EFTA00296277

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EFTA00296277

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page I of 31 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
COMPLAINT 
CASE NO.: 1:17-CV-00616 
JANE DOE 43, 
U 
T 
14
I 
A 
V WIC 
3.- X ttel V 
Plaintiff 
xf, 
EFFREY EP TEIN 
HI LAINE MAXWELL 
AND 
Defendants. 
FIRST AMENDED COMPLAINT 
Plaintiff JANE DOE 43, by and through her undersigned counsel, for her 
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 2 of 31 
claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, 
and 
alleges upon personal knowledge with respect to her 
own acts and status, and upon personal knowledge, 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. *section 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 
andthe disclosure of name-publielsfrwillwhich, in association with her 
name, would 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. 
4. At all times material to this cause of action Defendant Jeffrey Epstein had 
multiple residences, including in New York, New York (within the Southern 
District of New York)  and the United States Virgin Islands. He is currently a citizen 
of the United States and claims to be  a resident ofNew--Y-Ork—ancl 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. 
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 3 of 31 
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 a United States 
citizen, residing in New York, New York,  and, 
of
eiti-zea-ef-the-14nite€1-States (within the Southern District of New York). 
8. At all times material to this cause of action 
was residinga United 
States citizen, employed by New York based company and regularly 
conducting business in New York, New York and, on information and belief, was a 
citizen of the United States(within the Southern District of New York). 
9.At all material times, n-was-resitling-in-New--Y-eFk r New 
YOFIreandr  en-infennatien-and-beliefrwas-a-eitizell-ef-the-binited-States, 
9. -1414neluding-bec-ausea substantial part of the acts,  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. *section 1391(b)(2) 
2 
10. -1-lat all times material to this cause of action, Defendants Jeffrey Epstein, 
Ghislaine Maxwell, 
an
—ann 
owed a 
duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire 
to commit intentional, criminal, fraudulent, or tortious illegal acts against her, 
including any acts in violation of 18 U.S.C. §1595. 
FACTUAL ALLEGATIONS 
EFTA00296280

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 4 of 31 
11. 4-2,At all times material to this cause of action, Defendant Jeffrey Epstein was 
an adult male over 50 years old. Defendant Epstein is knownwidely recognized as a 
billionaire who uses his extraordinary wealth to commit illegal sexual crimes in 
violation of federal and state statutes and to employ and conspire with a group of 
numerous others, including each of  the named Defendants, to eenspir-e-and-assist in 
committing those crimes and additional torts as well as to preteet-and-conceal his
crimes and torts of the Epstein sex trafficking group from being discovered. 
12 44-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. For example,  he owned and-ewns(directly or indirectly) a Boeing 
aircraft (of make and model B-727-31H with tail number N908JE) and a 
Gulfstream aircraft 
3 
of make and model G-1159B with tail number N909JE 
He also owned 
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 Islandsa 
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 5 of 31 
mansion in London, England; a home 
; 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. Epstein used all of the real and personal property 
described in this paragraph to facilitate the illegal sex trafficking venture and 
enterprise described in this Complaint and in furtherance of that venture and 
enterprise, 
a 
4-4:Defendant Epstein has a compulsive sexual preference for young females 
as young as 13 and as told!: as 25. Through information and belief  Defendant 
hed-see-with-yeung-fenieieeaaiFtueilygastein engages iusxual actsa 
range every day and accicted in the development and execution ofdeveloped, 
through the employment of and conspiracy with the other Defendants, a sex 
trafficking schemeventure and enterprise designed to fulfill his sexual desires: 
and conceal the operation of the venture and enterprise and conduct of its 
participants. As part of the venture and enterprise, Epstein also provided 
young females for sexual purposes to his friends in order to secure social, 
business, and other contacts as well as other things of value. 
14. 44:Defendant Maxwell was for decades the highest-ranking employee of the 
Defendants' sex trafficking venture and  enterprise. She herself recruited young, 
including underage, 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 
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 6 of 31 
acted in certain specific ways in order to advance the purposes of the scheme and 
eeneeal-4, including providing young females to Epstein for sexual purposes on 
a daily basis, and concealing these activities from law enforcement. 
4-67Defendant 
recruited young females for Epstein for sexual 
purposes, brought gifts to females in order to entice those females to commit 
sex acts with Epstein and to assist in concealing the illegal sexual conduct of the 
venture and enterprise, and maintained 
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. 
