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including in New York, New York and the United States Virgin Islands. He is currently a citizen of the United States and a resident of New York and the U.S. Virgin Islands. 5. At all times material to this cause of action Defendant Jeffrey Epstein was an adult male born in 1953. 6. At all times material to this cau
ture. 63. Additionally, Defendant Epstein's New York mansion, located at 9 East 71st street, New York, New York, and his private island located in the United States Virgin Islands, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. 64. As a direct and pro
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
including in New York, New York and the United States Virgin Islands. He is currently a citizen of the United States and a resident of New York and the U.S. Virgin Islands. 5. At all times material to this cause of action Defendant Jeffrey Epstein was an adult male born in 1953. 6. At all times material to this cau
ture. 63. Additionally, Defendant Epstein's New York mansion, located at 9 East 71st street, New York, New York, and his private island located in the United States Virgin Islands, were used as means and instruments of Defendants' tortious and criminal offenses and, as such, are subject to forfeiture. 64. As a direct and pro
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
ombination of these and similar tactics. Following the Defendants' recruitment and procurement of the young females to join Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent promises, coercion, and threats of coercion in order to entice and coerce the females into sex and, once sexual act
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
nd a combination of these and similar tactics. Following the Defendants' recruitment and procurement of the females to join Epstein in New York and the U.S. Virgin Islands, the Defendants used fraudulent 6 EFTA00596330 promises, coercion, and threats of coercion in order to entice young females into sex and, once s
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
Entities connected to both U.S. Virgin Islands and Florida Police Department

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
New York
LOCATIONthe Southern District
LOCATIONJane Doe
PERSON
Bradley Edwards
PERSON
Virginia Giuffre
PERSON
Lesley Groff
PERSON
Paul Cassell
PERSON
David Boies
PERSON
Southern District of New York
ORGANIZATIONSigrid McCawley
PERSONFISTOS & LEHRMAN
ORGANIZATIONJaffe
PERSON
Weissing
PERSON
Meredith Schultz
PERSON
Boies Schiller & Flexner LLP
ORGANIZATIONFanner
PERSONJ. Stanley Pottinger
PERSONAlex Boies
PERSON