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Plaintiff was subject to acts of rape, sexual misconduct, criminal sexual acts,
sexual abuse, forcible touching, assault, battery, intentional and reckless infliction of emotional
distress, duress, false imprisonment, and threats of death and/or serious bodily injury by the
Defendants that took place at several parties during the summer months of 1994. The parties
were held by Defendant Epstein at a New York City residence that was being used by Defendant
Epstein at 9 E. 71st St. in Manhattan. During this period, Plaintiff was a minor of age 13 and
was legally incapable under New York law of consenting to sexual intercourse and the other
sexual contacts detailed herein. NY Penal L § 130.05(3)(a). The rapes in the first, second, and
third degrees; sexual misconduct; criminal sexual acts in the first, second, and third degrees;
sexual abuse in the first, second, and third degrees; and forcible touching (and, on information
Case 1:16-cv-07673-RA Document 4 Filed 10/03/16 Page 2 of 10
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and belief, predatory sexual assault) detailed herein are unlawful under New York law, e.g., NY
Penal L § 130.20-130.52, and 130.55-130.65 (and, on information and belief, 130.95) and
constitute the torts of, inter alia, assault, battery, false imprisonment, and intentional or reckless
infliction of emotional distress, including threats of force and serious bodily harm, under New
York law. In addition, 18 U.S. Code § 2255 provides Plaintiff with a civil remedy for personal
injuries because Plaintiff, while a minor, was a victim of violations of 18 U.S.C. §§ 1591, 2421,
2422(b), and 2423(a) and she suffered personal injury as a result of such violations. Declaration
of Plaintiff Jane Doe, Exhibit A hereto; Declaration of Tiffany Doe, Exhibit B hereto;
Declaration of Joan Doe, Exhibit C hereto; Jane Doe, Tiffany Doe, and Joan Doe are each
pseudonyms as each woman wishes anonymity. Tiffany Doe, a witness, was an employee of
Defendant Epstein. Exh. B. Joan Doe, a witness, was a childhood classmate of Plaintiff who, in
the 1994-95 school year, was told by Plaintiff that Plaintiff was subject to sexual contact by the
Defendants at parties in New York City during the summer of 1994. Exh. C