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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
JANE DOE 43, 
Plaintiff, 
VS. 
JEFFREY EPSTEIN, GHISLAINE 
MAXWELL, 
LESLEY 
GROFF, AND 
Defendants. 
COMPLAINT 
JURY TRIAL DEMANDED 
CASE NO.: 
Plaintiff Jane Doe 43, by and through her undersigned counsel, for her 
claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, 
M, 
Lesley Grog and 
, alleges upon personal knowledge with 
respect to her own acts and status and upon information and belief as to all other 
matters, as follows: 
1. 
This cause of action arises under federal statutes and jurisdiction is 
proper under 28 U.S.C. § 1331. 
2. 
Plaintiff files this Complaint under a pseudonym in order to protect 
her identity because this Complaint makes allegations of a sensitive sexual nature 
and disclosure of Plaintiffs name publicly will cause further harm to her. 
3. 
At all times material to the events alleged in this cause of action the 
Plaintiff was a citizen of South Africa residing in New York, New York. 
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4. 
At all times material to this cause of action Defendant Jeffrey Epstein 
had multiple residences, including in New York, New York and the United States 
Virgin Islands. He is currently a citizen of the United States and a resident of New 
York and the U.S. Virgin Islands. 
5. 
At all times material to this cause of action Defendant Jeffrey Epstein 
was an adult male born in 1953. 
6. 
At all times material to this cause of action Defendant Ghislaine 
Maxwell was residing in in New York, New York and was a citizen of Great 
Britain and France. 
7. 
At all times material to this cause of action 
was residing 
in New York, New York, and, on information and belief, was a citizen of the 
United States. 
8. 
At all times material to this cause of action Lesley Groff was residing 
in New York, New York and, on information and belief, was a citizen of the 
United States. 
9. 
At all material times, 
was residing in New York, 
New York and, on information and belief, was a citizen of the United States. 
10. 
Including because a substantial part of the events and omissions 
giving rise to this cause of action occurred in the Southern District of New York, 
venue is proper in that District. 28 U.S.C. § 1391(b)(2) 
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11. 
At all times material to this cause of action, Defendants Jeffrey 
Epstein, Ghislaine Maxwell, 
M, 
Lesley Groff, and 
owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit 
or conspire to commit intentional or tortious illegal acts against her. 
FACTUAL ALLEGATIONS 
12. 
At all times material to this cause of action Defendant Jeffrey Epstein 
was an adult male over 50 years old. Defendant Epstein is known as a billionaire 
who uses his extraordinary wealth to commit illegal sexual crimes in violation of 
federal and state statutes and to employ numerous others, including the named 
Defendants, to conspire and assist in committing those crimes and additional torts 
as well as to protect and conceal his crimes and torts from being discovered. 
13. 
Defendant Epstein displays his enormous wealth, power and influence 
to his employees; to the victims procured for sexual purposes; and to the public in 
order to advance and carry out his crimes and torts. At all relevant times, 
Defendant Epstein owned and continues to own, directly or through nominee 
individuals used to conceal his interests, a fleet of airplanes, motor vehicles, boats 
and one or more helicopters. He owned and owns numerous properties and homes, 
including a 51,000-square-foot mansion in Manhattan; a $30 Million, 7,500-acre 
ranch in New Mexico; a 70-acre private island formerly known as Little St. James 
in or near St. Thomas, U.S. Virgin Islands; a mansion in London, England; a home 
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in Paris, France; and a mansion in Palm Beach County, Florida. The allegations 
herein primarily concern the defendant's conduct while at his townhouse in New 
York; on one or more of his private airplanes; and on his private island in the 
United States Virgin Islands. 
14. 
Defendant Epstein has a compulsive sexual preference for young 
females as young as 13 and as "old" as 25. Defendant had sex with young females 
virtually every day and assisted in the development and execution of a sex 
trafficking scheme designed to fulfill his sexual desires. 
15. 
Defendant Maxwell was for decades the highest-ranking employee of 
the Defendants' sex trafficking enterprise. She herself recruited young females; 
oversaw and trained other recruiters on how best to recruit girls for sex; developed 
and executed schemes designed to recruit young females; and ensured that all 
participants of the Defendants' sex trafficking scheme acted in certain specific 
ways in order to advance the purposes of the scheme and conceal it from law 
enforcement. 
