EFTA00296277.txt

"Defendant Epstein's Palm Beach mansion"

"Defendant Epsteinl's mansion in New York City"

"his private island in the Virgin Islands"

"a Non-Prosecution Agreement was signed between Jeffrey Epstein and the United States Attorney's Office"

"Defendant Epstein converted it into a sexual act and made it known to Plaintiff that further sex would be required"

"Defendants Maxwell, [REDACTED] and IM each also confirmed and reiterated this promise to Plaintiff"

"Defendant Epstein's private island"

"his townhouse in New York"

"Plaintiff's being trafficked on Defendant-Epstein!:s private planeairplane"

"Defendant Maxwell instructed Plaintiff how to massage Epstein using the techniques that heMaxwell knew that Epstein preferred."

"demands that she service Epstein sexually"

"These Defendants worked in concert with one another to recruit, procure, entice, and otherwise cause many other females to engage in commercial sex ac"

"were on Epstein's island"

"including when she travelled to E stein's island in the U.S. Virgin Islands"

"Defendants sent Plaintiff from the-Uctited4takasNew York City... to South Africa"

"Defendants Epstein and Maxwell continued to provide Plaintiff with things of value in exchange for Plaintiff-:s continued compliance with Epsteie 4-6 "

"Defendants individually and together... knowingly recruited, enticed, harbored, transported, provided, maintained, patronized, solicited, threatened, "

"Defendants individually and together... knowingly recruited, enticed, harbored, transported, provided, maintained, patronized, solicited, threatened, "

"Defendant Epstein's New York mansion, located at 9 East 71st Street"

"his private island located in the United States Virgin Islands"

"Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking venture and enterprise. She herself recruited young,"

"he owned and-ewns(directly or indirectly) a Boeing aircraft (of make and model B-727-31H with tail number N908JE)"

"and a Gulfstream aircraft of make and model G-1159B with tail number N909JE"

"He also owned... a 70-acre private island formerly known as Little St. James"

"Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking venture and enterprise"

"Case 1:17-cv-00616-JGK... Defendants Jeffrey Epstein, Ghislaine Maxwell"

"Case 1:17-cv-00616-JGK... Defendants Jeffrey Epstein, Ghislaine Maxwell"

"Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled Epstein!) compulsive need for sex with young females"

"Defendant Epstein had engaged in sexual activities with dozens of young teenage school children"

"Defendants Epstein and Maxwell, with help from assistants, associates and underlings, recruited and procured hundreds of girls"

"Defendant [REDACTED] working as One of the enterprise's snafu recruiters... when she approached and recruited Plaintiff."

"Defendants Epstein and Maxwell possessed and control of Plaintiff's passport to induce and coerce Plaintiff"

"In 2005, Defendant Epstein and other co-conspirators... removed computer systems that logged information about Epstein and his co-conspirators' illega"

"Defendants took possession of Plaintiffs passport when she was being trafficked by them"

"Plaintiff JANE DOE 43... claims against Defendants Jeffrey Epstein, Ghislaine Maxwell... this Complaint makes allegations of a sensitive sexual nature"

"reported directly up the line of authority to Defendants Maxwell and Epstein"

"Defendant [REDACTED] was an integral part of the illegal venture and enterprise... communicated and coordinated with Defendants Epstein, Maxwell"

"Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females. Defendant's cover- up included effo"

"Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females. Defendant's cover- up included effo"

"Certain property of Defendant Epstein's was essential to the commission of the federal crimes and torts described herein, including the use of multipl"

"Certain property of Defendant Epstein's was essential to the commission of the federal crimes and torts described herein, including... a Gulfstream ai"

"In May, 2007, Plaintiff left the United States and did not return. Between returtaSouth Africa"

"since at least 2002 and continues to work for Defendant Epstein today"

"Defendant [REDACTED] legatusarkingwiththelasteinrrasextraffickintyventure and enterprise as early as 2001"

"She herself recruited young, including underage, females... providing young females to Epstein for sexual purposes on a daily basis"

"Defendant [REDACTED] reported to her superiors, Defendants M, [REDACTED] and Maxwell, and was paid for her recruitment of young females"

"Defendants sent Plaintiff... to South Africa-in-pact to recruit, for a promised fee, one or more aspiring female models"

"they had contacts at F.LT. and at modeling agencies who could ensure her admission"

"STEPTOE & JOHNSON, LLP Michael C. Miller Justin Y.K. Chu Attorneys for Defendants"