Case 1:17-cv-00616 Document 1 Filed 01126/17 Page 12 of 21

Case 1:17-cv-00616 Document 1 Filed 01126/17 Page 12 of 21 39. Plaintiff reasonably believed that her compliance with Defendants' demands was crucial to her physical, psychological, financial, and reputational survival. 40. Defendant Maxwell instructed Plaintiff how to massage Epstein using the techniques that he preferred. During Plaintiff's first massage, Defendant Epstein convened it into a sexual act and made it known to Plaintiff that further sex would be required in order for her to obtain the assistance 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 Defendants 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 prescribed sexual acts. 12 EFTA00313651