Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/237-17.pdf

EXHIBIT 17 Case 1:22-cv-10904-JSR Document 237-17 Filed 07/25/23 Page 1 of 18 Case 1:22-cv-10904-JSR Document 237-17 Filed 07/25/23 Page 2 of 18 ., 4 CREDITOR'S CLAIM IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN ********** IN THE MATTER OF THE ESTATE OF ) ) ) ) ) ) JEFFREY E. EPSTEIN Deceased. _________________ ) CLAIM CASE NO. ST-19-PB-80 ACTION FOR PROBATE The Undersigned, Mariann Meier Wang, Esq., of Cuti Hecker Wang LLP., Richard P. Bourne-Vanneck, Esq., and Allred, Maroko & Goldberg, hereby present and file this claim on behalf of • (the "Claimant") for unliquidated and unsecured damages from the Estate of Jeffrey E. Epstein (the "Estate") in the above captioned matter now pending before Court, and in support thereof state as follows: 1. Jeffrey Edward Epstein (the "Decedent") was arrested in New York City, New York on July 6, 2019, and held in custody on sex trafficking charges, following a series of investigations into his activities prior thereto. 2. Claimant is one of a number of under-age victims of Decedent's criminal actions. 3. Decedent, upon information and belief, conspired with multiple individuals, including attorneys and advisors, to fraudulently convey and hide assets from his victims, including Claimant, by transferring assets into a newly created Trust through the provisions of a contemporaneously drafted Last Will and Testament on or about August 8, 2019. 4. On November 21, 2019 Claimant filed a civil action in the United States District Court for the Southern District of New York seeking damages against the Estate. A true and correct copy of the Complaint so filed and indexed as Case No. 1: 19:cv-l 0788 is attached hereto as Exhibit "A". 5. Pursuant to New York's Child Victims Act, among other bases, Claimant's civil action in New York was commenced timely. 6. Decedent committed sexual abuse, including repeated sexual assault and forcible rape upon Claimant on multiple occasions. See, Exhibit "A". Case 1:22-cv-10904-JSR Document 237-17 Filed 07/25/23 Page 3 of 18 Case 1:19-cv-10788 Document 1 Filed 11/21/19 Page 6 of 13 34. -met Epstein for the first time in 2002, when she was seventeen years old. Epstein was visiting Los Angeles, and -drove with her sister to meet him at the Hotel Bel-Air. 35. During that first meeting, Epstein lay on a bed in his spacious hotel suite, fully clothed. He asked I sister to massage his feet, then encouraged -to join her. Afterwards, Epstein took them shopping, and insisted on buying several items for - 36. After that meeting, Epstein kept in touch with -through frequent phone calls. Epstein veered the conversation toward career goals and how Epstein could help her achieve them. He purported to want to help her and guide her to a better life. 37. Epstein offered to send-to school to learn hairdressing, but- made clear that this was not what she wanted to do in the long term. -explained that she had a passion for languages and for people, and that her dream was to be a translator. 38. Epstein claimed that he wanted to help -study to become a translator. He suggested that he would pay for -to study in Spain for a semester. Soon after, Epstein helped her to obtain a letter of recommendation from her high school counselor and helped her get accepted to study at the University of Madrid. 39. -was over the moon, feeling her dreams were coming true. Epstein made sure she felt that it was all his doing. 40. -prepared for this exciting opportunity to study abroad and pursue her dream career. She gave notice at her hairdressing job and gave up her apartment in Los Angeles, preparing to move to Spain. 41. Before -left for her school program, however, Epstein began what would become a long pattern of using her as his sexual object. 6 Case 1:22-cv-10904-JSR Document 237-17 Filed 07/25/23 Page 4 of 18 ' .. ···--• , ••• ,--------------------------· Case 1:19-cv-10788 Document 1 Filed 11/21/19 Page 7 of 13 42. In approximately the summer of 2002, Epstein flew -and her sister to his ranch in New Mexico. -felt no reason to be wary of Epstein. He had been kind in their first meeting and had acted with generosity towards her. 43. When -got to Epstein's ranch, Epstein's close associates Ghislaine Maxwell and Sarah Kellen were there. Maxwell asked -questions about herself and took her horseback riding. Kellen invited -to go swimming. 44. After-swam, Epstein asked her to go into a massage room along with Kellen. Kellen began massaging Epstein, and -innocently joined in, as she had when her sister massaged Epstein's feet the first time. 45. At that point, Epstein began fondling Kellen and took off Kellen's shirt. -became very uncomfortable, as the massage had quickly and unexpectedly turned into a sexual encounter. Epstein reached inside bathing suit and fondled her genitals. - began crying, but Epstein continued to grope her as he masturbated to completion. 46. -felt extremely vulnerable. Epstein had arranged the circumstances to ensure that -was completely at his mercy. -had given up her job and her apartment in order to travel to Spain at Epstein's expense. If Epstein decided to rethink his generosity at any point, -would have had nothing, and would have been left homeless and jobless once again, after being brought so close to her dream. Even though Epstein had preyed upon her and sexually assaulted her, -understood she had no choice but to submit to him. His power over her was all-encompassing. 4 7. Epstein viciously exploited this power dynamic. In the summer and fall of 2002, he flew seventeen-year-old-to his homes in New York, Florida, and the U.S. Virgin Islands, sexually assaulting her in each of those locations. 48. In or around December 2002, Epstein flew -to stay at his townhouse 7 Case 1:22-cv-10904-JSR Document 237-17 Filed 07/25/23 Page 5 of 18 Case 1:19-cv-10788 Document 1 Filed 11/21/19 Page 8 of 13 located at 9 East 71st Street in Manhattan. While they were in the dining room of the townhouse, Epstein without warning stuck his hand down I I pants and fondled her genitals. It was as if she were his toy. 49. In or around that same month, at Epstein's home in Florida, Epstein crept into bedroom while she was sleeping and raped her. 50. Also around that same month, at the private island Epstein owned in the Virgin Islands, Epstein ordered -to massage him, then proceeded to sexually assault her in the massage room. 51. -finally traveled to Spain to study in or around the end of 2002. 52. In early 2003, when -was still seventeen years old, Epstein flew her from Madrid to Paris. At his home in Paris, Epstein again crept into I bedroom while she slept and raped her. 53. When Epstein inflicted these sexual assaults on -she felt completely intimidated and fearful. All she could think about was trying to survive. Her body froze up, and she began crying. 54. After••• semester in Madrid, she had no home and no job. Instead, Epstein brought her to live a nomadic lifestyle in his close orbit. -traveled around the country with Epstein and his entourage, which generally included Maxwell, Kellen, and others. Virtually every few days, Epstein would bring-to a different home of his, including his Manhattan townhouse and throughout the country, where he continued to sexually assault her on a frequent basis. Epstein regularly used his private planes to traffic -into various locations for his sexual abuse of her. 55. Epstein had power over every aspect of life, and he had groomed - to be completely dependent on him and completely submissive to him. Epstein treated 8 Case 1:22-cv-10904-JSR Document 237-17 Filed 07/25/23 Page 6 of 18 Case 1:19-cv-10788 Document 1 Filed 11/21/19 Page 9 of 13 -as a sexual object, using her body for his sexual gratification frequently and at his whim. 56. Eventua