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and is domiciled in the Southern District of New York. JURISDICTION AND VENUE 22. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at the time of his death. Jeffrey Epstein maintained a residence in the Southern District of New York. As the legal representatives of the Estate o
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
and is domiciled in the Southern District of New York. JURISDICTION AND VENUE 22. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at the time of his death. Jeffrey Epstein maintained a residence in the Southern District of New York. As the legal representatives of the Estate o
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
and is domiciled in the Southern District of New York. JURISDICTION AND VENUE 22. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at the time of his death. Jeffrey Epstein maintained a residence in the Southern District of New York. As the legal representatives of the Estate o
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
d other investigations into Epstein's sex trafficking, because it knew it would be exposed as assisting in Epstein's scheme. 159. During a trip to the U.S. Virgin Islands in January 2007, Jane Doe 1 was repeatedly raped and coerced into commercial sex. She was paid $10,000 in hush money, which Epstein's agents appare
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 U.S. Virgin Islands and New York Penal

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Richard Kahn
PERSON
New York
LOCATION
Les Wexner
PERSON
Palm Beach
LOCATION
Kenneth Marra
PERSON
Martha Stewart
PERSON
Jes Staley
PERSON
David Boies
PERSON
Southern District of New York
ORGANIZATION
Jay Lefkowitz
PERSON
United Kingdom
LOCATIONSuperior Court
ORGANIZATION
New Mexico
LOCATIONSigrid McCawley
PERSONN.Y. Post
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION