WEBVTT 1 00:00:00.160 --> 00:00:03.879 What's up everyone, and welcome back to the Epstein Chronicles. 2 00:00:04.480 --> 00:00:07.240 In this episode, we're going to hear the allegations from 3 00:00:07.559 --> 00:00:10.800 Jane Doe number seventeen, and we're going to keep the 4 00:00:10.880 --> 00:00:15.640 discuss bus rolling. The complaint. Plaintiff Jane Doe seventeen buy 5 00:00:15.640 --> 00:00:18.800 and through the undersigned Council in support of her claims 6 00:00:18.839 --> 00:00:23.679 against defendant alleges and states as follows. One, This action 7 00:00:23.800 --> 00:00:27.760 is brought inter ally a pursuant to common law, statutory law, 8 00:00:28.160 --> 00:00:32.000 and US Code eighteen section fifteen ninety one and fifteen 9 00:00:32.079 --> 00:00:36.320 ninety five. Therefore, jurisdiction is proper under US Code twenty 10 00:00:36.359 --> 00:00:39.600 eight thirteen thirty one, and the damages sought exceed the 11 00:00:39.679 --> 00:00:44.759 jurisdictional requirements of this Court. Two Plaintiff files this complaint 12 00:00:44.920 --> 00:00:48.079 under a pseudonym in order to protect her identity, because 13 00:00:48.079 --> 00:00:52.280 the complaint makes allegations of a sensitive sexual nature, the 14 00:00:52.359 --> 00:00:56.640 disclosure of which, in association with her name, would further 15 00:00:56.920 --> 00:01:01.960 cause her harm. Three Plaintiff is currently resident and domiciled 16 00:01:02.000 --> 00:01:04.079 in the state of Florida and over the age of 17 00:01:04.120 --> 00:01:08.519 eighteen four. At all times material, Jeffrey Epstein was a 18 00:01:08.560 --> 00:01:11.560 citizen of the United States and resident of the US 19 00:01:11.640 --> 00:01:14.920 Virgin Islands. Epstein was a man of extreme wealth who 20 00:01:14.959 --> 00:01:20.400 frequently traveled between and regularly stayed in his numerous residences, 21 00:01:20.439 --> 00:01:23.359 including in New York within the Southern District of New 22 00:01:23.439 --> 00:01:27.040 York at nine East seventy first Street, New York, New York. 23 00:01:27.519 --> 00:01:30.959 In pom Beach, Florida at three fifty eight l Brio Way, 24 00:01:31.239 --> 00:01:34.560 pom Beach, Florida, in New Mexico at forty nine Zora 25 00:01:34.640 --> 00:01:39.359 Ranch Road, Stanley, New Mexico, in Paris, France at twenty 26 00:01:39.400 --> 00:01:43.000 two Avenue Fought, Paris, France, and in the United States 27 00:01:43.079 --> 00:01:47.680 Virgin Islands at Little Saint James Island, number five. At 28 00:01:47.719 --> 00:01:50.879 all times material to this cause of action. Epstein was 29 00:01:50.920 --> 00:01:54.680 an adult male born on January twentieth, nineteen fifty three, 30 00:01:54.920 --> 00:01:59.760 who died on August tenth, twenty nineteen six. Defendant Darren 31 00:01:59.799 --> 00:02:04.079 Ky and Richard D. Con as joint personal representatives of 32 00:02:04.120 --> 00:02:07.879 the Estate of Jeffrey e Epstein. A State of Jeffrey 33 00:02:07.920 --> 00:02:11.400 e Epstein was opened and domiciled in the United States 34 00:02:11.520 --> 00:02:15.400 Virgin Islands, Saint Thomas Division, and is the legal entity 35 00:02:15.599 --> 00:02:20.039 responsible for intentional, criminal, or tortious conduct committed by Epstein 36 00:02:20.199 --> 00:02:24.560 as described in this complaint seven. At all times material 37 00:02:24.639 --> 00:02:29.400 here too. Defendant ninety seventy first Street Corporation was a 38 00:02:29.439 --> 00:02:33.759 domestic business corporation conducting business in New York, with its 39 00:02:33.800 --> 00:02:38.039 principal place of business located at five seventy five Lexington, 40 00:02:38.520 --> 00:02:43.319 fourth Floor, New York eight. At all times material here too. 41 00:02:43.400 --> 00:02:47.400 Defendant Laurel Incorporated was and is the US Virgin Islands 42 00:02:47.400 --> 00:02:52.039 corporation conducting business in multiple locations, including New York and 43 00:02:52.159 --> 00:02:56.560 Florida number nine. At all times material here too. Defendant 44 00:02:56.560 --> 00:03:00.599 Financial Trust Company Incorporated was and it is the US 45 00:03:00.680 --> 00:03:05.199 Virgin Islands corporation conducting business in multiple locations, including New 46 00:03:05.280 --> 00:03:09.639 York number ten. At all times material here too. Defendant 47 00:03:09.759 --> 00:03:15.240 nes LLC nes was and is a domestic limited liability 48 00:03:15.240 --> 00:03:20.280 company registered in and conducting business in multiple locations, including 49 00:03:20.319 --> 00:03:24.639 New York eleven at all times material here too. Defendant 50 00:03:24.719 --> 00:03:28.840 Maple Incorporated was and is a US Virgin Island corporation 51 00:03:29.120 --> 00:03:33.520 conducting business in New York number twelve. At all times 52 00:03:33.639 --> 00:03:39.199 material here