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the only hat Epstein and Maxwell sexually abused. During that summer, was lured into an "artist in residence" position by Epstein at billionaire Les Wexner's Ohio estate on which Epstein owned a guest house. There, Epstein and Maxwell both sexually assaulted Wexner's security personnel did not allow 14
sition by Epstein at billionaire Les Wexner's Ohio estate on which Epstein owned a guest house. There, Epstein and Maxwell both sexually assaulted Wexner's security personnel did not allow 14 EFTA00105988 Case 1:19-cv-10475-LGS Document 1 Filed 11/12/19 Page 15 of 19 M o exit his estate, even afte
touched Plaintiff in an offensive and sexual manner without her consent. 81. Epstein and Maxwell's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to forcible touching as defined in Article 130.52, inasmuch as Epstein and Maxwell intentionally and for
ly member that Epstein and Maxwell sexually abused. During that summer, was lured into an "artist in residence" position by Epstein at billionaire Les Wexner's Ohio estate on which Epstein owned a guest house. There, Epstein and Maxwell both sexually assaulted . Wexner's security personnel did not allow 1
tion by Epstein at billionaire Les Wexner's Ohio estate on which Epstein owned a guest house. There, Epstein and Maxwell both sexually assaulted . Wexner's security personnel did not allow 14 EFTA00078324 Case 1:19-cv-10475-LGS-DCF Document 1 Filed 11/12/19 Page 15 of 19 to exit his estate, even a
touched Plaintiff in an offensive and sexual manner without her consent. 81. Epstein and Maxwell's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to forcible touching as defined in Article 130.52, inasmuch as Epstein and Maxwell intentionally and for
ter." 127. Before Staley, Epstein relied heavily on the massive wealth bestowed upon him primarily by one individual, Leslie (Les) Herbert Wexner ("Wexner"), to give him the appearance of grand importance while relying on his then-madame, Maxwell, to find and groom young women to be abused. 128. It h
Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 36 of 130 Epstein's international sex trafficking operation, most notably Ghislaine Maxwell, Les Wexner, Jean Luc Brunel, and Jes Staley, acting through and on behalf of JP Morgan. 139. In later years, Deutsche Bank swapped in for JP Morgan and provid
f 130 75. In addition to coercing commercial sex acts from his victims, Epstein also committed coercive sexual offenses against them as defined in New York Penal Law § 130, as described in greater detail below. 76. Throughout around 1998 through about July 2019, the Epstein's sex- trafficking venture recrui
Entities connected to both Les Wexner and New York Penal

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
U.S. Virgin Islands
LOCATIONDarren Indyke
PERSON
New York
LOCATION
United States
LOCATION
Palm Beach
LOCATION
Kenneth Marra
PERSON
Richard Kahn
PERSON
Martha Stewart
PERSON
Jes Staley
PERSON
David Boies
PERSONSigrid McCawley
PERSON
United Kingdom
LOCATION
Metropolitan Correctional Center
ORGANIZATION
New York Post
ORGANIZATION
Jay Lefkowitz
PERSON
Alaska
LOCATION
New Mexico
LOCATION
Southern District of New York
ORGANIZATION