4 Defendant 
 
n intend art f the sex traffi kin venture and 
enterprise and reported directly up the 
line of authority to 
DefendeetDefendants Maxwell and Epstein. 
-1-7,Defendant Epstein employed many recruiters of young females. The 
nature of the Defendants' sex trafficking schemeventure and enter ris  enabled 
victims themselvesTsueh-as-Defendent 
to elevate their status to that of a 
paid recruiter of other victims. 
S 
Recruiters were taught by Defendants Epstein-and, Maxwell andM 
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 
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 7 of 31 
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
girlsyoung females were actually required to perform intimate sexual acts at the 
Defendants' direction and the Defendants did not help efnor intend to help advance 
the victims' careers. Victims 
id t 
brin 
F stem other 
females for sex and were told by Defendants Epstein, Maxwell, and 
that 
those young females who brought other females would further benefit from 
bringing other girls, 
17. -1-8,Defendant In 
was an integral part of the illegal venture and 
enterprise. =coordinated schedules between Defendant Epstein and the various 
young females used for sex; made travel arrangements for the girlsyoung females;
tended to thcirthe living needsafid-eemmunieateci-with-fliemeerder-te-mainta
-
their of those females; communicated and coordinated with Defendants 
Epstein, Maxwell and 
to assist in facilitating young females being 
available in locations where the other Defendants were traveling; and she 
carried messages to the young females from the other Defendants including 
false representations in order to maintain the young females' compliance with 
the rules of beluwimsexual compliance imposed upon-them-by this structured 
sex-trafficking group. 
was aware of 
6 
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page $ of 31 
the entewiseactivities of the venture and enterprise, including the fraudulent 
representations and other coercion that was being applied to secure the 
females' compliance with demands of sex. 
-IA The Defendants, led primarily by Defendants Epstein and Maxwell, 
fulfilled Epstein!) compulsive need for sex with young females by preying on their 
personal, psychological, financial, and related vulnerabilities. The Defendants' 
tactics included promising the victims money, shelter, transportation, gifts., 
employment, admission into educational institutions, educational tuition, 
protection,  and other things of value in exchange for sex. Defendants also took 
possession of the victims' passports to coerce compliance with their demands. 
Defendants also trafficked young females to Epstein's friends and 
acquaintances in order to secure financial and other benefits as well as social, 
educational, and business connections, 
19. 2.0:Defendants' sex trafficking venture and enterprise operated in a hierarchal 
structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top-anil 
underlings-belew,Defendants Epstein and Maxwell operated the sex trafficking 
scheme dating back to at least the mid-nineties, and over the years perfected 
their roles and the roles of oth 
volume of young females recruited for sex and in insulating the enterprise from 
criminalLiniesligationorprosetation.Defendantas
ith 
Defendant Epstein and Maxwell 
7 
since at least 2002 and continues to work for Defendant Epstein today. 
Defendant 
legatusarkingwiththelasteinrrasextraffickintyenture 
and enterprise as early as 2001 and her role in their venture and enterprise was 
EFTA00296285

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 9 of 31 
well-defined and primarily consisted of conspiring in the commission an 
cover-up of sex crimes. 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. 
20. 2-hDefendants 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, threats, intimidation, fear,  the threat of coercion, and a combination of 
these and similar tactics. Following the Defendants' recruitment and procurement of 
the young females to join Epstein in New York and the U.S. Virgin Islands, the 
Defendants used fraudulent 
6 promises, coercion, and threats of coercion in order to entice yettegand coerce 
the females into sex and, once sexual activities ensued, to cause them to remain in 
the enterprise. The Defendants also transported females in 
A 
interstate and foreign commerce and in ways that affected interstate and foreign 
commerce. The sex acts were commercial in nature, because the Defendants 
promised to provide financial and other compensation to the females in 
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 10 of 31 
exchange for providing sex acts to Epstein. 
21Defendants specifically targeted underprivileged, emotionally vulnerable 
and/or economically disadvantaged young females to join the Defendants' 
entecpciseprovide sex for Epstein. 
23.Additionally, Defendants always made clear to every you 
that they were wealthy, well-connected and could either help or hurt the 
females depending on their degree of cooperation. In fact, Defendants Epstein 
and Maxwell have been known to threaten young females with physical harm, 
It 
is unknown exactly how long Defendant 
Epstein and 
Maxwell's 
afecenwatienetithe Defendants' criminal and illegal venture and 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 venture and  enterprise and 
eeftspireey-up to the present time in some form or another and with additional 
co-conspirators and narticinant,  . 
