(On behalf of Jane Doe individually)  (Battery)  (Common Law of New York, Florida, U.S. Virgin Islands, and France)  153.  Plaintiff hereby incorporates each of the foregoing paragraphs as if fully  set forth herein.  154.  In committing the acts described above, Epstein intentionally subjected  Jane to bodily contact that was harmful and offensive in nature.  155.  Groff is liable for aiding and abetting Epstein’s actions.    156.  Upon information and belief, Groff knowingly provided substantial  assistance to Epstein in Epstein’s tortious actions against Jane.  157.  Upon information and belief, Groff was aware at the time that she was  playing a role in overall illegal and/or tortious activity by Epstein.  158.  As a result of Epstein’s and Groff’s actions, Jane suffered damages in an  amount to be determined at trial.  39.  Jane Doe’s early childhood was in a small city.  She lived in Moscow from her  teenage years until recently.  In 2017, she was attending a university in Moscow and working  part-time as an interpreter.  She often used a Russian job posting website to find postings for  part-time jobs working as an interpreter at conferences and other events.   41.  Shortly after she applied for that job, Jane received a message on WhatsApp from  an unknown number that connected Jane to a Russian woman who worked for Jeffrey Epstein.   That woman asked Jane to send her résumé and photographs of herself, and then to send her  Instagram handle.     42.  The Russian woman set up a Skype call with another Russian woman who  worked for Epstein, Woman 1.   Woman 1 interviewed Jane over Skype, in Russian.  Woman 1  emphasized in the interview that it was not merely a job, but an “investment” in herself, and an  opportunity to build a successful career.  Woman 1 told Jane that it was a financial company and  that a man was looking for a personal assistant, but she did not tell Jane the name of the company  or the full name of the man she would be working for.  When Jane asked for more information,  such as the name of the company or the identity of the CEO, Woman 1 told her that information  was confidential.     43.  A day or two later, Jane was invited to meet with Woman 1 in person at a coffee  shop in Moscow.  Woman 1 was with her mother during the meeting, which reassured Jane that  there was nothing to be concerned about.  During that meeting, Woman 1 told Jane about the  great opportunities the job would provide her, such as traveling around the world and having her  education paid for.  Jane felt inspired by what the woman said, and eager to pursue this once-in- a-lifetime opportunity.   45.  Another employee of Epstein’s who was based in New York, Woman 2, emailed  Jane the airline ticket.  The email chain indicated that the ticket had been sent to Woman 2 by  another of Epstein’s associates working out of New York, Lesley Groff.     46.  Groff knew or recklessly disregarded the facts and information that made clear  that Epstein was trafficking Jane to Paris for commercial sex purposes, and that Epstein was  doing so by means of force, threats of force, fraud, coercion, and/or a combination of such  means.  Epstein Traffics Jane to Paris and Sexually Assaults Her   47.  Jane arrived in Paris from a flight paid for by Epstein and arranged by his New  York-based employees/agents on or about September 9, 2017.  On information and belief,  Epstein used funds and/or financial institutions based in New York to arrange for Jane’s flight.     48.  Epstein had arranged for a driver to pick Jane up at the airport and drive her to his  third-floor flat.  Jane marveled at how large Epstein’s home was:  it appeared to have at least ten  rooms, a gym, a huge living room, a huge office with a library on one side, and at least five guest  bedrooms.  Each of the guest rooms was stocked with pajamas, hygiene products, and other  amenities.  The flat was decorated in what Jane viewed as a “wealthy classical” style.  Jane also  noticed that there were photos of girls on the walls throughout the apartment, including of  Woman 1 (the woman Jane had met in Moscow).  Most of the girls in the photos looked quite  young.   50.  Jane introduced herself to Epstein, and he asked her some basic, normal questions  about herself and about the job she was being interviewed for.     51.  Epstein gave her approximately 500 euros in cash, and when Jane asked why he  was giving that to her when she had just come for an interview, he said it was to pay her for  coming.  In fact, this money was payment for his own use of her for his sexual gratification, as  she would later brutally learn.    