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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
iller & Flexner LLP E: Pro Hoc Vice to be filed 20 EFTA00285442 Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 21 of 21 Bradley J. Edwards Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. T: E: Pro Hoc Vice to be filed J. Stanley Pottinger J. Stanley Pottinger PLLC 21 EFTA002854
stein and named the additional individuals Lesley Groff and as enablers .(17°] Katlyn Doe, et at v. Epst
149-1 In October 2019, Araoz amended her complaint to include over 20 co orate entities associated with Epstein and named the additional individuals Lesley Groff and as enablers .(17°] Katlyn Doe, et at v. Epstein's estate (2019) https://en.wikipedia.orgAviki/Jeffray_Epstein 13/60 EFTA00263221 itc i .sa
New York, alleging that she and her 15-year-old sister, Annie, had been sexually assaulted by Epstein and Maxwell in separate locations in 1996. Fanner met Epstein and Maxwell at her graduate art gallery reception at the New York Academy of Art in 1995. The following year, in the summer of 1996, th
D§91 In October 2019, Araoz amended her complaint to include over 20 corporate entities associated with Epstein and named the additional individuals Lesley Groff and Cimberly Espinosa as enablers [1701. Katlyn Doe, et at v. Epstein's estate (2019) https://en.wicipedia.orgMiki/Jeffrey_Epstein 13/60 EFTA002
stein and named the additional individuals Lesley Groff and Cimberly Espinosa as enablers [1701. Katlyn
n New York, alleging that she and her 15-year-old sister, Annie, had been sexually assaulted by Epstein and Maxwell in separate locations in 1996. Fanner met Epstein and Maxwell at her graduate art gallery reception at the New York Academy of Art in 1995. The following year, in the summer of 1996, th
69.1 In October 2019, Araoz amended her complaint to include over 20 corporate entities associated with Epstein and named the additional individuals Lesley Groff and Cimberly Espinosa as enablers021 staHun neo pt al it Fngtaires &slate (20191 EFTA00264769 B 7.5k3 -') 5 es-5 EM - MEDICAL B 0-7.51 ES.S im
stein and named the additional individuals Lesley Groff and Cimberly Espinosa as enablers021 staHun neo
l court in New York, alleging that she and her 35-year-old sister, Annie, had been assaulted Epstein and Maxwell in separate locations in 1996. Fanner met Epstein and Maxwell at her graduate art gallery reception at the New York Academy of Art in 1995. The following year, in the summer of 1996, th
-691 In October 2019, Araoz amended her complaint to include over 20 corporate entities associated with Epstein and named the additional individuals Lesley Groff and Cimberly Espinosa as enablers. -1 !ragtag newa at of if FnchainSt acetate (20191 EFTA00264824 5PCc=iAL\STm esc 'CAC- CENTRE 1>a)e Co p me-N
stein and named the additional individuals Lesley Groff and Cimberly Espinosa as enablers. -1 !ragtag n
ear, in the summer of 1996, they hired her to work on an art project in. Leslie Weimer's Ohio mansion, where she was then seawall assaulted (}6 41 Fanner reported the incident to the New 'lark City Police Department d. I. an the FB 16 Farmer's affidavit also stated that during the same summer, Epstei
.1 In Ocibber 2019, Amos amended her eramplaint to include over 20 corporate entities associated with Epstein and -named the additional individuals Lesley Groff and Cimberly Espinosa as enablers-rani EFTA00265117 e.rsTem (ACV 5/27J22, 1:31 PM Jefhey Epstein - VVildpedla Epstein attended local public s
tein and -named the additional individuals Lesley Groff and Cimberly Espinosa as enablers-rani EFTA0026
fallowing year, in the summer of 1996 they hired her to work on an art lielljeCt in Leslie Weems Ohio mansion, where she was then seraalkaspaulted Fanner reportedthe incident to the New York City Police Department andtheFEL1165-1 Farmer's affidavit also stated that &jag the same summer, Epstein flew h
of E stein, including but not limited to Lesley Groff, or Further, upon execution o is agreement and
United States also agrees that it will not institute any criminal charges First anatential co-conspirators of E stein, including but not limited to Lesley Groff, or Further, upon execution o is agreement and a plea agreement with e tate Attorney's Office, the federal Grand Jury investigation will be susp
ilroad Avenue West Palm Beach. FL 33401 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards 11 A31 EFTA00798197 Bradley J. Edwards Fanner, Jaffee, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Avenue, Suite 2 Fort Lauderdale FL 33401 Co-Counsel for Defendant/Counter-Plain
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
. 2003) 259 United States v. Ewell, 383 U.S. 116 (1966) 80 EFTA00077619 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) United States v. Fanner, 137 F.3d 1265 (10th Cir. 1998) United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) United States v. Fennell, 166, 169 179, 180 8, 20, 27 4
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
. 2003) 259 United States v. Ewell, 383 U.S. 116 (1966) 80 EFTA00039434 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) United States v. Fanner, 137 F.3d 1265 (10th Cir. 1998) United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) United States v. Fennell, 166, 169 179, 180 8, 20, 27 4
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
nited States v. Ewell, 383 U.S. 116 (1966) 54 xii EFTA00095079 United States v. Falso, 544 F.3d 110 (2d Cir. 2008) 113, 114 United States v. Fanner, 137 F.3d 1265 (10th Cir. 1998) 120, 121 United States v. Feldman, 939 F.3d 182 (2d Cir. 2019) 6, 18, 22 United States v. Fennell, 496 F. Supp
Entities connected to both Lesley Groff and Fanner

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Marc Rich
PERSON
John F. Kennedy
PERSONLeon Black
PERSON
Woody Allen
PERSON
Prince Andrew
PERSON
George Mitchell
PERSON
Prince Charles
PERSON
Harry Reid
PERSON
Joe Biden
PERSONRichard Barnett
PERSON
Alan Dershowitz
PERSON
Jes Staley
PERSON
Eric Trump
PERSON
Condoleezza Rice
PERSON
Lawrence Krauss
PERSON
George W. Bush
PERSON
FedEx
ORGANIZATION
Reid Weingarten
PERSON