3
Shared Docs
3
Same-Page
7 / 3
Mentions
dersigned 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 belief as to all other
l, financial, and reputational weiatingan_d_survival. 43. 4&Defendant Maxwell instructed Plaintiff how to massage Epstein using the techniques that heMaxwell knew that Epstein preferred. During Plaintiff's first massage, Defendant Epstein converted it into a sexual act and made it known to Plaintiff that
of 31 claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, and alleges upon personal knowledge wi
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
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
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
males like Plaintiff achieve their personal and professional goals and aspirations. 36. Defendant reported to her superiors, Defendants Groff and Maxwell, and was paid for her recruitment of young females, including the recruitment of Plaintiff. 37. Defendant introduced Plaintiff to Defendant Epste
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
Entities connected to both Ghislaine Maxwell and The Fashion Institute of Technology

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATION
New York
LOCATION
David Boies
PERSON
Lesley Groff
PERSON
U.S. Virgin Islands
LOCATION
Southern District of New York
ORGANIZATION
Boies Schiller & Flexner LLP
ORGANIZATION