Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 18 of 21

Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 18 of 21 60. Defendants individually and together, within the special maritime and territorial jurisdiction of the United States, in interstate and foreign commerce and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, maintained, patronized, solicited, threatened, forced, and coerced Plaintiff to engage in commercial sex acts. Such actions by Defendants were undertaken with knowledge and/or reckless disregard of the fact that their threats of force, fraud, coercion, and combinations of such means would be used, and were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In so doing, Defendants violated 18 U.S.C. §§1591 through 1594 and arc subject to civil causes of action under 18 U.S.C. § 1595. 61. Defendants additionally profited from the sex trafficking of Plaintiff; obstructed investigations of the violations; attempted and conspired to violate, and succeeded in violating, 18 U.S.C. §§ 1591 through 1595, by the commission of the torts and crimes described in this complaint. 62. Certain property of Defendant Epstein's was essential to the commission of the federal crimes and torts described herein, including the use of multiple private aircraft including a Hoeing aircraft (of make and model 8-727- 311-I with tail number N908JE) and a Gulfstream aircraft (of make and model G- 1159B with tail number N909JE). Such aircraft, along with other of Defendants' IS EFTA00313663