too. Lsje LLC LSJ was and is a 53 00:03:39.319 --> 00:03:43.319 US Virgin Islands corporation conducting business in the United States 54 00:03:43.400 --> 00:03:48.199 Virgin Islands conducting business in New York thirteen at all 55 00:03:48.240 --> 00:03:53.479 times material here too. Defendant HBRK Associates was and is 56 00:03:53.520 --> 00:03:57.960 a domestic business corporation registered in and conducting business and 57 00:03:58.120 --> 00:04:02.000 multiple locations, including New York, with a registered agent located 58 00:04:02.520 --> 00:04:06.639 at thirteen sixty five York Avenue, Apartment twenty eight, New 59 00:04:06.719 --> 00:04:11.919 York fifteen. At all times material here too. Defendant Cypress 60 00:04:11.919 --> 00:04:16.360 Incorporated was and is the US Virgin Islands corporation conducting 61 00:04:16.399 --> 00:04:20.519 business in New York and New Mexico sixteen at all 62 00:04:20.560 --> 00:04:25.240 times material here too. Defendant Jege Incorporated is the US 63 00:04:25.319 --> 00:04:29.800 Virgin Islands corporation conducting business throughout the United States of America, 64 00:04:30.120 --> 00:04:33.519 including but not limited to Florida, New York, and the 65 00:04:33.600 --> 00:04:39.000 Virgin Islands, United States. Seventeen Corporate defendants nine East Laurel 66 00:04:39.120 --> 00:04:46.560 Financial Trust, NES maple Ls, je HBRK, Jege, Nautilus, and Cypress, 67 00:04:46.839 --> 00:04:50.519 referred to as corporate defendants, each performed business in whole 68 00:04:50.680 --> 00:04:54.519 or in part in New York eighteen. Plaintiff intends to 69 00:04:54.560 --> 00:04:58.240 amend this complaint to add or substitute additional parties as 70 00:04:58.319 --> 00:05:03.000 discovery reveals the identity of other tortious corporate or individual 71 00:05:03.040 --> 00:05:07.279 actors nineteen. Epstein, the leader of a complex commercial sex 72 00:05:07.319 --> 00:05:11.879 trafficking and abuse ring, was an officer, director, or employee 73 00:05:12.000 --> 00:05:15.639 of many corporate entities registered in various states throughout the 74 00:05:15.720 --> 00:05:18.920 United States, one or more of which may also be 75 00:05:19.040 --> 00:05:22.639 legally responsible for the crimes and torts he committed against 76 00:05:22.720 --> 00:05:28.879 young females, including Plaintiff twenty Additionally, individuals who worked at 77 00:05:28.920 --> 00:05:32.680 the residences where sexual crime acts were committed, or friends 78 00:05:32.720 --> 00:05:36.959 or acquaintances who assisted Epstein in committing such violations, or 79 00:05:37.000 --> 00:05:40.720 those of his wealthy, famous, or socially powerful friends with 80 00:05:40.759 --> 00:05:44.279 whom Epstein caused Plaintiff to be sexually abused by, or 81 00:05:44.360 --> 00:05:47.839 those who were employed, through, or worked for numerous other 82 00:05:47.879 --> 00:05:52.279 corporate entities whose participation caused or contributed to causing the 83 00:05:52.319 --> 00:05:56.399 sexual violations that caused arm to plaintiff may additionally be 84 00:05:56.439 --> 00:06:01.639 added as defendants twenty one. A substantial part of the acts, events, 85 00:06:01.680 --> 00:06:04.879 and omissions giving rise to this cause of action occurred 86 00:06:04.879 --> 00:06:07.879 in the Southern District of New York. Venue is proper 87 00:06:07.920 --> 00:06:11.720 in this district according to US Code twenty eight thirteen 88 00:06:11.800 --> 00:06:15.879 ninety one B two twenty two. At all times material 89 00:06:15.959 --> 00:06:19.600 to this cause of action Epstein legally represented now through 90 00:06:19.680 --> 00:06:23.160 Darren k Endyke and Richard D. Con as joint personal 91 00:06:23.199 --> 00:06:27.120 representatives of the Estate of Jeffrey e Epstein, referred to 92 00:06:27.199 --> 00:06:30.600 herein as a state of Jeffrey e Epstein and corporate 93 00:06:30.600 --> 00:06:33.800 defendants owe a duty to plaintiff to treat her in 94 00:06:33.839 --> 00:06:36.920 a non negligent manner and not to commit or conspire 95 00:06:37.000 --> 00:06:40.560 to commit, or cause to be committed intentional, criminal, fraudulent, 96 00:06:40.959 --> 00:06:44.680 or tortious acts against plaintiff, including any acts that would 97 00:06:44.680 --> 00:06:48.560 cause plaintiff to be harmed through conduct committed against her 98 00:06:48.560 --> 00:06:51.959 in violation of common law battery New York Penal Code 99 00:06:52.160 --> 00:06:55.480 Section one thirty dot twenty or New York Penal Law 100 00:06:55.680 --> 00:06:58.800 Section one thirty dot thirty five or New York Penal 101 00:06:58.879 --> 00:07:02.279 Law Section three thirty dot five zero or New York 102 00:07:02.319 --> 00:07:05.519 Penal Law one thirty dot five to two or New 103 00:07:05.600 --> 00:07:09.560 York Penal Law one thirty dot sixty six, any