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Document 1 Filed 01/26/17 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE 43, Plaintiff, VS. JEFFREY EPSTEIN, GHISLAINE MAXWELL, Defendants. COMPLAINT JURY TRIAL DEMANDED CASE NO.: Plaintiff Jane Doe 43, by and through her undersigned counsel, for her claims aga
Filed 01/26/17 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE 43, Plaintiff, VS. JEFFREY EPSTEIN, GHISLAINE MAXWELL, Defendants. COMPLAINT JURY TRIAL DEMANDED CASE NO.: Plaintiff Jane Doe 43, by and through her undersigned counsel, for her claims against Defe
T JURY TRIAL DEMANDED CASE NO.: Plaintiff Jane Doe 43, by and through her undersigned counsel, for her claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, and , alleges upon personal knowledge with respect to her own acts and status and upon information and belief as to all other matters, as follow
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
s. COMPLAINT JURY TRIAL DEMANDED CASE NO.: Plaintifl by and through her undersigned counsel, for her claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, Lesley Grog and alleges upon personal knowledge with respect to her own acts and status and upon information and belief as to all other matters,
erial to this cause of action Defendant Jeffrey Epstein was an adult male born in 1953. 6. At all times material to this cause of action Defendant Ghislaine Maxwell was residing in in New York, New York and was a citizen of Great Britain and France. in 7. At all times material to this cause of actior
is cause of action Defendant Jeffrey Epstein was an adult male born in 1953. 6. At all times material to this cause of action Defendant Ghislaine Maxwell was residing in in New York, New York and was a citizen of Great Britain and France. in 7. At all times material to this cause of actior was res
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 Epstein, Ghi
INE MAXWELL, LPSLEY R FF AND Defendants. COMPLAINT Plaintiff P.C., by and through her undersigned counsel, sues the Defendants Jeffrey Epstein, Ghislaine Maxwell, Lesley Groff and a and alleges as follows: 1. This cause of action arises under federal statute and jurisdiction is proper under 28 U.S.C. sect
irtually every day and assisted in the development and execution of a sex trafficking scheme designed to fulfill his sexual desires. 15. Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking enterprise. She herself recruited young females; oversaw and train
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
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 against Defendants J
ts. / FIRST AMENDED COMPLAINT Plaintiff JANE DOE 43, by and through her undersigned counsel, for her 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 belief as to all o
6 JANE DOE 43, Plaintiff, vs. JEFFREY EPSTEIN GHISLAINE MAXWELL, AND Defendants. / FIRST AMENDED CO
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
rable 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-1990's thro
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 Ghislaine Maxwell and Florida Police Department

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
New York
LOCATIONJane Doe
PERSON
David Boies
PERSON
Lesley Groff
PERSONSigrid McCawley
PERSON
U.S. Virgin Islands
LOCATION
Paul Cassell
PERSON
Southern District of New York
ORGANIZATIONFISTOS & LEHRMAN
ORGANIZATION
Weissing
PERSONJaffe
PERSON
Meredith Schultz
PERSONJ. Stanley Pottinger
PERSONFanner
PERSON
Boies Schiller & Flexner LLP
ORGANIZATIONAlex Boies
PERSON