52.  After the meal, they returned to Epstein’s flat.  Woman 1 was present, as was  another one of Epstein’s assistants, Woman 3.     53.  Woman 1 showed Jane to a bedroom where she would be staying, and told Jane  she should change into the pajamas that were in her bedroom.  Jane saw that the other girls had  changed into similar pajamas as well.  Jane found it strange and surprising that everyone had to  put those pajamas on and could not just keep wearing their own clothes they had brought for  themselves.  Jane asked Woman 1 if she could stay in her room and sleep, as they had just had  the interview and she had traveled that day.  But Woman 1 said that Jane should stay awake and  available outside her room because Epstein might want to talk to her.     54.  A short time later, Epstein told his assistant Woman 1 to bring Jane to the  massage room.  Jane was led to that room, which she recalls being on one side, just past the gym  and next to two of the bedrooms.  The massage room was mostly dark.  There was a shelf with  what appeared to be facial-treatment masks, creams, and oil, and there were photos of naked  females on the walls.  Jane had the impression that they were girls and women whom Epstein  knew.   56.  After approximately 20 minutes, Woman 3 left, leaving Jane alone with Epstein in  the massage room.  Epstein instructed Jane to continue to massage him.  Epstein then told Jane to  take off the top half of her pajamas, but Jane refused.  Jane felt frozen, confused and scared  about what was happening.  Epstein clearly noticed, and asked Jane why she was so  embarrassed, and said in substance – both cajoling and shaming her – “You need to be more  open, or you won’t get anywhere in life.  Just relax.”  Epstein made all this strange behavior  seem normal and made Jane feel like it was her fault that she did not want to comply.  Epstein  then again directed Jane to strip down to just her bra and underwear and to lie down on the  massage table.  This time, Jane complied.     57.  Epstein critiqued Jane’s body, telling her that she had more weight on her hips  than she should, and told Jane that she needed to lose weight (although she was not remotely  overweight).   59.  Jane still felt frozen with enormous fear and confusion.  Minutes earlier, everyone  in this man’s luxurious house had seemed so happy, and suddenly she was in a room where the  man who owned and dictated the entire atmosphere and had bought her plane tickets, paid for her  housing and food and flown her here was forcing unwanted sexual acts on her.  Jane felt utterly  frozen and powerless.  She was in a foreign country, she did not know anyone in the apartment,  and Epstein had insisted to her that this was all normal and that she was at fault for failing to be  “open.”  Epstein continued masturbating until he ejaculated.  Without missing a beat, and again  acting as if everything were normal, he then told Jane to change her clothes and to meet him in  his office.   60.  Epstein then spoke with Jane in his office.  Epstein mostly lectured Jane about her  mentality and critically asked why she was so “closed.”  He said that if she wanted to achieve  anything, she should do what he told her to do, implying that the wealth and power he had were  the result of his own genius and she could be part of it if she just followed his directions.  Jane  expressed that she had a college degree and was not looking for this kind of job, that this was not  something she could ever imagine herself doing.  She told him, in substance, “I thought this was  a normal job.  I did not think this sex part was involved,” but Epstein did not respond to that.     62.  During the above conversations, Epstein effectively laid out his twisted thinking  as to why he had focused on recruiting young women from former Soviet countries to be  trafficked.    63.  Jane was scheduled to return to Moscow the next day.  Around 11:00 the  following morning, Epstein told Jane to come to the massage room.  He condescendingly asked  if Jane had learned anything from their conversation the previous day, and urged her to change  her mind and work for him.  Epstein then instructed Jane to give him a massage, and she obeyed,  feeling she had no choice.  Epstein ordered Jane to take off her clothes, and she obeyed, leaving  only her underwear on.  Epstein ordered Jane to massage his chest and touch his nipples, and she  obeyed.  The massage went on for approximately 20 minutes.  Partway through, Epstein began to  masturbate with one hand.  He ordered Jane to take her underwear off, and touched Jane’s  genitals with the other hand, without her consent, while he masturbated.  