violation 104 00:07:09.680 --> 00:07:13.199 of US Code eighteen, Section fifteen ninety one or section 105 00:07:13.319 --> 00:07:18.360 fifteen ninety five the factual allegations twenty three at all 106 00:07:18.399 --> 00:07:21.800 times material to this cause of action. Epstein was an 107 00:07:21.839 --> 00:07:25.600 adult male over forty five years old. Epstein was a 108 00:07:25.680 --> 00:07:30.120 tremendously wealthy individual widely recognized as a billionaire, who used 109 00:07:30.120 --> 00:07:34.279 his wealth, power, resources, and connections to commit illlegal sexual 110 00:07:34.319 --> 00:07:38.000 crimes in violation of federal and state laws, and who 111 00:07:38.040 --> 00:07:42.360 employed or conspired with other individuals and corporate entities to 112 00:07:42.439 --> 00:07:45.800 assist them in committing those crimes or torts, or who 113 00:07:45.839 --> 00:07:50.720 facilitated or enabled those acts to occur. Twenty four. Epstein 114 00:07:50.759 --> 00:07:54.279 displayed enormous wealth power and influence to his employees, to 115 00:07:54.360 --> 00:07:58.040 the employees of the corporate or company entities who worked 116 00:07:58.040 --> 00:08:01.879 at his direction, to the victims pro cured for sexual purposes, 117 00:08:02.120 --> 00:08:04.879 and to the public in order to advance, carry out, 118 00:08:05.120 --> 00:08:09.360 and conceal his crimes and torts twenty five. At all 119 00:08:09.399 --> 00:08:12.959 relevant times, Epstein had access to numerous mansions, as well 120 00:08:13.000 --> 00:08:16.279 as a fleet of airplanes, motor vehicles, boats, and one 121 00:08:16.360 --> 00:08:20.959 or more helicopters. For example, he regularly traveled by private 122 00:08:21.040 --> 00:08:24.800 jet aboard a Boeing Aircraft of making model B seven 123 00:08:24.839 --> 00:08:27.759 twenty seven thirty one H with a tail number of 124 00:08:28.600 --> 00:08:32.559 N nine zero eight JE or a Gulfstream Jet of 125 00:08:32.679 --> 00:08:37.200 making model G eleven five nine B with tail number 126 00:08:37.799 --> 00:08:42.600 N nine oh nine JE. Twenty six. Epstein also inhabited 127 00:08:42.639 --> 00:08:46.519 and frequently traveled between numerous properties and homes, each of 128 00:08:46.559 --> 00:08:49.360 which he admitted to being owned or controlled by them, 129 00:08:49.799 --> 00:08:53.000 including a Manhattan town home located at nine e seventy 130 00:08:53.039 --> 00:08:57.120 first Street, New York, valued conservatively by Epstein's own admission 131 00:08:57.440 --> 00:09:00.639 at fifty five million, nine hundred and thirty one thousand dollars, 132 00:09:00.960 --> 00:09:04.080 but valued by the US Attorney's Office for this district 133 00:09:04.320 --> 00:09:08.080 at seventy seven million. A ranch located at forty nine 134 00:09:08.159 --> 00:09:12.039 Zoro Ranch Road in Stanley, New Mexico, valued conservatively by 135 00:09:12.120 --> 00:09:15.480 Epstein's own admission at seventeen million, two hundred and forty 136 00:09:15.519 --> 00:09:19.320 six thousand, two hundred and eight dollars. Home located at 137 00:09:19.360 --> 00:09:23.279 three fifty eight lbri O Way, Palm Beach, Florida, valued 138 00:09:23.320 --> 00:09:27.159 conservatively by Epstein's own admission at twelve million, three hundred 139 00:09:27.159 --> 00:09:30.120 and eighty thousand, two hundred and nine dollars. An apartment 140 00:09:30.159 --> 00:09:34.519 located at twenty two Avenue Foch, Paris, France, valued conservatively 141 00:09:34.559 --> 00:09:37.600 by Epstein's own admission at eight million, six hundred and 142 00:09:37.600 --> 00:09:40.960 seventy two thousand, eight hundred and twenty dollars. An island 143 00:09:40.960 --> 00:09:44.919 located at Great Saint James Island number six A USVII 144 00:09:45.200 --> 00:09:48.279 zero zero eight zero two parcels A, B and C, 145 00:09:48.840 --> 00:09:52.240 and An Island, Little Saint James Island number six B 146 00:09:52.480 --> 00:09:56.159 USVII zero zero eight zero two parcels A, B and C. 147 00:09:56.799 --> 00:10:00.559 See Jeffrey Epstein Asset Summary June thirtieth, two thousand, nineteen, 148 00:10:00.960 --> 00:10:05.360 filed in Case number one nineteen dash cr DASH zero 149 00:10:05.519 --> 00:10:09.159 zero four to nine zero dash RMB on July fifteenth, 150 00:10:09.360 --> 00:10:14.799 twenty nineteen twenty seven. Epstein controlled or was affiliated with 151 00:10:14.919 --> 00:10:19.320 the corporation or business entities that owned, managed, or maintained 152 00:10:19.600 --> 00:10:22.879 each of the real properties listed in the preceding paragraph 153 00:10:22.960 --> 00:10:27.200 and numerated in Exhibit A twenty eight. The allegations here 154 00:10:27.240 --> 00:10:31.320 in concerned Epstein's tortious conduct committed against plaintiff while that 155 00:10:31.440 --> 00:10:34.840 the residence is owned