EFTA00304713.txt

"Defendant Epstein converted it into a sexual act and made it known to Plaintiff that further sex would be required in order for her to obtain the assi"

"Commencing in approximately October 2006 and continuing through April 2007, Defendants recruited Plaintiff into their sexual enterprise"

"his private island in the Virgin Islands"

"Defendant Epstein's mansion in New York"

"Plaintiff's being trafficked on Defendant Epstein's private plane"

"through September 2007, at which time a Non-Prosecution Agreement was signed between Jeffrey Epstein and the United States Attorney's Office"

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

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

"In January 2007, Defendants sent Plaintiff from the United States to South Africa"

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

"He owned and owns numerous properties and homes, including... a 70-acre private island formerly known as Little St. James"

"He owned and owns numerous properties and homes, including... a mansion in Palm Beach County, Florida"

"He owned and owns numerous properties and homes, including a 51,000-square-foot mansion in Manhattan"

"He owned and owns numerous properties and homes, including... a $30 Million, 7,500-acre ranch in New Mexico"

"JEFFREY EPSTEIN... Defendants"

"GHISLAINE MAXWELL... Defendants"

"JANE DOE 43, Plaintiff"

"maintain Plaintiffs sexual compliance... provide sex to Defendant Epstein and others in the times, places and manners demanded by Defendants"

"The relationship between Plaintiff and Defendants Epstein and Maxwell was defined and characterized by Defendant Epstein's and Defendant Maxwell's fre"

"Defendants recruited Plaintiff into their sexual enterprise"

"and was paid for her recruitment of young females, including the recruitment of Plaintiff"

"requiring subordinates and victims to refrain from speaking with law enforcement officials"

"Defendants Epstein and Maxwell developed and implemented a sophisticated system designed to insulate them from criminal and civil liability"

"In January 2007, Defendants sent Plaintiff from the United States to South Africa in part to recruit, for a promised fee, one or more aspiring female "

"Certain property of Defendant Epstein's was essential to the commission of the federal crimes... including the use of multiple private aircraft includ"

"Certain property of Defendant Epstein's was essential to the commission of the federal crimes... including... a Gulfstream aircraft... N909JE"

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

"Defendant [REDACTED] reported directly up the enterprise's line of authority to Defendant Maxwell"

"victims themselves, such as Defendant [REDACTED] to elevate their status to that of a paid recruiter of other victims"

"Defendants Epstein and Maxwell informed Plaintiff that she would not be permitted to return to the United States to receive her promised education unl"

"Defendant was working as one of the enterprise's recruiters of young females"

"Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: Ls/ David Boies"

"Defendant Maxwell... herself recruited young females; oversaw and trained other recruiters on how best to recruit girls for sex"

"Defendant [REDACTED] recruited young females and maintained Epstein's sex schedule"