Throughout this  encounter, Jane just kept thinking that she wanted to leave as soon as possible, while trying to  keep a neutral facial expression and not show outwardly the fear, shame, and turmoil inside her.   It was apparent to her that Epstein was angry with her because he thought she was too “closed”  and did not do what he wanted.  Eventually, Epstein ejaculated.  He told her to change, pack for  her flight, and come talk to him in his office before she left.   65.  Jane went home shocked and confused.  She still did not understand what the  “job” was.  She knew that she could not tell anyone about what had occurred in Paris, and did  not know what to do.  She also thought more and more about the fact that perhaps Epstein was  right, that she was the one who was closed off and unable to see the opportunities he was  offering her.   66.  In the ensuing weeks, Epstein began communicating with Jane frequently by text  and by Skype video chat.  Epstein plainly was communicating to Jane from New York during  some or all of these conversations.  Epstein offered to send Jane money, and he asked her to send  him nude photos of herself.  Jane refused to do so, which angered Epstein.  Jane explained to  Epstein that she did not understand what the job he was offering her entailed, and asked him to  explain.  In response, Epstein gave her two “tasks” to do: to come up with an idea for a  Christmas gift for Epstein to give all of his employees, and to design furniture for a new house of  Epstein’s on his island.  Jane thoughtfully and diligently prepared those tasks and emailed them  to Epstein, but Epstein just ignored her work, giving the plain impression that those were not real  assignments but simply attempts to get Jane to stop asking questions.  Epstein Again Traffics Jane to Paris and Sexually Assaults Her   68.  Upon information and belief, Groff, working from Epstein’s townhouse in New  York City, took one or more actions to traffic and/or to facilitate the trafficking of Jane to Paris  on this second occasion.   69.  Once again, Epstein had a driver pick Jane up at the airport and take her to his  flat.  When Jane arrived at the apartment, the only people there were Epstein, Woman 3, and  another driver of Epstein’s.     70.  Soon after Jane arrived, Epstein told her it was time for a massage and sent her to  the massage room.  Epstein then came into the massage room, laid on the massage table, and  ordered her to start massaging him.  Partway through the massage, Epstein began to masturbate  while Jane massaged him.  He once again ordered Jane to take her underwear off, and began  once again to touch and rub Jane’s genitals while he masturbated.  Eventually, Epstein  ejaculated.  He then told Jane to change her clothes and meet him in his office, once again  normalizing the sexual assault as part of some kind of business opportunity, albeit a fraudulent  one.     72.  Jane flew back to Moscow the next day.  Before she went to the airport, Epstein  again criticized her for not being more attentive to what he wanted, specifically telling her she  should have asked his driver how Epstein likes his coffee prepared so she could make it for him  without being asked.  Jane then traveled back to Moscow.  Epstein Fraudulently Traffics Jane to Florida Under the Guise of a Job and Rapes Her   73.  After Jane returned to Moscow, Epstein told her that he had work for her to do,  and that she should come to his home in Florida.  Jane was still under the impression that a  lucrative job and opportunities with Epstein’s business were being offered to her, and Epstein  had groomed her to believe that she had no choice but to obey – that in fact it was her own  limitations that made her question this opportunity.     74.  On or about September 20, 2017, Epstein’s assistant Bella Klein, who worked out  of New York City, wired Jane 2,000 Euros so she could apply for a U.S. visa to come to  Epstein’s Florida home.  Jane obtained the visa in early November.  She was flown to Palm  Beach and entered the United States from Russia on or about November 17, 2017.    76.  When Jane arrived at the airport in Palm Beach, Epstein’s employees Woman 3  and a driver took Jane from the airport and drove her to Epstein’s mansion.     77.  Epstein’s Palm Beach estate was as impressive as his Paris home.  The palatial  home had a pool, a poolhouse, a number of bedrooms, and there were two Cadillacs there.   Before one entered the mansion, there was a small building that housed approximately three of  Epstein’s employees, who appeared to be Southeast Asian, perhaps Filipino.  