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s complaint, Jeffrey Epstein was an extraordinarily wealthy man with multiple residences in the United States, including a New York City mansion, a New Mexico Ranch, an apartment in Paris, France, a Palm Beach mansion, and an island in the U.S. Virgin Islands. 105. Beginning in about 1998 (and perhaps earlier)
e Bank joined while it was on-going. Deutsche Bank ratified the earlier-committed acts of the conspiracy. This action is also timely under RICO and New York's Adult Survivors Act. 4 EFTA00161961 Case 1:22-cv-10018-JSR Document 42 Filed 01/13/23 Page 5 of 163 II. PARTIES 7. Jane Doe 1 is a United Stat
n addition to coercing commercial sex acts from his victims, Epstein also committed intentional torts and sexual offenses against them as defined in New York Penal Law § 130, as described in greater detail below. 117. From around 1998 through about July 2019, Epstein's sex-trafficking venture recruited,
ung girl for the purpose of degrading her, abusing her, or gratifying their sexual desires. 86. Epstein and Maxwell brought Plaintiff to Epstein's New Mexico Ranch with the intent to confine her in that location so that they could sexually abuse her. Plaintiff was conscious of her confinement and did not conse
d with friends and hired staff to maintain and keep secret this network of sexual abuse for years, which sprawled throughout Epstein's residences in New York, Florida, New Mexico, the United States Virgin Islands, and Paris. Epstein's preference was to have three different girls a day for his sexual pleas
ung girl for the purpose of degrading her, abusing her, or gratifying their sexual desires. 86. Epstein and Maxwell brought Plaintiff to Epstein's New Mexico Ranch with the intent to confine her in that location so that they could sexually abuse her. Plaintiff was conscious of her confinement and did not conse
d with friends and hired staff to maintain and keep secret this network of sexual abuse for years, which sprawled throughout Epstein's residences in New York, Florida, New Mexico, the United States Virgin Islands, and Paris. Epstein's preference was to have three different girls a day for his sexual pleas
ung girl for the purpose of degrading her, abusing her, or gratifying their sexual desires. 86. Epstein and Maxwell brought Plaintiff to Epstein's New Mexico Ranch with the intent to confine her in that location so that they could sexually abuse her. Plaintiff was conscious of her confinement and did not conse
d with friends and hired staff to maintain and keep secret this network of sexual abuse for years, which sprawled throughout Epstein's residences in New York, Florida, New Mexico, the United States Virgin Islands, and Paris. Epstein's preference was to have three different girls a day for his sexual pleas
. These records prove incontrovertibly that I could not have been, and was not, where Roberts’ falsely claimed to have met me — a Caribbean Island, a New Mexico Ranch, a private jet, a Palm Beach mansion — during the relevant time period. I also called for an independent investigation by the former Director of th
eeds seventy-five thousand ($75,000), exclusive of interest and costs. 25. This Court has personal jurisdiction over Defendant. Defendant resides in New York City; Defendant conducts regular business in New York City; and this action arose, HOUSE_OVERSIGHT_017941 Case 1:19-cv-03377 Document 1 Filed 04/16/19 P
Entities connected to both New Mexico Ranch and New York

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Virginia Giuffre
PERSON
Bill Clinton
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSONDarren Indyke
PERSONFBI
ORGANIZATION
New York City
LOCATION
U.S. Virgin Islands
LOCATION
Bradley Edwards
PERSON
Palm Beach
LOCATION
Lesley Groff
PERSON