by defendant nine East, New York, 156 00:10:35.039 --> 00:10:39.000 defendant Laurel in Florida, Defendant Cyprus in New Mexico, and 157 00:10:39.080 --> 00:10:44.039 defendant's LSJE and Nautilus in the US Virgin Islands. Many 158 00:10:44.080 --> 00:10:48.759 such acts were facilitated by defendant nes or, defendant HBRK 159 00:10:49.320 --> 00:10:54.759 or defendant JEGE twenty nine. Epstein had a compulsive sexual 160 00:10:54.840 --> 00:10:58.120 preference for young females as young as fourteen years old, 161 00:10:58.440 --> 00:11:02.279 and acted on that sexual preference for decades. Thirty Epstein 162 00:11:02.360 --> 00:11:06.399 enjoyed sexual contact with young females, including minor children, and 163 00:11:06.480 --> 00:11:10.720 also took pleasure corrupting vulnerable and innocent young females, including 164 00:11:10.759 --> 00:11:15.240 minor children, into engaging in sexual acts with them. Thirty one. 165 00:11:15.279 --> 00:11:19.519 Epstein directed a complex system of individuals, including employees and 166 00:11:19.639 --> 00:11:23.120 associates of defendants entities, to work in concert and that 167 00:11:23.240 --> 00:11:26.600 is direction, for the purpose of harming young females through 168 00:11:26.639 --> 00:11:31.360 sexual exploitation, abuse, and trafficking. Thirty two. It was widely 169 00:11:31.399 --> 00:11:35.679 known among individuals regularly in Epstein's presence that he obtained 170 00:11:35.679 --> 00:11:40.240 pleasure from corrupting and inducing vulnerable young girls into engaging 171 00:11:40.360 --> 00:11:44.720 into uncomfortable and unwanted sexual acts for his own gratification. 172 00:11:45.440 --> 00:11:49.840 Thirty three. Epstein's illegal sexual activities were investigated by law 173 00:11:49.960 --> 00:11:53.080 enforcement on at least two occasions, once in two thousand 174 00:11:53.080 --> 00:11:55.919 and five and two thousand and eight by the United 175 00:11:55.960 --> 00:11:59.039 States Attorney for the Southern District of Florida and more 176 00:11:59.080 --> 00:12:01.679 recently by the United Nited States Attorney for the Southern 177 00:12:01.679 --> 00:12:06.240 District of New York. Thirty four. On July sewo twenty nineteen, 178 00:12:06.440 --> 00:12:09.159 the United States Attorney's Office for the Southern District of 179 00:12:09.320 --> 00:12:12.639 New York filed a sealed two count indictment, including one 180 00:12:12.639 --> 00:12:15.759 count of sex trafficking conspiracy and one count of sex 181 00:12:15.799 --> 00:12:19.960 trafficking for violations of US Code eighteen fifteen ninety one, 182 00:12:20.240 --> 00:12:23.879 in part due to Epstein's criminal activities against children in 183 00:12:23.919 --> 00:12:27.559 the New York mansion located at ninety seventy first Street 184 00:12:27.840 --> 00:12:30.960 thirty five. In addition to the allegations in the criminal 185 00:12:31.000 --> 00:12:35.399 indictment referenced above, Epstein also utilized a similar, if not 186 00:12:35.480 --> 00:12:39.000 the same scheme many years before the time period that 187 00:12:39.120 --> 00:12:41.879 was charged and many years after, as well as an 188 00:12:41.919 --> 00:12:48.000 additional location. Nationally and internationally, thirty six corporate defendants enabled 189 00:12:48.000 --> 00:12:52.159 Epstein to receive daily massages from young females, often miners, 190 00:12:52.320 --> 00:12:56.039 who were not experienced in massage. Rather than receive regular 191 00:12:56.080 --> 00:13:00.720 body massages, Epstein was predictably sexually abusing a young females, 192 00:13:01.000 --> 00:13:04.639 including plaintiff, in violation of New York Penal Code one 193 00:13:04.639 --> 00:13:08.840 point thirty thirty seven. Additionally, employees of the various corporate 194 00:13:08.879 --> 00:13:12.960 defendants performed actions or failed to perform actions that further 195 00:13:13.000 --> 00:13:16.799 places victims, including plaintiff in danger of being sexually abused 196 00:13:16.840 --> 00:13:20.399 by Epstein and assisted in the concealment of his sexually 197 00:13:20.440 --> 00:13:25.000 abusive acts. Thirty eight defendants employed many recruiters of young 198 00:13:25.039 --> 00:13:28.840 females or directed employees of his related companies to recruit 199 00:13:28.879 --> 00:13:32.600 young females in order to grow the enterprise and satisfy 200 00:13:33.000 --> 00:13:37.000 his insatiable sexual desire. Epstein and those working at his 201 00:13:37.080 --> 00:13:41.399 direction enabled victims themselves to elevate their status within the 202 00:13:41.519 --> 00:13:44.639 enterprise to that of a paid recruiter of other victims, 203 00:13:44.840 --> 00:13:48.799 an elevation only made possible through the assistance of defendants. 