Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 18 of 21Case 1:17•cv-00616 Document 1 Filed 01/26/17 Page 20 of 21
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efta-efta00313664DOJ Data Set 9OtherCase 1:17-cv-00616 Document 1 Filed 01/26/17 Page 19 of 21
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Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 19 of 21
property, were used as means and instruments of Defendants' tortious and criminal
offenses and, as such, are subject to forfeiture.
63.
Additionally, Defendant Epstein's New York mansion, located at 9
East 71st street, New York, New York, and his private island located in the United
States Virgin Islands, were used as means and instruments of Defendants' tortious
and criminal offenses and, as such, are subject to forfeiture.
64.
As a direct and proximate result of Defendants' commission of the
aforementioned criminal offenses enumerated in Title 18 U.S.C. § 1591 et. seq.
and the civil remedies provided in § 1595, Plaintiff has in the past suffered and will
continue to suffer injury and pain; emotional distress; psychological and psychi-
atric trauma; mental anguish; humiliation; confusion; embarrassment; loss of self-
esteem; loss of dignity; loss of enjoyment of life; invasion of privacy; and other
damages associated with Defendants' actions. Plaintiff will incur medical and
psychological expenses. These injuries are permanent in nature and Plaintiff will
continue to suffer from them in the future. In addition to these losses, Plaintiff has
incurred attorneys' fees and will do so in the future.
19
EFTA00313664
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