16. 
Defendant 
recruited young females and maintained Epstein's 
sex schedule in order to ensure that he was not without the sexual favors of young 
females for any extended period of time. Defendant 
also handled travel 
arrangements for the various females being exploited for sexual purposes. 
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Defendant 
reported directly up the enterprise's line of authority to 
Defendant Maxwell. 
17. 
Defendant Epstein employed many recruiters of young females. The 
nature of the Defendants' sex trafficking scheme enabled victims themselves, such 
as Defendant 
to elevate their status to that of a paid recruiter of other 
victims. Recruiters were taught by Defendants Epstein and Maxwell to inform 
targeted victims that Epstein possessed extraordinary wealth, power, resources and 
influence; that he was a philanthropist who would help female victims advance 
their careers and lives; and that the recruits needed only to provide Epstein with 
body massages in order to avail themselves of his financial assistance and 
influence. In fact, however, these representations were fraudulent. The vast 
majority of girls were required to perform intimate sexual acts at the Defendants' 
direction and the Defendants did not help or intend to help advance the victims' 
careers. 
18. 
Defendant Groff coordinated schedules between Defendant Epstein 
and the various young females used for sex; made travel arrangements for the girls; 
tended to their living needs; and communicated with them in order to maintain 
their compliance with the rules of behavior imposed upon them by the enterprise. 
19. 
The Defendants, led primarily by Defendants Epstein and Maxwell, 
fulfilled Epstein's compulsive need for sex with young females by preying on their 
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personal, psychological, financial, and related vulnerabilities. The Defendants' 
tactics included promising the victims money, shelter, transportation, employment, 
admission into educational institutions, educational tuition, and other things of 
value in exchange for sex. 
20. 
Defendants' sex trafficking venture and enterprise operated in a 
hierarchal structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the 
top and underlings below. Underlings included the other named Defendants as 
well as unnamed co-conspirators such as various housekeepers and butlers; an 
airplane pilot; and various employees, assistants and associates. Wittingly and 
unwittingly, such underlings performed their respective roles with the purpose and 
effect of insuring that the enterprise supplied young females to Defendant Epstein 
and others for sexual purposes. At all times materials to this complaint, the 
venture and enterprise was a group of two or more individuals associated in fact 
and deed. 
21. 
Defendants Epstein and Maxwell, with help from assistants, associates 
and underlings, recruited and procured hundreds of girls over the decades of the 
operation of their scheme. Such recruitment and procurement included fraud, 
coercion, the threat of coercion, and a combination of these and similar tactics. 
Following the Defendants' recruitment and procurement of the females to join 
Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent 
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promises, coercion, and threats of coercion in order to entice young females into 
sex and, once sexual activities ensued, to cause them to remain in the enterprise. 
The Defendants also transported females in interstate and foreign commerce and in 
ways that affected interstate and foreign commerce. 
22. 
Defendants 
specifically 
targeted 
underprivileged, 
emotionally 
vulnerable and/or economically disadvantaged young females to join the 
Defendants' enterprise. 
23. 
It is unknown exactly how long Defendant Epstein and Maxwell's 
aforementioned criminal and illegal enterprise operated, although it was at least 
continuously and actively in operation from the mid-1990's through and including 
the calendar year 2007. 
24. 
Defendant Epstein has continued the enterprise and conspiracy up to 
the present time. 
25. 
In 2005, Defendant Epstein and numerous co-conspirators within the 
enterprise were the subjects of a Palm Beach, Florida Police Department criminal 
investigation which revealed that Defendant Epstein had engaged in sexual 
activities with dozens of young teenage children. Each child was lured into 
Defendant Epstein's Palm Beach mansion with a promise that she would receive 
money for providing him with a body massage, although once there, each child 
was made to engage in a sex act in order to receive the promised compensation. 
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Several were also made to engage in sex with another of Defendant Epstein's 
female sexual traveling companions. 
26. 
In 2006, the Palm Beach Police Department investigation was turned 
over to the FBI and the United States Attorney's Office for the Southern District of 
Florida. The United States Attorney's Office investigated Defendant Epstein and 
his co-conspirators for their violations of numerous federal statutes, including 18 
U.S.C. §1591, one of the statutory bases for this complaint. 