204 00:13:49.120 --> 00:13:52.799 Thirty nine recruiters were taught by Epstein or by employees 205 00:13:52.840 --> 00:13:57.159 of corporate defendants to inform target young females that Epstein 206 00:13:57.240 --> 00:14:01.480 possessed extraordinary wealth, power, resources, and influence, that he was 207 00:14:01.519 --> 00:14:05.039 a philanthropist who would help female victims advance her education, 208 00:14:05.279 --> 00:14:08.480 careers and lives, and that she only needed to provide 209 00:14:08.480 --> 00:14:12.639 Epstein with body massages in order to avail herself of 210 00:14:12.679 --> 00:14:18.440 his nearly unlimited assistance and influence. Forty Epstein and corporate 211 00:14:18.440 --> 00:14:22.519 defendants and their many employees fulfilled Epstein's compulsive need for 212 00:14:22.600 --> 00:14:27.000 sex with young females by praying on their personal, psychological, financial, 213 00:14:27.320 --> 00:14:31.840 and related vulnerabilities. Epstein and defendants tactics included promising the 214 00:14:31.879 --> 00:14:38.240 victim's money, shelter, transportation, gifts, employment, admission into educational institutions, 215 00:14:39.240 --> 00:14:43.759 professional licensure, protection, health care, and other things of value. 216 00:14:43.919 --> 00:14:48.360 Forty one. Epstein's sexual attraction to young, often underage females 217 00:14:48.720 --> 00:14:51.080 dated back to at least the mid nineties, and the 218 00:14:51.159 --> 00:14:55.080 number of victims increased substantially with the necessary assistance from 219 00:14:55.080 --> 00:14:59.559 the defendants and the defendants employees. Forty two. Defendants, at 220 00:14:59.559 --> 00:15:03.600 the direction of Epstein or in furtherance of his demands 221 00:15:03.639 --> 00:15:07.039 and with help from assistance associates and underlings and even 222 00:15:07.080 --> 00:15:11.039 other victims, recruited or procured dozens, if not hundreds of 223 00:15:11.080 --> 00:15:15.440 young females, including miners, for the purpose of Epstein's sexual gratification. 224 00:15:15.879 --> 00:15:20.600 Forty three. Epstein and employees of certain corporate defendants, including 225 00:15:20.639 --> 00:15:26.519 at least defendant HBRK, specifically targeted underprivileged, emotionally vulnerable, and 226 00:15:26.759 --> 00:15:31.240 or economically disadvantage young females to sexually molest and abuse 227 00:15:31.720 --> 00:15:36.600 forty four. Additionally, Epstein and corporate defendants, through employees inform 228 00:15:36.679 --> 00:15:40.600 young females, including plaintiff, that Epstein was wealthy, well connected, 229 00:15:40.799 --> 00:15:43.759 and had the power and ability to impact her life 230 00:15:43.960 --> 00:15:47.639 of any young female recruited or obtained to provide a massage. 231 00:15:47.799 --> 00:15:51.320 Forty five each of the corporate defendants committed acts of 232 00:15:51.360 --> 00:15:54.440 negligence that allowed for Epstein to commit acts of violation 233 00:15:54.879 --> 00:15:58.360 of New York Penal Law Section one thirty forty six 234 00:15:58.960 --> 00:16:02.320 each of the defendants emitted acts against plaintiff in violation 235 00:16:02.440 --> 00:16:06.480 of US Code eighteen, fifteen ninety one and fifteen ninety five. 236 00:16:07.159 --> 00:16:09.480 All right, folks, we're gonna wrap up part one here 237 00:16:09.759 --> 00:16:11.840 and we're gonna pick up in the next episode with 238 00:16:12.000 --> 00:16:15.039 Part two. All of the information that goes with this 239 00:16:15.120 --> 00:16:19.480 episode can be found in the description box. What's up everyone, 240 00:16:19.559 --> 00:16:24.080 and welcome back to the Epstein chronicles. In this episode, 241 00:16:24.080 --> 00:16:27.080 we're gonna pick up where we left off with Jane 242 00:16:27.080 --> 00:16:33.120 Doe number seventeen forty seven. Consistent with Epstein's foregoing plan 243 00:16:33.440 --> 00:16:37.600 scheme Enterprise, the plaintiff was recruited to provide Epstein with 244 00:16:37.720 --> 00:16:43.039 massages for monetary compensation. These massages provided to Abstein by 245 00:16:43.039 --> 00:16:47.639 a plaintiff progressed to instances of inappropriate sexual contact with 246 00:16:47.759 --> 00:16:52.840 a plaintiff by Epstein in touching, inappropriate vaginal penetration and 247 00:16:52.879 --> 00:16:59.440 outright rape. Plaintiff was sexually assaulted, violated, and otherwise degraded, injured, victimized, 248 00:16:59.639 --> 00:17:04.799 and sub rejected to outrageous, reckless abuse and insult forty eight. 