Epstein Secrets

45 Filed 06/05/17 Page 1 of 31 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO.: 1:17-CV-00616 JANE DOE 43, Plaintiff, vs. JEFFREY EPSTEIN GHISLAINE MAXWELL, AND Defendants. / FIRST AMENDED COMPLAINT Plaintiff JANE DOE 43, by and through her undersigned counsel, for her claims ag

5. FACTUAL ALLEGATIONS 11. At all times material to this cause of action, Defendant Jeffrey Epstein was an adult male over 50 years old. Defendant Epstein is widely recognized as a billionaire who uses his extraordinary wealth to commit illegal sexual crimes in violation of federal and state statutes

would not obtain formal education f she failed to provide the sexual favors desired by Defendant Epstein or abide by the instructions given her by Defendants Epstein, M, and Maxwell. 42. Plaintiff reasonably believed that her compliance with Defendants' demands was crucial to her physical, psychological, financial

O.: 1:17-CV-00616 JANE DOE 43, Plaintiff, vs. JEFFREY EPSTEIN GHISLAINE MAXWELL, AND Defendants. /

smission of Notices of Electronic Filing generated by CM/ECF. STEPTOE & JOHNSON, LLP Michael C. Miller Justin Y.K. Chu Attorneys for Defendants Jeffrey Epstein & By: /s/ Bradley J. Edwards 31 EFTA00615969

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

91(b)(2) 2 EFTA00304714 Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 3 of 21 11. At all times material to this cause of action, Defendants Jeffrey Epstein, Ghislaine Maxwell, and owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire to commit intentional or tor

r. 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 emplo

rey Epstein was an adult male over 50 years old. Defendant Epstein is known as a billionaire who uses his extraordi

TRICT OF NEW YORK JANE DOE 43, Plaintiff, VS. JEFFREY EPSTEIN, GHISLAINE MAXWELL, Defendants. COMPLA

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

91(b)(2) 2 EFTA00285424 Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 3 of 21 11. At all times material to this cause of action, Defendants Jeffrey Epstein, Ghislaine Maxwell, Lesley Groff, and owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire to commit inte

r. 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 emplo

rey Epstein was an adult male over 50 years old. Defendant Epstein is known as a billionaire who uses his extraordi

SOUTHERN DISTRICT OF NEW YORK Plaintiff, VS. JEFFREY EPSTEIN GHISLAINE MA3CWEL LESLEY GROFF, AND D

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

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO.: P.C. Plaintiff, vs. JEFFREY EPSTEIN, GHISLAINE MAXWELL, LPSLEY R FF AND Defendants. COMPLAINT Plaintiff P.C., by and through her undersigned counsel, sues the Defendants Jeffrey

er. 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 emplo

rey Epstein was an adult male over 50 years old. Defendant Epstein is known as a billionaire who uses his extraordi

CT OF NEW YORK CASE NO.: P.C. Plaintiff, vs. JEFFREY EPSTEIN, GHISLAINE MAXWELL, LPSLEY R FF AND D

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

Subject: RE: Jane Does 1 U.S. (re Jeffrey Epstein) - Litigation Hold - Additional Date: Thu, 04 Nov 2010 14:20:37 +0000 Importance: Normal Thank you very much Enjoy your cruise! u : : lane (re

el fon? • Jeffrey Epstein, Defendant in state criminal action and party to USAO-SDFLA Non-Prosecution Agreement • Lilly Ann Sanchez, Counsel For Epstein • Jack Goldberger, Counsel for Epstein Palm Beach Florida Police Department Subject: Jane Does I U.S. (re Jeffrey Epstein) - Litigation Hold Imp

Subject: RE: Jane Does 1 U.S. (re Jeffrey Epstein) - Litigation Hold - Additional Date: Th

on and party to USAO-SDFLA Non-Prosecution Agreement • Lilly Ann Sanchez, Counsel For Epstein • Jack Goldberger, Counsel for Epstein Palm Beach Florida Police Department Subject: Jane Does I U.S. (re Jeffrey Epstein) - Litigation Hold Importance: High « File: Re.Jeffrey Epstein.Jane Does U.S. - 11.2.2010 JAW Lit Ho

nally 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

enterprise. 23. It is unknown exactly how long Defendant Epstein and Maxwell's aforementioned criminal and illega

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