27. 
The United States Attorney's investigation continued from 2006 
through September 2007, at which time a Non-Prosecution Agreement was signed 
between Jeffrey Epstein and the United States Attorney's Office deferring federal 
prosecution of Defendant Epstein and his numerous co-conspirators for identified 
federal sex crimes against more than 30 minors. 
28. 
From late 2006 through September 2007, Epstein's team of lawyers 
negotiated with the federal government in an effort to avoid the filing of the fifty-
three-page draft indictment of Epstein. During these negotiations, Defendant 
Epstein decamped from Palm Beach to New York and the U.S. Virgin Islands in 
order to convey an image to prosecutors that he and his co-conspirators had 
stopped committing sex crimes. 
29. 
Remarkably, however—as this case will highlight—Defendant 
Epstein and his co-Defendants, including the other defendants named herein, did 
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not abandon their sex trafficking enterprise even while they were under state and 
federal investigation for crimes committed in violation of 18 U.S.C. § 1591, among 
other laws, and even as Defendants and their attorneys were busy arguing Epstein's 
innocence and publicly defaming his victims as liars. Rather, Defendants merely 
changed their style. Instead of targeting local Palm Beach Florida high school 
girls, the Defendants transported young females from other places in the U.S. and 
abroad and brought them to Defendant Epstein's mansion in New York and his 
private island in the Virgin Islands. 
30. 
In June of 2008, Epstein pleaded guilty to Florida state felony sex 
offenses for procuring a minor for prostitution and soliciting prostitution by 
minors. 
31. 
Defendants Epstein and Maxwell developed and implemented a 
sophisticated system designed to insulate them from criminal and civil liability by 
protecting them from potential testimony of knowledgeable subordinates. The 
system included requiring subordinates to sign confidentiality agreements covering 
civil and criminal activity; requiring subordinates and victims to refrain from 
speaking with law enforcement officials; requiring them to notify Defendant 
Epstein's lawyers in the event they (subordinates and victims) were contacted by 
law enforcement officials; requiring them to accept the representation of attorneys 
paid for by Defendant Epstein; requiring them to invoke the Fifth Amendment in 
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response to questions they might be asked by investigators and prosecutors; 
requiring them to invoke the Fifth Amendment in order to refuse to turn over 
incriminating and non-incriminating evidence to law enforcement officers; 
requiring them to destroy evidence or refuse to reveal knowledge of destroyed 
evidence; and requiring them generally to refuse all cooperation with law 
enforcement officials or investigations. 
32. 
In 2005, Defendant Epstein and other co-conspirators, aware that law 
enforcement officials were preparing imminently to execute a search warrant of his 
home, removed computer systems that logged information about Epstein and his 
co-conspirators' illegal and criminal conduct; the identities of witnesses; nude 
photographs of young females; scheduling books; message pads; tangible items 
such as vibrators and toys; and other incriminating matter. 
33. 
Commencing in approximately October 2006 and continuing through 
April 2007, Defendants recruited Plaintiff into their sexual enterprise by 
fraudulently promising to use their connections and resources to secure her 
admission to an institution of higher education at the expense of Defendant 
Epstein. 
34. 
Defendant 
was working as one of the enterprise's recruiters 
of young females when she approached and recruited Plaintiff. 
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35. 
Defendant 
informed Plaintiff that she would introduce 
Plaintiff to Defendant Epstein, whom she described as a wealthy philanthropist 
who regularly used his wealth, influence and connections to help financially poor 
females like Plaintiff achieve their personal and professional goals and aspirations. 
36. 
Defendant 
reported to her superiors, Defendants M, 
Groff and Maxwell, and was paid for her recruitment of young females, including 
the recruitment of Plaintiff. 
37. 
Defendant 
introduced Plaintiff to Defendant Epstein, who 
confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff 
admitted into The Fashion Institute of Technology, known as "F.I.T.", in New 
York City, or into a similar institute of higher learning offering a curriculum of 
fashion industry training. Defendants Maxwell, 
and Groff each confirmed 
this promise to Plaintiff many times. 
38. 