249 00:17:05.240 --> 00:17:10.400 In this regard, the defendants willingly participated, contributed, cooperated, and 250 00:17:10.519 --> 00:17:14.720 assisted the inappropriate and the legal scheme by facilitating such 251 00:17:14.759 --> 00:17:18.319 scheme by and through the employees of the corporate defendant, 252 00:17:18.599 --> 00:17:22.400 such as the corporate defendants were acting jointly and in 253 00:17:22.480 --> 00:17:25.319 concert with the illegal scheme, with the goal designed to 254 00:17:25.359 --> 00:17:30.000 produce corrupt sexual gratification for Epstein and degradation for the 255 00:17:30.000 --> 00:17:33.079 targets and victims of the corrupt scheme set in motion 256 00:17:33.440 --> 00:17:36.319 with the active involvement of the corporate defendants and their 257 00:17:36.319 --> 00:17:41.079 employees forty nine. Epstein's abuse of plaintiff was not incidental 258 00:17:41.240 --> 00:17:44.799 or fleeting, but rather was borne out of a pathological 259 00:17:44.839 --> 00:17:50.200 desire to achieve corrupt and deviate sexual gratification through the 260 00:17:50.279 --> 00:17:54.720 subjugation and abuse of Epstein's targeted victims. The actions on 261 00:17:54.759 --> 00:17:58.920 behalf of the corporate defendants buy and through its employees, enhanced, 262 00:17:59.000 --> 00:18:03.400 facilitated and promoted the deviate sexual acts of Epstein and 263 00:18:03.519 --> 00:18:08.480 contributed a corrupting influence which ensnared unsuspecting women and girls 264 00:18:08.680 --> 00:18:13.400 in its reach. Fifty Epstein, by acting singularly and in 265 00:18:13.480 --> 00:18:17.519 concert with the corporate defendants, devised a sophisticated plan and 266 00:18:17.640 --> 00:18:22.960 modus operandi which subtly and pervasively over time, connived to 267 00:18:23.079 --> 00:18:26.880 influence the victims and subjects of the corrupt and deviant 268 00:18:26.920 --> 00:18:30.759 sexual scheme, to influence the will to resist the temptations 269 00:18:30.799 --> 00:18:34.319 both actual and promised on behalf of the scheme, and 270 00:18:34.400 --> 00:18:38.240 thereby manipulate the victims into acceptance of the scheme as 271 00:18:38.319 --> 00:18:41.960 being one that was acceptable and appropriate. By virtue of 272 00:18:42.079 --> 00:18:46.799 communications and representations made on behalf of Abstein by the 273 00:18:46.799 --> 00:18:51.079 corporate defendants and in fact Epstein himself, the scheme utilized 274 00:18:51.119 --> 00:18:54.160 a gradual wearing down of the victim's will to resist, 275 00:18:54.400 --> 00:18:57.599 and did so by virtue of offering positive and negative 276 00:18:57.640 --> 00:19:02.599 rewards for compliance with the schemes overall deviant methodology and 277 00:19:02.720 --> 00:19:07.839 goals fifty one. Once Epstein and the corporate defendants, victims 278 00:19:07.839 --> 00:19:12.079 were entrapped and the scheme's methodologies enabled, Epstein and the 279 00:19:12.079 --> 00:19:17.240 corporate defendants through the employees utilized techniques to further inhibit, indoctrinate, 280 00:19:17.519 --> 00:19:21.400 and threaten Epstein's victims such that compliance with the deviant 281 00:19:21.400 --> 00:19:26.480 scheme's goals could further be obtained. Fifty two. The deviant 282 00:19:26.480 --> 00:19:29.799 scheme was perpetrated over years by the actions of Epstein 283 00:19:30.119 --> 00:19:33.319 and the corporate defendants, such that victims were caught up 284 00:19:33.319 --> 00:19:37.880 in the scheme. Pressure, threats, and indoctrination techniques utilized to 285 00:19:37.960 --> 00:19:42.039 bring the victims to heal fifty three. For victims young, vulnerable, 286 00:19:42.079 --> 00:19:47.880 and struggling financially, the scheme's methodology was particularly effective fifty four. 287 00:19:48.559 --> 00:19:52.200 As part and parcel of the scheme's goals, Epstein's colleagues 288 00:19:52.240 --> 00:19:55.839 and acquaintances were involved in the scheme and benefited from 289 00:19:55.839 --> 00:20:00.839 the scheme by virtue of receiving sexual favors and inappropriate, illegal, 290 00:20:01.079 --> 00:20:05.839 and otherwise commercial sexual services provided by Epstein's victims, such 291 00:20:05.920 --> 00:20:09.519 that the corrupt intent of this scheme involved males other 292 00:20:09.559 --> 00:20:12.599 than Epstein himself. So is anyone going to get arrested 293 00:20:12.880 --> 00:20:14.279 or are we going to talk about the flight logs 294 00:20:14.279 --> 00:20:17.480 a little bit more? As a direct and proximate result 295 00:20:17.559 --> 00:20:20.839 of the methodology of the deviant scheme and the goals 296 00:20:20.880 --> 00:20:25.240 of sexual exploitation of the women recruited and victimized plaintiff 297 00:20:25.279 --> 00:20:28.640 with subject to unwonted touching of her breasts and genitals 298 00:20:28.960 --> 00:20:32.319 other sensitive areas of her body, required to perform acts 299 00:20:32.319 --> 00:20:35.680 of a sexual nature against her will and subjected to 300 00:20:35.759 --> 00:20:41.359 genital penetration, and otherwise sexually degraded, abused, insulted, coerced, and 301 00:20:41.480 --> 00:20:48.839 injured experience, resulting in