24. 2-5,In 2005, Defendant Epstein and numerous co-conspirators within the 
venture and  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 school children. Each 
child identified in that particular investigation was lured into Defendant 
Epstein's Palm 
2 
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 10 of 31 
Beach mansion with a promise that she would receive money for providing him with 
a body massage, although once there, each el
young female was made to engage 
in a sex actsexual acts in order to receive the promised compensation. 
Several were also made to engage in sex with another of Defendant Epstein's 
female sexual-tfaveling-eempathenstraveling sex companions who Epstein 
referred to as his lesbian sex slave and bragged about purchasin her from 
her family when she herself was underage. 
15, 2.-.67In 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. *Section  1591, one of the statutory bases for this complaint. 
26. 2-7-.The United States Attorneys 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, including Defendants 
and 
named by the Federal Government as co- conspirators, 
for identified federal sex crimes against more than 30 minors. 
27. 28.From late 2006 through September 2007, Epstein's team of lawyers 
negotiated with the federal government in an effort to avoid the-filing-ef-thea fifty-
three-page dra€tFederal felony indictment effrom being filed against Epstein. 
During these 
14 
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 11 of 31 
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. 
28. 24Remarkably, however—as this case will highlight—Defendant Epstein 
and his co-Defendants, including the other defendants named herein, did 
8 not abandon their sex trafficking yenture and  enterprise even while they were 
under state and federal investigation for crimes committed in violation of 18 
U.S.C. *section 1591, among other laws, and even as Defendants and their 
attorneys were busy arguing Epstein!) innocence and publicly defaming his 
victims as liars. Rather, Defendants merely changed their stylciocation. Instead of 
targeting local Palm Beach Florida high-school girls, the Defendants transported 
young females from other places in the 
U.S. (including the Southern District of New York)  and abroad and brought them 
to Defendant Epsteinl's mansion in New York City and his private island in the 
Virgin Islands. 
29. 40,In June of 2008, Epstein pleaded guilty to Florida state felony sex offenses 
for procuring a minor for prostitution and soliciting prostitution by minors and 
reaistered as a Sex Offender for Life. 
30. 3-1-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. 
11 
Defendants 
and 
adapted to the system and also carried it out for 
years in exchange for significant pay, benefits, and protection from 
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 12 of 31 
prosecution. The system included requiring subordinates to sign confidentiality 
agreements evering-eivil-andbarring disclosure of criminal activity; maintaining 
records of underage females who were abused by Epstein;  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 
4 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. 
IL 32In 2005, Defendant Epstein and other co-conspirators, aware that law 
enforcement officials were preparing imminently to execute a search warrant effor 
his home, removed computer systems that logged information about Epstein and his 
co-conspirators' illegal and criminal conduct; the identities of witnesses; nude 
12 
photographs of young females; scheduling books; message pads; tangible items such 
as vibrators and toys; and other incriminating matter. 
32. The sex recruiting and trafficking venture and enterprise designed to 
procure young females for sexual purposes and to conceal those activities was 
developed and fine-tuned over time, and each of the named Defendants had a 
well-defined role and improved in his/her role over time, with practice and 
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 13 of 31 
experience. By the time Plaintiff was recruited into victimization, each 
Defendant had years of experience perfecting methods of coercion, 
understanding Epstein's requirements, and becoming more loyal to the 
continuance and survival of the venture and enterprise. All of the 
knew about the activities of the venture and enterprise and worked in concert 
for the goals of the venture and knowingly benefitted, financially and by 
receiving things of value, from their 
I articii ation in the venture and 
enterprise. 
E. A typical way the Defendants procured young females for sex with 
Defendant Epstein was to make false promises of a modeling opportunity, offer 
a better life, offer payment for a formal education, or offer other money or 
consideration. 
34, ff eenfirnerkeingjlegim_g
lin  in approximately October 2006 and continuing 
through April 2007, Defendants recruited Plaintiff into their sexual enterprise by 
fraudulently 
U 
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
 W113 working as One of the enterprise's snafu 
recruiters-efaatilurkinglascruit 
young females_for 
Epstein for sex when she approached and recruited Plaintiff. 
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 14 of 31 
44 
4-5-,Defendana 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. 