There was another  small house on the property with Epstein’s office, a gym, and a bathroom in it.  Inside, the  mansion was largely white, including the sofas and two end tables.  There were books on the  living room table, photos on the wall, and a decorative wooden bicycle.  At one point during the  visit, Epstein showed Jane a broken guitar on display and said that it had been a gift from Woody  Allen.   78.  The evening that Jane arrived, Epstein told the driver to show her into Epstein’s  office.  Epstein questioned her about her life in Moscow and what she was doing.  Jane tried,  tentatively, to assert herself, telling Epstein during the conversation that she was not able to have  much stress in her life because of an underlying long-term disease which was exacerbated by  stress.  Epstein did not react emotionally to that, but told her that she did not need to worry  because no one had stress in his house.  At one point, Woman 3 came into the office.  Epstein put  on some current pop music and Woman 3 began dancing.  Epstein suggested that Jane dance too,  but Jane explained that she was very tired because she had been traveling all day.  At that point,  Jane went to her room for the night.  Jane’s room, which was on the second floor of the mansion,  looked like a typical hotel room.  It had a private bathroom, and was stocked with pajamas and  various personal hygiene items.   80.  Epstein entered the massage room and closed all of the windows and doors to that  room.  He directed Jane to massage him starting with his legs and told her which oil to use.   Epstein then ordered Jane to massage his chest and touch his nipples.  At one point during the  massage, Epstein appeared to notice that Jane appeared unhappy, and he got angry that she was  not more enthusiastic and playful about what she was doing.  Epstein angrily halted the massage  and told Jane to take off her shorts and underwear.  Jane declined to do so, and told Epstein,  truthfully, that she had her period.  Epstein said he did not care, and again ordered her to do so.   Frightened and confused, Jane finally obeyed his order and took her underwear off.  Epstein then  physically turned Jane around and proceeded to have sex with her while standing behind her.   This forcible rape went on for approximately five minutes, and Epstein ejaculated inside of Jane.     81.  During this rape, Jane felt worse than she had ever felt in her life.  It felt  psychologically overwhelming, like she could not even understand what was happening to her.   It felt like the rock bottom of her life.     83.  Jane had traveled to Florida under the impression that she would meet some of  Epstein’s employees in Florida so they could show her the work she was to do.  But she was  never given any specific work to do.  Instead, when Epstein was not raping or otherwise forcing  sexual acts on her, Jane found herself just sitting around, not understanding what she was  supposed to be doing.   84.  At one point while Jane was in Palm Beach, Epstein directed her to come to his  office.  She arrived, and Epstein was watching pornographic videos on a website.  He began to  show them to Jane.  Epstein told her, in substance, “You should watch this and see how they do  it.”  At one point, Woman 3 came into the office while the pornographic videos were on, but she  did not visibly react, once again messaging to Jane that this was “normal” behavior.  With  Woman 3 present, Epstein told Jane that she needed to learn to massage his penis better.  He told  her that Woman 3 had gone to Turkey and learned how to massage a man, and similarly referred  to another girl, whose photo was on the table, who he said had done so as well.    86.  The next morning, Epstein asked Jane, in substance, “Why don’t you do anything  I want you to?”  He told her she was not attentive to what he wanted.  Once again, he criticized  her for not asking one of his employees how to prepare his coffee so she could make it for him.   He told Jane that she had bad energy, and he became brusque and rude towards her.  His angry  behavior made Jane afraid.   87.  Before Jane left Palm Beach, Woman 3 approached her and said that Epstein was  mad at Jane and that she should be more “open.”  She said that Jane should consider herself  lucky because she was able to see Epstein on three occasions, whereas most girls never came  back after one visit.  She told Jane, in substance, “If you want to make him happy, go back to his  office and give him [oral sex]” to remedy that.  Jane did not do that.  Instead, she did her best to  hide from Epstein for the final day she was in Florida.  