confusion, emotional distress, mental pain and suffering, shame, humiliation, 302 00:20:49.279 --> 00:20:52.839 loss of the enjoyment of life, inconvenience, and other injuries 303 00:20:52.880 --> 00:20:57.559 to body, mind, and soul. Fifty five. Epstein and the 304 00:20:57.599 --> 00:21:01.759 corporate defendants buy And, through their employees and agents, substantially 305 00:21:01.799 --> 00:21:06.640 contributed to proximately cause injury to the plaintiff as aforementioned 306 00:21:07.039 --> 00:21:10.440 fifty six. Over the course of years, Epstein and the 307 00:21:10.480 --> 00:21:14.839 corporate defendants buy And, through its employees and agents, facilitated 308 00:21:14.880 --> 00:21:17.759 the multiple rapes conducted on the plaintiff, in addition to 309 00:21:17.839 --> 00:21:21.720 other deviant sexual acts against her will. Furthermore, the Plaintiff's 310 00:21:21.759 --> 00:21:27.039 virginity was forcefully taken from her against her will. Fifty seven. 311 00:21:27.200 --> 00:21:30.720 This fraudulent scheme of Epstein's constituted acts of coercion from 312 00:21:30.720 --> 00:21:33.680 beginning to end from two thousand and one through mid 313 00:21:33.680 --> 00:21:37.160 two thousand and six, inasmuch as the scheme was designed 314 00:21:37.240 --> 00:21:40.200 to end, in fact caused plaintiff to believe that her 315 00:21:40.279 --> 00:21:44.240 failure to perform any sex act required by Epstein would 316 00:21:44.319 --> 00:21:49.000 result in serious financial, reputational, physical and emotional harm. Tour 317 00:21:50.160 --> 00:21:53.359 count one battery against Darren ky Endyke and Richard D. 318 00:21:53.480 --> 00:21:58.000 Coon as joint personal representatives of the estate of Jeffrey Epstein, 319 00:21:58.480 --> 00:22:02.039 fifty eight. The plaintiff adopts and re alleges paragraphs one 320 00:22:02.240 --> 00:22:06.319 through fifty seven above fifty nine, Epstein committed a harmful 321 00:22:06.559 --> 00:22:10.480 or offensive touching against plaintiff sixty As a direct and 322 00:22:10.599 --> 00:22:14.000 proximate result of Epstein's battery, the plaintiff has in the 323 00:22:14.079 --> 00:22:17.039 past suffered and in the future will continue to suffer 324 00:22:17.319 --> 00:22:24.160 physical injury, pain, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, 325 00:22:24.559 --> 00:22:28.200 loss of self esteem, loss of dignity, invasion of her privacy, 326 00:22:28.400 --> 00:22:31.279 and the loss of her capacity to enjoy life, as 327 00:22:31.319 --> 00:22:36.119 well as other damages. Plaintiff incurred medical and psychological expenses, 328 00:22:36.319 --> 00:22:39.440 and plaintiff will in the future suffer additional medical and 329 00:22:39.519 --> 00:22:44.319 psychological expenses. These injuries are permanent in nature, and plaintiff 330 00:22:44.359 --> 00:22:48.079 will continue to suffer these losses in the future. Wherefore, 331 00:22:48.160 --> 00:22:52.440 Plaintiff demands judgment against the Estate of Jeffrey E. Epstein 332 00:22:52.720 --> 00:22:57.480 for compensentory in general damages, attorney fees, punitive damages, and 333 00:22:57.640 --> 00:23:01.599 other and further relief. As this Court deems just and proper. 334 00:23:02.000 --> 00:23:05.960 Plaintiff hereby demands trial by jury on all issues triable 335 00:23:06.279 --> 00:23:10.720 as the right by a jury. Count two battery violation 336 00:23:10.839 --> 00:23:14.079 of Section one thirty against Darren kay Endyke and Richard D. 337 00:23:14.240 --> 00:23:18.559 Con as joint personal representatives of the Estate of Jeffrey Epstein, 338 00:23:19.000 --> 00:23:23.119 sixty one. The plaintiff adopts and re alleges Paragraphs one 339 00:23:23.160 --> 00:23:26.720 through fifty seven above sixty two. The intentional acts of 340 00:23:26.720 --> 00:23:31.240 Epstein against plaintiff constitute a sexual offense as defined in 341 00:23:31.319 --> 00:23:34.720 New York Penal Law Section one thirty, including but not 342 00:23:34.799 --> 00:23:39.319 limited to the following. A sexual misconduct is defined in 343 00:23:39.400 --> 00:23:43.160 section one thirty dot twenty. Inasmuch as Epstein engaged in 344 00:23:43.240 --> 00:23:48.000 sexual intercourse with plaintiff without Plaintiff's consent. B Rape in 345 00:23:48.039 --> 00:23:51.039 the first degree is defined in Section one thirty dot 346 00:23:51.160 --> 00:23:55.160 thirty five inasmuch as Epstein engaged in sexual intercourse with 347 00:23:55.240 --> 00:23:59.720 plaintiff by forcible compulsion see criminal sexual act in the 348 00:23:59.759 --> 00:24:03.680 first degree as defined in section one thirty dot five zero, 349 00:24:04.039 --> 00:24:07.960 inasmuch as Epstein engaged in oral sexual conduct with plaintiff 350 00:24:08.200 --> 00:24:13.119 by forcible compulsion d Forcible touching has defined in section 351 00:24:13.160 --> 