Defendant Maxwell told Plaintiff she would need to provide 
Defendant Epstein with body massages in order to reap the benefits of his and 
Maxwell's connections. Maxwell and Epstein also threatened Plaintiff that, while 
they had the ability to advance her education and career, they also had the ability to 
make sure that she would obtain no formal education or modeling agency contracts 
if she failed to provide the sexual favors desired by Defendant Epstein or abide by 
the instructions given her by Defendants Epstein and Maxwell. 
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39. 
Plaintiff reasonably believed that her compliance with Defendants' 
demands was crucial to her physical, psychological, financial, and reputational 
survival. 
40. 
Defendant Maxwell instructed Plaintiff how to massage Epstein using 
the techniques that he preferred. During Plaintiff's first massage, Defendant 
Epstein converted it into a sexual act and made it known to Plaintiff that further 
sex would be required in order for her to obtain the assistance he promised and to 
avoid Defendants' threatened retaliation if Plaintiff did not perform as demanded. 
41. 
Defendants Maxwell and Epstein informed Plaintiff that other young 
females in Defendant Epstein's company were there not only to provide massages, 
but also sexual acts. 
42. 
Plaintiff was instructed dozens of times to provide body massages to 
Defendant Epstein, both at his townhouse in New York and on his private island in 
the U.S. Virgin Islands. Each time she was so instructed she was also required to 
perform a sexual act with Defendant Epstein. The Defendants transported Plaintiff 
in interstate and foreign commerce, and affecting interstate and foreign commerce, 
for these sexual purposes. 
43. 
During many sexual encounters, Defendant Epstein gave Plaintiff no 
option, opportunity or choice not to participate in the prescribed sexual acts. 
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44. 
Defendant Maxwell frequently controlled the assignment, or 
"rotation," of Plaintiff and the other young females concerning the time, place and 
manner of the sex acts they were told to provide to Defendant Epstein. Defendants 
Maxwell and Epstein also required Plaintiff to engage in sex acts with other 
females. 
45. 
Defendants Epstein and Maxwell intimidated, threatened, humiliated 
and verbally abused Plaintiff in order to coerce her into sexual compliance. These 
Defendants threatened Plaintiff with serious harm, as well as serious 
psychological, financial, and reputational harm, with the purpose and effect of 
compelling Plaintiff to perform and continue performing the demanded 
commercial sexual activity. 
46. 
On one occasion, after suffering verbal abuse and threats by 
Defendants Epstein, Maxwell, and M, 
Plaintiff attempted to escape from 
Defendant Epstein's private island. 
A search party led by Defendant Epstein 
located her and physically returned her to the main house on the island. Through 
these and other actions, the Defendants intended to cause, and did cause, Plaintiff 
to believe that failure to perform the actions they requested would result in 
physical restraint and potential harm to her person, as well as harm to her 
reputation, employability, and stable state of mind. 
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47. 
Defendant Epstein's wealth, influence, power and connections were 
used both as an inducement to provide sex (in exchange for promises of support), 
and as a means of threatening punishment (should Plaintiff refuse to comply with 
Defendants' instructions). 
48. 
In addition to Plaintiff's being trafficked on Defendant Epstein's 
private plane, Defendants Groff, Maxwell and 
with the knowledge of and 
instruction by Defendant Epstein, arranged Plaintiffs commercial air travel on 
numerous occasions for the purpose of causing Plaintiff to commit commercial sex 
acts. 
49. 
Defendants provided living quarters for Plaintiff at 301 East 66 Street, 
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. 
50. 
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 Epstein and others in the times, places and manners demanded by 
Defendants. Plaintiff reasonably relied on those representations. In fact, however, 
those representations were knowingly false, were not acted upon, and were made 
by Defendants Epstein and Maxwell solely for the purpose of maintaining 
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Plaintiffs financial dependence on, emotional vulnerability to, and sexual 
compliance with Defendants Epstein and Maxwell and their demands. The other 
Defendants intentionally repeated those representations and intentionally attempted 
to convince Plaintiff that the representations were true and could be relied upon. 
51. 
In January 2007, Defendants sent Plaintiff from the United States to 
South Africa in part to recruit, for a promised fee, one or more aspiring female 
models supposedly for Defendant Epstein to use as an alleged personal assistant. 
Defendants Epstein and Maxwell continuously and frequently demanded that 
Plaintiff fulfill this task as a condition of her receiving the education, career and 
related benefits promised by Defendants Epstein and Maxwell. 
