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ALLRED, MAROKO & GOLDBERG
NATHAN GOLDBERG*
MICHAEL MAROKO"
GLORIA R. ALLRED*t
JOHN S. WEST
DOLORES Y. LEAL
RENEE MOCHKATEL
MARGERY N. SOMERS
MARCUS SPIEGEL
CHRISTINA CHEUNGt
BYRON LAU
KIRBY F. CANON
* A PROFESSIONAL CORPORATION
t ALSO ADMITTED TO NEW YORK BAR
OALSO ADMITTED TO WASHINGTON DC BAR
A PARTNERSHIP OF PROFESSIONAL CORPORATIONS
6300 WILSHIRE BOULEVARD
SUITE 1500
LOS ANGELES, CALIFORNIA 90048
FAX
www.amglaw.com
VIA FEDERAL EXPRESS & EMAIL
Mr. Scott Link
Link & Rockenbach, PA
1555 Palm Beach Lakes Blvd., Suite 930
West Palm Beach, FL 33401
Re:
Dear Mr. Link,
June 19, 2019
OF COUNSEL
MARIA G. DEAZ
E-MAIL:
We represent with reference to her claims against Jeffrey Epstein
for childhood sexual abuse which occurred in New York City when she was years old.
New York recently passed the Child Victims Act which creates a 1 year window for
claims where the statute of limitations had expired. Therefore, will be able to sue
Mr. Epstein for the sexual abuse which she experienced while she was a minor.
was the perfect victim.
She was born in M, a town on the coast. When was four years
old, descended into civil war. At the age of six, her entire village was evacuated. She
fled her hometown travelling through war zones on foot with her family, in a stream of refugees.
Her family settled in the outskirts of . As refugees, with no money, her family
lived together in one room, sharing a bathroom with other families. Her parents eventually
found low paying, unskilled jobs. Their only clothing was what was provided to them by the
Red Cross.
When she was ten years old,
family arrived in
By the sixth grade, was 5'10", beautiful and naturally slim. She desperately
NEW YORK OFFICES I 305 BROADWAY, SUITE 607 I NEW YORK, NEW YORK 10007
T (212) 202-2966 I FAX (212) 202-2967
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June 19, 2019
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wanted to leave She learned about a talent search for models and persuaded her
mother to take her. She was a huge success and began modeling at age fourteen. Though her
parents disparaged her for marketing her appearance, they allowed her to work because she
earned more than their combined income.
At age sixteen, moved to New York City to model. She lived in an
apartment for models, with one or two roommates and no adult on the premises. Her father was
deeply ashamed of her because he disapproved of her profession and her parents distanced
themselves.
days were hectic with professional assignments. She worked with top tier
clients and for DNA Modeling Agency, a well-known agency representing supermodels such as
Linda Evangelista and Natalia Vodianova.
was very innocent and inexperienced prior to meeting Mr. Epstein. At age
sixteen, experienced her first kiss. The director of a perfume campaign, Fabian
Barron, wanted a kiss at the end of the commercial as a finale to a perfume ad. She dreaded her
parents' reaction to seeing the commercial. She was raised in the Orthodox Christian Church
where abstinence was encouraged.
met Jeffrey Epstein when was sixteen years old. She was introduced
through a fellow model a few years her senior.
Mr. Epstein seemed bigger than life. He did not drink or do drugs, which put her at ease.
He was friends with former President Bill Clinton, the President who made it possible for ME
and her family to immigrate to America. When she told Mr. Epstein how her family
came to America, Mr. Epstein said he would personally thank "Bill" for her. Mr. Epstein touted
other impressive connections. He made it known that he had A list celebrities on speed-dial.
She felt very fortunate to have made the connection with Mr. Epstein.
As s estrangement from her family increased, Mr. Epstein's role in her life
became more and more important. He encouraged her and built her confidence. She trusted him
completely.
Mr. Epstein told hat he was on the board of directors at Harvard
University. He promised that once she took her SATs and obtained the scores she needed, he
would write a letter of recommendation for her, which he said would carry significant weight
with regard to her admission. Her dream was to establish herself as a successful model and to
one day graduate from Harvard. Mr. Epstein made her feel that everything she wanted was
possible.
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confided to him that she had never even had a boyfriend. He told her
everything would fall into place, "just keep doing what you are doing, work hard and stay
focused." She told Mr. Epstein that she preferred to abstain from sex until she was married.
The first time asked her for a massage was to help with an ache in his
shoulder. thought it was an innocent request. He said his masseuse had failed to
get a kink out of his shoulder. He gave her a large purple massager for her to use to take the knot
out of his back. Mr. Epstein told her she was an excellent masseuse and she was pleased to be
able to ease his pain.
When the massage ended, Mr. Epstein pulled two hundred dollars from his wallet and
handed it to her. He said, "I was going to give it to the masseuse anyway, so you take it and pay
for your car service or something."
Mr. Epstein began calling her every day, no matter where she was in the world. He told
her he loved her. He became a vital part of_________________Iworld as her parents remained
distant. He invited her to stay at one of his apartments close to him on the Upper East Side. Her
arduous work schedule, starting with 6:00 a.m. call times and shows running late into the night
were exhausting. Epstein's daily check-up calls and pep talks gave her strength to survive her
grinding schedule.
When in Paris, Mr. Epstein allowed her to stay at his home with her sister and arranged
for a night out at a concert with Naomi Campbell. It appeared to that Mr. Epstein's
thoughts were focused on her career, future and good fortune.
