Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 14 of 21

Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 14 of 21 47. Defendant Epstein's wealth, influence, power and connections were used both as an inducement to provide sex (in exchange for promises of support), and as a means of threatening punishment (should Plaintiff, refuse to comply with Defendants' instructions). 48. In addition to Plaintiff's being trafficked on Defendant Epstein's private plane, Defendants Groff, Maxwell an with the knowledge of and instruction by Defendant Epstein, arranged Plaintiffs commercial air travel on numerous occasions for the purpose of causing Plaintiff to commit commercial sex acts. 49. Defendants provided living quarters for Plaintiff at 301 East 66 Street, New York; a car service for Plaintiff to use as needed; a cell phone; and other valuable consideration in order to maintain Plaintiffs sexual compliance. 50. The relationship between Plaintiff and Defendants Epstein and Maxwell was defined and characterized by Defendant Epstein's and Defendant Maxwell's frequent and persistent fraudulent representations that they would provide Plaintiff with a formal education and career advancement if site provided sex to Defendant Epstein and others in the times, places and manners demanded by Defendants. Plaintiff reasonably relied on those representations. In fact, however, those representations were knowingly false, were not acted upon, and were made by Defendants Epstein and Maxwell solely for the purpose of maintaining I4 EFTA00313653