Epstein Secrets

ment 1 Filed 01/26/17 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, VS. JEFFREY EPSTEIN GHISLAINE MA3CWEL LESLEY GROFF, AND Defendants. COMPLAINT JURY TRIAL DEMANDED CASE NO.: Plaintifl by and through her undersigned counsel, for her claims against Defendants J

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, as follows:

m intimate sexual acts at the Defendants' direction and the Defendants did not help or intend to help advance the victims' careers. 18. Defendant Groff coordinated schedules between Defendant Epstein and the various young females used for sex; made travel arrangements for the girls; tended to their

es triable as of right by a jury. Dated: January 26, 2017 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ David Boies David Boies Boies Schiller & Flexner LLP Alex Boies Boies Schiller & Flexner LLP Sigrid McCawley Meredith Schultz Boies Schiller & Flexner LLP E: Pro Hoc Vice to be filed 20 EFTA002

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. section 1331. 2. P

C. section 1391(b)b(2) 2 EFTA00596326 11. At all times material to this cause of action, Defendants Jeffrey Epstein, Ghislaine Maxwell, .,esley Groff, and owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire to commit intentional or tortious illegal acts

right by a jury. Dated: January 2016. Respectfully Submitted, 19 EFTA00596343 BOIES, SCHILLER & FLEXNER LLP By: /s/ David Boies David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 20 EFTA00596344

f Epstein, including but not limited to Lesley Groff, or NPA at 5; Def. Mot. 1 at 20-21. Aside from t

d States also agrees that it will not institute any criminal charges against any otential co-cons irators of Epstein, including but not limited to Lesley Groff, or NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted above, is insufficient, the defendant does not poin

on to the public, as part of an ongoing campaign to vilify Ms. Maxwell." (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government o

will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted above, is insufficient, the defen

ot limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 2

on to the public, as part of an ongoing campaign to vilify Ms. Maxwell." (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Gover

will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted above, is insufficient, the defen

ot limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 2

on to the public, as part of an ongoing campaign to vilify Ms. Maxwell." (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Gover