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nd through her undersigned counsel, for her EFTA00296278 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 beli
nts 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
rey Epstein was an adult male over 50 years old. Defendant Epstein is knownwidely recognized as a billionaire who u
06/05/17 Page 2 of 31 claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, and alleges upon pe
t 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
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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
t 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
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Case 1:17-cv-00616 Document 1 Filed 01126/17 Page 11 of 21 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 Plai
Plaintiff that she would introduce Plaintiff to Defendant Epstein, whom she described as a wealthy philanthropist
t 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
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Mutual Connections (9)
Entities connected to both Jeffrey Epstein and The Fashion Institute of Technology
Lesley Groff
PERSON84,246 w/ Jeffrey·2 w/ The
Ghislaine Maxwell
PERSON8,987 w/ Jeffrey·3 w/ The
United States
LOCATION4,786 w/ Jeffrey·2 w/ The
the Southern District
LOCATION2,140 w/ Jeffrey·2 w/ The
New York
LOCATION1,992 w/ Jeffrey·3 w/ The
U.S. Virgin Islands
LOCATION1,639 w/ Jeffrey·2 w/ The
David Boies
PERSON978 w/ Jeffrey·2 w/ The
Southern District of New York
ORGANIZATION686 w/ Jeffrey·2 w/ The
Boies Schiller & Flexner LLP
ORGANIZATION25 w/ Jeffrey·2 w/ The