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e 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 al
ntroduced Plaintiff to Defendant Epstein, who confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into in New York City, or into a similar institute of higher learning offering a curriculum of fashion industry training. Defendants Maxwell, and each confirmed this p
racy 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
was a residing in New York, New York and, on information and belief, was a citizen of New York 9. At all material times, was residing in New York, New York and, on information and belief, was a citizen of New York. 10. Because a substantial part of the events and omissions giving rise to this cause of
d 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 t
scheme 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
omises they repeatedly made in order to coerce her into commercial sex acts. 63. Defendants' sexual demands on Plaintiff continued while she was in New York City, in the Southern District of New York, or in other locations in close proximity to the Defendants. 64. In May, 2007, Plaintiff left the United Stat
and participants. 24. 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 9 EFTA00615947 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Pag
e 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 al
racy 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
Entities connected to both New York and Florida Police Department

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
U.S. Virgin Islands
LOCATION
Bradley Edwards
PERSON
Lesley Groff
PERSONJane Doe
PERSON
Paul Cassell
PERSON
Southern District of New York
ORGANIZATION
David Boies
PERSONSigrid McCawley
PERSONFISTOS & LEHRMAN
ORGANIZATIONJaffe
PERSON
Weissing
PERSON
Meredith Schultz
PERSONFanner
PERSON
Boies Schiller & Flexner LLP
ORGANIZATIONJ. Stanley Pottinger
PERSONAlex Boies
PERSON