37. 36.Defendant 
reported to her superiors, Defendants M, 
and Maxwell, and was paid for her recruitment of young females, including-the 
feeruitment-ef 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."31 in New 
York City; or into a similar institute of higher learning offering a curriculum of 
fashion industry training. Between October 2006 and May 2007,  Defendants 
Maxwell, 
and IM each also  confirmed and reiterated this promise to 
Plaintiff many times t each telling Plaintiff that Epstein would use his wealth and 
connections to advance Plaintiff's education. More specifically, each of the 
Defendants last verified this information that Epstein was using his 
connections to ensure Plaintiff was admitted 
14 
into F.I.T. in exchange for Plaintiff's continued sexual cooperation with 
Epstein in March or April of 2007. 
39. 38.Defendant Maxwell told Plaintiff she would need to provide Defendant 
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 15 of 31 
Epstein with body massages in order to reap the benefits of his and' 
connections. 
40. All Defendants, including Maxwell, Epstein, 
and M, 
knew that 
Plaintiff was actually being recruited for sexual purposes, and each knowingly 
and deliberately made false representations to ensure that Plaintiff would 
cooperate in fulfilling Epstein's sexual desires. These false and fraudulent 
representations included Defendants' telling Plaintiff that Epstein would use 
his connections to have her admitted into F.I.T. or a similar institute, college, 
universi y or school of higher learning and provide her with employment 
opportunities. Plaintiff reasonably relied on these representations and had a 
credible basis for such reliance, including the credible representations of 
Epstein and the other Defendants that they possessed extensive political, 
business, financial, social, and educational influence and connections. Epstein 
and the other Defendants represented to Plaintiff in manners that were 
persuasive, credible, and reasonable to Plaintiff, as they would have been to 
any other person similarly situated, that they had the political, business, 
financial, social, educational, and other influence and 
15 
connections sufficient to arrange for and insure her admission into F.I.T. or a 
similar school of higher learning. 
41, Maxwell and Epstein also threatened Plaintiff that, while they had the ability 
EFTA00296293

Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 16 of 31 
to advance her education and career, they also had the ability to make sure that 
shePlaintiff would not  obtain ne-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. 
44 
42 3-9,Plaintiff reasonably believed that her compliance with Defendants' 
demands was crucial to her physical, psychological, financial, and reputational 
weiatingan_d_survival.
43. 4&Defendant Maxwell instructed Plaintiff how to massage Epstein using the 
techniques that heMaxwell knew that Epstein 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 her  and to avoid Defendants' threatened retaliation against her  if Plaintiff 
did not perform as demanded. 
j4, 4-I,Defendants—Maxwell and Epstein informed Plaintiff that other young 
females in Defendant-Epstein's company were there net-enly-te-previde-massages3
but-also to perform  sexual acts, for Epstein and his friendsnd 
!piped to secure the presence of the other young females for these purposes, 
11
427Plaintiff 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 
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 17 of 31 
perform a sexual act with-Defendant Epstein. The Defendants all participated in 
arranging for Plaintiff to be  transported Plaintiff in interstate and foreign 
commerce, and affecting interstate and foreign commerce, for these sexual purposes. 
The Defendants Epstein, Maxwell, andased 
possession and control of 
Plaintiff's passport to induce and coerce Plaintiff into nerforminiz sexual acts 
with Epstein and others. 
46. 43:During many sexual encounters, Defendant Epstein gave Plaintiff no 
option, opportunity, or choice not to participate in the prescribed sexual acts. 
4-2 
47. 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. Defendant Maxwell also 
gave instructions on how to perform certain sexual techniques on Epstein. 
Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with 
other females. 
4-SDefendants 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, with4hesufpese-and-OffeGt-eg 
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Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 1$ of 31 
compelling Plaintiff to perform and continue performing the demanded-commercial 
sexual activity demanded by Defendants. 
49_, 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 DcfcndantDefendants Epstein and 
Maxwell 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. Defendants further used possession and 
control of Plaintiff's passport, without lawful consent or authority, to restrict 
Plaintifralikertismiiherthilorethenforayidtienniaskins 
50. 4-7,Defendant Epstein's wealth, influence, power and connections were used 
by Defendants Maxwell, 
and 
 both as an inducement to provide sex 
(in exchange for promises of support to Plaintiff}, and as a means of threatening 
punishment (sheuldin the event Plaintiff fecuserefused to comply with Defendants' 
instructions to provide sex to Epstein and others). 
a 48,In addition to Plaintiff's being trafficked on Defendant-Epstein!:s private 
planeairplane, Defendants =, 
Maxwell and 
with the knowledge of and 
instruction by Defendant Epstein, arranged Plaintiffs living accommodations, 
private car travel, 
EFTA00296296