Case 1:17-cv-00616 Document 1 Filed 01126/17 Page 11 of 21

Case 1:17-cv-00616 Document 1 Filed 01126/17 Page 11 of 21 35. Defendant informed Plaintiff that she would introduce Plaintiff to Defendant Epstein, whom she described as a wealthy philanthropist who regularly used his wealth, influence and connections to help financially poor females like Plaintiff achieve their personal and professional goals and aspirations. 36. Defendant reported to her superiors, Defendants Groff and Maxwell, and was paid for her recruitment of young females, including the recruitment of Plaintiff. 37. Defendant introduced Plaintiff to Defendant Epstein, who confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into The Fashion Institute of Technology, known as "F.I.T.", in New York City, or into a similar institute of higher learning offering a curriculum of fashion industry training. Defendants Maxwell, and Groff each confirmed this promise to Plaintiff many times. 38. Defendant Maxwell told Plaintiff she would need to provide Defendant Epstein with body massages in order to reap the benefits of his and Maxwell's connections. Maxwell and Epstein also threatened Plaintiff that, while they had the ability to advance her education and career, they also had the ability to make sure that she would obtain no formal education or modeling agency contracts if she failed to provide the sexual favors desired by Defendant Epstein or abide by the instructions given her by Defendants Epstein and Maxwell. I I EFTA00313650