,
power, and connections.
41. During Jane Doe's time with Epstein, he forced her to give him sexual massages and
made her use sex toys.
42. Epstein also flew Jane Doe to his residence in Palm Beach, Florida, where she was also
forced to give Epstein sexual massages.
43. On one occasion, Epstein forced Jane Doe to meet with a lawyer, even though she did not
express any need for a lawyer to Epstein. The lawyer she met with was a prominent attorney and
a law professor who was described to Jane Doe as Epstein's close friend and lawyer. The
lawyer appeared to be interviewing her, asking personal questions about her family's financial
situation. The meeting had no legal purpose, and Epstein later used the information that the
lawyer had obtained through his meeting with Jane Doe to intimidate her and to keep her
compliant in his sex-trafficking scheme.
10
EFTA00023301