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Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 3 of 14
As with Jane Doe 41 and Jane Doe #2, Jane Doc #3 was repeatedly sexually abused by
Epstein. The Government then concealed from Jane Doe #3 the existence of its NPA from Jane
Doc #3, in violation of her rights under the CVRA. If allowed to join this action, Jane Doc #3
would prove the following:
In 1999, Jane Doc #3 was approached by Ghislaine Maxwell, one of the main women
whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator
in his sexual abuse and sex trafficking scheme. In fact, it became known to the government that
Maxwell herself regularly participated in Epstein's sexual exploitation of minors, including Jane
Doe #3. Maxwell persuaded Jane Doc #3 (who was then fifteen years old) to come to Epstein's
mansion in a fashion very similar to the manner in which Epstein and his other co-conspirators
coerced dozens of other children (including Jane Doe 41 and Jane Doe #2). When Jane Doc #3
began giving Epstein a "massage," Epstein and Maxwell turned it into a sexual encounter, as
they had done with many other victims. Epstein then became enamored with Jane Doe #3, and
with the assistance of Maxwell convened her into what is commonly referred to as a "sex slave."
Epstein kept Jane Doe #3 as his sex slave from about 1999 through 2002, when she managed to
escape to a foreign country and hide out from Epstein and his co-conspirators for years. From
1999 through 2002, Epstein frequently sexually abused Jane Doe #3, not only in West Palm
Beach, but also in New York, New Mexico, the U.S. Virgin Islands, in international airspace on
his Epstein's private planes, and elsewhere.
Epstein also sexually trafficked the then-minor Jane Doe, making her available for sex to
politically-connected and financially-powerful people. Epstein's purposes in "lending" Jane Doe
(along with other young girls) to such powerful people were to ingratiate himself with them for
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