00:24:17.359 one thirty dot fifty two, inasmuch as Epstein intentionally and 352 00:24:17.480 --> 00:24:21.920 for no legitimate purpose, engage the forcible sexual touching of 353 00:24:21.960 --> 00:24:25.599 plaintiff for the purpose of degrading or abusing her, or 354 00:24:25.640 --> 00:24:29.680 for the purpose of gratifying his own sexual desire n E. 355 00:24:30.400 --> 00:24:34.200 Aggravated sexual abuse in the third degree as defined in 356 00:24:34.240 --> 00:24:37.799 section one thirty dot sixty six, inasmuch as Epstein and 357 00:24:37.880 --> 00:24:41.240 started a foreign object in the vagina of plaintiff by 358 00:24:41.359 --> 00:24:46.319 forcible compulsion sixty three. As a direct and proximate result 359 00:24:46.359 --> 00:24:49.960 of Epstein's violations of New York Penal Law Section one thirty, 360 00:24:50.279 --> 00:24:53.240 plaintiff has in the past suffered, and in the future 361 00:24:53.279 --> 00:24:58.400 will continue to suffer physical injury, pain, emotional distress, psychological trauma, 362 00:24:58.680 --> 00:25:03.759 mental anguish, humiliate embarrassment, loss of self esteem, loss of dignity, 363 00:25:03.920 --> 00:25:06.720 invasion of her privacy and the loss of her capacity 364 00:25:06.920 --> 00:25:11.000 to enjoy life, as well as other damages. Plaintiff incurred 365 00:25:11.039 --> 00:25:15.039 medical and psychological expenses, and plaintiff in the future will 366 00:25:15.079 --> 00:25:19.960 suffer additional medical and psychological expenses. These injuries are permanent 367 00:25:20.079 --> 00:25:23.279 in nature, and Plaintiff will continue to suffer these losses 368 00:25:23.480 --> 00:25:28.079 in the future. Wherefore, Plaintiff demands judgment against the Estate 369 00:25:28.200 --> 00:25:33.119 of Jeffrey e Epstein for compensantory in general damages, attorney fees, 370 00:25:33.400 --> 00:25:36.839 punitive damages, and such other and further relief as this 371 00:25:36.960 --> 00:25:40.920 Court deems just and proper. Plaintiff hereby demands trial by 372 00:25:41.039 --> 00:25:44.759 jury on all issues triable as a right by a jury. 373 00:25:45.680 --> 00:25:48.839 Count three. Cause of action against Darren ky Endyke and 374 00:25:48.920 --> 00:25:52.359 Richard D. Con as joint personal representatives of the Estate 375 00:25:52.720 --> 00:25:56.920 of Jeffrey e Epstein, pursuanto US Code eighteen, Section fifteen 376 00:25:57.039 --> 00:26:02.119 ninety five, sixty four. Plaintiff adopts and re alleges Paragraphs 377 00:26:02.119 --> 00:26:06.200 one through fifty seven above sixty five. Epstein within the 378 00:26:06.200 --> 00:26:10.880 special maritime and territorial jurisdiction of the United States is 379 00:26:10.960 --> 00:26:15.160 interstate and foreign commerce and or affecting interstate and foreign 380 00:26:15.160 --> 00:26:23.480 commerce knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized, solicited, threatened, forced, 381 00:26:23.680 --> 00:26:27.920 and coerse plaintiff to engage in commercial sex acts sixty six. 382 00:26:28.359 --> 00:26:32.400 Such actions were undertaken knowing that his use of force, 383 00:26:32.640 --> 00:26:36.759 threats of force, fraud, coercion, and or a combination of 384 00:26:36.799 --> 00:26:39.640 such means would be used, and were in fact used 385 00:26:39.759 --> 00:26:43.200 in order to cause plaintiff to engage in commercial sex acts. 386 00:26:43.559 --> 00:26:47.839 In doing so, Epstein violated US Code eighteen, fifteen ninety one, 387 00:26:48.200 --> 00:26:53.000 sixty seven. Furthermore, Epstein attempted to violate US Code eighteen, 388 00:26:53.240 --> 00:26:57.559 section fifteen ninety one. In doing so, violated section eighteen 389 00:26:57.599 --> 00:27:01.680 of US Code fifteen ninety four A. Sixty eight. Epstein 390 00:27:01.759 --> 00:27:04.920 conspired with each member of the enterprise and with other 391 00:27:04.960 --> 00:27:09.000 persons known and unknown, to violate US Code eighteen fifteen 392 00:27:09.119 --> 00:27:13.599 ninety one. In doing so, violated eighteen fifteen ninety four C. 393 00:27:14.400 --> 00:27:18.759 Sixty nine. By virtue of Epstein's violations of US Code eighteen, 394 00:27:19.039 --> 00:27:22.640 section fifteen ninety one, fifteen ninety three A, and fifteen 395 00:27:22.720 --> 00:27:27.240 ninety four, defendants Darren K. Endike and Richard D. Con 396 00:27:27.480 --> 00:27:31.359 as joint personal representatives of the estate of Jeffrey E. 397 00:27:31.359 --> 00:27:35.079 Epstein is subject to civil causes of action under US 398 00:27:35.119 --> 00:27:38.799 Code eighteen, Section fifteen ninety five by plaintiff who is 399 00:27:38.839 --> 00:27:43.640 a victim of the violations seventy Certain property of Epstein's 400 00:27:43.720 --> 00:27:46.640 was essential to the commission of the federal crimes and 401 00:27:46.759 --> 00:27:50.799