Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 3 of 21 I I. At all times material to this cause of action, Defendants Jeffrey Epstein, Ghislaine Maxwell, owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire to commit intentional or tortious illegal acts against her. FACTUAL ALLEGATIONS 12. At all times material to this cause of action Defendant Jeffrey Epstein was an adult male over 50 years old. Defendant Epstein is known as a billionaire who uses his extraordinary wealth to commit illegal sexual crimes in violation of federal and state statutes and to employ numerous others, including the named Defendants, to conspire and assist in committing those crimes and additional torts as well as to protect and conceal his crimes and torts from being discovered. 13. Defendant Epstein displays his enormous wealth, power and influence to his employees; to the victims procured for sexual purposes; and to the public in order to advance and carry out his crimes and torts. At all relevant times, Defendant Epstein owned and continues to own, directly or through nomincc individuals used to conceal his interests, a fleet of airplanes, motor vehicles, boats and one or more helicopters. He owned and owns numerous properties and homes, including a 51,000-square-foot mansion in Manhattan; a $30 Million, 7,500-acre ranch in New Mexico; a 70-acre private island formerly known as Little St. James in or near St. Thomas, U.S. Virgin Islands; a mansion in London, England; a home EFTA00313634