F Document 1 Filed 11/20/19 Page 17 of 19 injury suffered as a result of conduct that would constitute sexual offenses as defined in Article 130 of the New York Penal Law, and such acts and/or omissions were committed against Mary when she was less than eighteen years of age. FIRST CAUSE OF ACTION (Battery) 108. P

would constitute sexual 10 EFTA00084153 Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 11 of 13 offenses as defined in Article 130 of the New York Penal Law, and such acts and/or omissions were committed against when she was less than eighteen years of age. 70. Epstein's conduct constitutes "childhood

onduct perpetrated against Plaintiff when she was under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55. COUNT TWO Sexual Battery 74. Plaintiff incorporates by reference all preceding parag

onduct perpetrated against Plaintiff when she was under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55. SECOND CAUSE OF ACTION (Sexual Battery) 38. Plaintiff incorporates by reference all