The first time the purple massage tool found its way between her legs, told
him to stop, but Mr. Epstein pushed the head of the massager firmly against her and forced her
legs apart. She felt ashamed and embarrassed. The massages became a ritual and were always
accompanied with sexual abuse and a two-hundred dollar payment at the end.
Mr. Epstein approached her as if he was her mentor and teacher, teaching her about
sexuality, opening her eyes. She experienced immense orgasms, and then shame and fear. She
felt claustrophobia as she stared up into Mr. Epstein's church-like ceiling of the massage parlor
while he fondled her. She felt she couldn't escape her position, and that this was the way it had
to be because this powerful man orchestrated it. At the end of each massage he would make
himself ejaculate by demanding she pay vigorous attention to his nipples with her fingers and he
would tell her what a good girl she was, that he loved her and would call her later, which made
everything seem better. Then he would open his wallet filled with hundred dollar bills and give
her a couple, which she accepted as pocket money, never thinking twice about it.
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thought this is what it must feel like to become a woman. She was both
thrilled and ashamed. She followed the path that Mr. Epstein set out for her because he said if
she trusted him and did what he told her to do, everything would go according to his plan and her
career would soar. Without him the world was a scary and unpredictable place. When she was
with him, she felt like everything was right because of how much love and care she received
from him. She started to think and believe that they would be together and that he would marry
her.
He used the purple massage vibrator on her time and time again. She closed her eyes
feeling lost, overwhelmed and out of control.
When he stuck his penis in her mouth, she did what she was told. She choked and
gagged and when she tried to move her head away he forced it back into place. Mr. Epstein was
extremely aggressive. When it was over he told her how amazing she was. She continued to
believe in Mr. Epstein's friendship and guidance.
Mr. Epstein took her virginity. This was the trajectory for which he groomed her. =
first sexual experience was devoid of tenderness or affection. She was stripped down
and made to shower. Mr. Epstein told her, "If you're lying about being a virgin, or I get a
disease from you, I'll kill you." She felt her mind separate from her body during intercourse.
She began to feel like a shell of her former self. She was mortified and in agony. She
felt she had become everything her parents feared she would become. She was appearing in
beauty magazines and making hundreds of thousands of dollars, but felt dirty and worthless. Mr.
Epstein made her feel like nothing more than a teenage prostitute. Everything came crashing
down once she realized that this was not love.
left Mr. Epstein's residence for the last time feeling less than human. On
her way out, she passed a young girl who appeared to be another young model. As
turned around to glance back, she saw the young woman entering Mr. Epstein's residence. She
was disgusted with the realization that she was one of many called to "massage" Epstein.
had a nervous breakdown while alone in New York. She found herself
crying inconsolably, shaking, hyperventilating and unable to go to her castings and meetings.
She was suicidal. She feared confiding in her agents and reaching out for help from them
because she was so ashamed. She booked a ticket to go home.
She flew back to Kansas where her parents were living. She never returned to New York.
was devastated with the realization of what she was lured into and how she
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had been victimized. It shattered her to her core. At the vulnerable age of 16, Mr. Epstein made
himself the center of her existence and the master of her world. She realized she was a
disposable pawn in his game. She could not talk about her years with Mr. Epstein because she
was consumed with shame. At 16 years old, he isolated her and made himself her only
emotional support system. Her mental torment and pain turned into depression. She was
prescribed medication. She numbed herself and tried not to deal with what had happened. She
tried to block the pain.
____________was embarrassed that she had been used and abused. She withdrew and had
no desire to model or interact with anyone in the modeling world anymore.
stopped taking calls from modeling agencies, and eventually they stopped calling for good. She
was afraid to go to New York where her emotions and memories would be triggered.
The final contact between and Mr. Epstein was when he tracked her
parent's house phone number in Kansas and tried to speak to her. mother
grabbed the phone and told Mr. Epstein she was calling the police before hanging up on him.
Her career dwindled to nothing. Taking a break from the modeling industry when clients
like Italian Vogue and Victoria's Secret were requesting bookings constituted career suicide.
In Kansas she became chronically depressed. She was suicidal before her 18th birthday.
She called the suicide hotline many times from her home.
While in Kansas, a friend of________________ent her an email with news that Mr. Epstein
had been arrested for trafficking underaged girls. felt as if she had gone from
being a supermodel to becoming an unsuspecting prostitute. Her parents' warnings of what
would become of her in New York had come to fruition. She fell prey to a child predator, Mr.
Epstein, and it took her a decade to understand the gravity of what Epstein had done to her as a
vulnerable young girl.
Mr. Epstein mas ueraded as a loving mentor, a parental substitute and friend who had
nothing bul best interest in mind. The repercussions of the sexual and mental
abuseendured remain with her. Her first sexual encounters are forever scarred by
memories of Mr. Epstein forcing his purple massage device between her legs amidst her cries for
him to stop. Debilitating nausea and stomach pain followed her separation from him. She had
no framework with which to reference what a "normal" sexual experience was. She remains
plagued with self-doubt and insecurity and finds it nearly impossible to separate memories of
Mr. Epstein's manipulation and abuse from new relationships she tries to develop.
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The sexual abuse Mr. Epstein inflicted upon left irreparable psychological
scars. She has struggled and continues to struggle with her ability to maintain healthy
relationships with men and in general. Her career is permanently compromised and the
likelihood of recovering severed professional ties is non-existent.
Please contact us within ten days of this letter to advise whether Mr. Epstein is amenable
to attempting to resolve 's civil claims without litigation.
Very truly yours,
ALLRED, MAROKO & GOLDBERG
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