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in this Complaint). Under Epstein's plan, underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Reach mansion. The recruiter would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or
in this Complaint). Under Epstein's plan, underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. The recruiter would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or
a man of tremendous wealth, powcr and influence. Ile maintains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Reach, FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach. 8. Upon information and belief, Epstein has a sexu
ed to put his hands down plaintiff's dress, and that there was an actual and intentional touching, sufficient to state a claim for battery); Hogan I Tavzel, 660 So.2d 350 (Fla. 5th DCA 1995) (tortfeasor may be liable for battery for infecting another with a sexually transmitted disease); see also Resta
Compl. 111-12; Jane Doe No. 7 Amd. Compl. 11-12). The pleading then alleges that, consistent with this scheme, the Plaintiff was lured to Epstein's Palm Beach mansion to give a massage for monetary compensation. (Jane Doe No. 2 Amd. Compl. 1 12; (Jane Doe No. 3 Amd. Compl. 1 12; Jane Doe No. 4 Amd. Compl.
ed to put his hands down plaintiff's dress, and that there was an actual and intentional touching, sufficient to state a claim for battery); Hogan'. Tavzel, 660 So.2d 350 (Fla. 5th DCA 1995) (tortfeasor may be liable for battery for infecting another with a sexually transmitted disease). Defendant doe
in this Complaint). Under Epstein's plan, underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. The recruiter would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or
ed to put his hands down plaintiff's dress, and that there was an actual and intentional touching, sufficient to state a claim for battery); Hogan'. Tavzel, 660 So.2d 350 (Fla. 5th DCA 1995) (tortfeasor may be liable for battery for infecting another with a sexually transmitted disease); see also Resta
Compl. 111-12; Jane Doe No. 7 Amd. Compl. 11-12). The pleading then alleges that, consistent with this scheme, the Plaintiff was lured to Epstcin's Palm Beach mansion to give a massage for monetary compensation. (Jane Doe No. 2 Amd. Compl. ¶ 12; (Jane Doe No. 3 Amd. Compl. ¶ 12; Jane Doe No. 4 Amd. Compl.
d to put his hands down plaintiff's dress, and that there was an actual and intentional touching, sufficient to state a claim for battery); Ilogani. Tavzel, 660 So.2d 350 (Fla. 5th DCA 1995) (tortfeasor may be liable for battery for infecting another with a sexually transmitted disease). Defendant doe
Entities connected to both Palm Beach and Tavzel

Jeffrey Epstein
PERSON
George W. Bush
PERSONLeon Black
PERSON
United States
LOCATIONJack Goldberger
PERSON
Alan Dershowitz
PERSONJane Doe
PERSON
Palm Beach County
LOCATIONFBI
ORGANIZATIONthe Southern District
LOCATION
Kenneth Marra
PERSON
Virginia Giuffre
PERSON
Alexander Acosta
PERSON
Scarlett Johansson
PERSON
Julie K. Brown
PERSON
West Palm
LOCATION
Bill Richardson
PERSON
A. Marie Villafana
PERSONSouthern District
LOCATION
Wilbur Ross
PERSON