Case 1:17-cv-00616 Document 1 Filed 01126/17 Page 12 of
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39. Plaintiff reasonably believed that her compliance with
Defendants'
demands was crucial to her physical, psychological, finan
cial, and reputational
survival.
40. Defendant Maxwell instructed Plaintiff how to massage Epste
in using
the techniques that he preferred. During Plaintiff's first massage, Defendant
Epstein convened it into a sexual act and made it know
n to Plaintiff that further
sex would be required in order for her to obtain the assis
tance he promised and to
avoid Defendants' threatened retaliation if Plaintiff did not
perform as demanded.
41. Defendants Maxwell and Epstein informed Plaintiff that
other young
females in Defendant Epstein's company were there not only
to provide massages,
but also sexual acts.
42. Plaintiff was instructed dozens of times to provide body
massages to
Defendant Epstein, both at his townhouse in New York and
on his private island in
the U.S. Virgin Islands. Each time she was so instructed
she was also required to
perform a sexual act with Defendant Epstein. The Defendan
ts transported Plaintiff
in interstate and foreign commerce, and affecting interstate
and foreign commerce,
for these sexual purposes.
43. During many sexual encounters, Defendant Epstein gave
Plaintiff no
option, opportunity or choice not to participate in the presc
ribed sexual acts.
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EFTA00313651