Based upon 
Plaintiffs experience with Defendants, however, she did not believe that the 
requested model would be placed in a legitimate position of employment with 
Defendant Epstein but would, instead, be forced into sexual servitude. As a result, 
Plaintiff deliberately refused to perform the recruitment assignment. 
52. 
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. 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 
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(approximately 125 pounds) to 52 kilograms (approximately 114 pounds). 
Believing she had no practical choice in the matter, Plaintiff attempted to comply 
with the order but, given her physical height and structure and her existing low 
body weight, the diet imposed upon her placed her in serious physical jeopardy, 
including kidney malfunction and extreme emotional and psychological distress. 
53. 
Defendants Epstein and Maxwell called Plaintiffs parents in South 
Africa to tell them that Defendants would take good care of Plaintiff when she 
returned to the United States and that they would use their connections and 
influence to have her admitted to F.I.T. or another well-regarded fashion school. 
54. 
In February of 2007, Plaintiff returned to New York and was promptly 
ordered by Defendant Maxwell to have sex with Defendant Epstein. Defendants 
Maxwell and Epstein fraudulently promised her again that her sexual compliance 
would be rewarded with admission to F.I.T. or a comparable college, a promise 
which they knew to be false. 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 as they had destroyed the careers of others 
who had failed to comply. 
55. 
Defendants Epstein and Maxwell continued to provide Plaintiff with 
things of value in exchange for Plaintiffs continued compliance with Epstein's 
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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 
college admission or on-going education, false promises they repeatedly made in 
order to coerce her into commercial sex acts. 
56. 
Defendants Epstein and Maxwell's sexual demands on Plaintiff 
continued while she was in New York or other geographic proximity to the 
Defendants. In addition to their requiring Plaintiff to provide Defendant Epstein 
with sex acts, Defendants continued to pressure her to lose excessive amounts of 
body weight and offered her no opportunity to decline or resist their instructions. 
57. 
In May, 2007, Plaintiff left the United States and did not return. 
58. 
Defendants' representations and promises were all false and 
fraudulent. Their threats were considered by Plaintiff to be real and credible. All 
such representations, promises and threats were made solely for the purpose of 
coercing and otherwise inducing Plaintiff into prolonged sexual compliance. 
Defendants knowingly benefitted financially and received things of value as a 
result of their participating in their illegal enterprise. 
COUNT I 
CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 18 U.S.C. 
4 1595 
59. 
Plaintiff adopts and realleges paragraphs 1 through 58 above. 
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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 
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 and are 
subject to civil causes of action under 18 U.S.C. § 1595. 
61. 
Defendants additionally profited from the sex trafficking of Plaintiff; 
obstructed investigations of the violations; attempted and conspired to violate, and 
succeeded in violating, 18 U.S.C. §§ 1591 through 1595, by the commission of the 
torts and crimes described in this complaint. 
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' 
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property, were used as means and instruments of Defendants' tortious and criminal 
offenses and, as such, are subject to forfeiture. 
63. 
Additionally, Defendant Epstein's New York mansion, located at 9 
East 71st street, New York, 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 forfeiture. 
64. 
As a direct and proximate result of Defendants' commission of the 
aforementioned criminal offenses enumerated in Title 18 U.S.C. § 1591 et. seq. 
and the civil remedies provided in § 1595, Plaintiff has in the past suffered and will 
continue to suffer injury and pain; emotional distress; psychological and psychi-
atric 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 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 do so in the future. 
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WHEREFORE, Plaintiff demands judgment against Defendants for 
compensatory 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. 
Dated: January 26, 2017 
Respectfully Submitted, 
BOIES, SCHILLER & FLEXNER LLP 
By: /s/ David Boies 
David Boies 
Boies Schiller & Flexner LLP 
333 Main Street 
Armonk, New York 10504 
T: 
E: 
Alex Boies 
Boies Schiller & Flexner LLP 
575 Lexington Ave., 76 Fl. 
New York, New York 10022 
T: 
E:
Sigrid McCawley 
Meredith Schultz 
Boies Schiller & Flexner LLP 
401 East Las Olas Blvd., Ste. 1200 
Fort Lauderdale, Florida 33301 
T: 
E: 
E: 
Pro Hoc Vice to be filed 
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