Case 1:17-cv-00616 Document 1 Filed 01126117 Page 5 of 21

Case 1:17-cv-00616 Document 1 Filed 01126117 Page 5 of 21 Defendant reported directly up the enterprise's line of authority to Defendant Maxwell. 17. Defendant Epstein employed many recruiters of young females. The nature of the Defendants' scx trafficking scheme enabled victims themselves, such as Defendant Malyshcv, to elevate their status to that of a paid recruiter of other victims. Recruiters were taught by Defendants Epstein and Maxwell to inform targeted victims that Epstein possessed extraordinary wealth, power, resources and influence; that he was a philanthropist who would help female victims advance their careers and lives; and that the recruits needed only to provide Epstein with body massages in order to avail themselves of his financial assistance and influence. In fact, however, these representations were fraudulent. The vast majority of girls were required to perform intimate sexual acts at the Defendants' direction and the Defendants did not help or intend to help advance the victims' careers. 18. Defendant Groff coordinated schedules between Defendant Epstein and the various young females used for sex; made travel arrangements for the girls; tended to their living needs; and communicated with them in order to maintain their compliance with the rules of behavior imposed upon them by the enterprise. 19. The Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled Epstein's compulsive need for sex with young females by preying on their 5 EFTA00313636