She left to walk on the beach when she  could.  When Epstein told her to go to the massage room once again, she made up an excuse and  said that she was feeling sick because of something she ate.  The next day, after spending three  or four days in Florida, Jane flew back to Moscow.    Epstein and His Associates Continue to Pressure Jane to Return    88.  After Jane returned to Moscow in November 2017, Epstein continued to text her  and to call her on Skype, often from New York.  He again asked her to send nude photos of  herself, and threatened that there would be negative consequences if she did not.  Jane was afraid  of Epstein and felt that she had no choice, so she eventually sent him two nude photos.    90.  Jane was trying desperately to assert herself, but at the same time continued to  think that perhaps she was wrong and this incredibly wealthy and successful man must be right,  and that his paying attention to her made her special.    91.  Epstein continued to contact Jane, including sending her a text in February 2018  wishing her “Happy Valentine’s Day” and sometimes sending photos to her.  In the summer of  2018, when the World Cup was taking place in Russia, Epstein’s assistant Woman 3 called Jane,  explained she was in Moscow, and asked if Jane would meet her.  Jane agreed to meet her in a  public place.  Woman 3 took a picture with Jane, which she clearly intended to send to Epstein.   Woman 3 again tried to convince Jane to see Epstein again, but Jane refused.  In September  2018, Jane was in France for a conference.  Woman 3 contacted her again, saying she had  learned from Instagram that Jane was in France and asking if she would see Epstein again.  Once  again, Jane refused.  Epstein Traffics Jane to New York Under the Pretense of Assisting Her Business   92.  In 2018, Jane tried starting a new business in Russia, which put her under  enormous pressure to succeed.  She was working long hours for the company and participating in  high-pressure programs and opportunities to bring the company a higher profile and investors.   94.  Under enormous stress, with little sleep and the sense that many people were  relying on her, Jane ultimately decided to reach out to Epstein’s employee, Woman 3, to ask her  if she thought Epstein would help her with a ticket to New York and a place to stay while she  was there.  At that point, Jane convinced herself that she felt Epstein “owed” her for what he had  done to her – the prior rape and assaults – and somehow also thought she could control these  interactions in ways that would avoid or minimize further abuse.  She also had echoes of Epstein  telling her that she was special and believed he would provide her with the opportunity to take  the meetings in New York to get the funding for her company that she desperately needed.  Of  course, she was wrong on all counts.   95.  Woman 3 told Jane that Epstein would agree to help her, but wanted to talk to her  first via Skype.  On that call, Epstein began by expressing enormous anger, chastising Jane for  having treated him poorly and having “run off” on him and “ignored” him.  He belittled her,  insulted her, and told her that she was a bad person, at the same time emphasizing that he was  such a nice and good person that he would forgive her and still agree to help her.  He made it  clear that she was in debt to him for his magnanimity and forgiveness, and said she would have  to do something for him.     96.  Jane felt there was no turning back.  She believed she could get the funding for  her company and convinced herself that she could somehow “handle” the acts Epstein might  potentially require of her in exchange; she said thank you to Epstein and accepted his help.  She  continued to simultaneously believe that somehow Epstein would in fact see her value and the  importance of her company.     98.  Jane was trafficked by Epstein to New York in early December 2018.  Upon  landing in New York City, Jane got into a taxi and thought she would be taken to the Manhattan  apartment where Epstein and/or his associates had said she would be staying.  On that drive,  while she was in the midst of planning her business meetings for the following days, Jane  received a phone call from Epstein.  He told her that instead, they would immediately pick up  Woman 3 and the two of them would be driven directly to a different airport.  Before she knew  it, and before she could embark on any of her plans in New York – the entire reason she had  reluctantly communicated with Epstein again – Jane was placed on a plane from New York to  Palm Beach.    