Speaker 1: What's up everyone, and welcome back to the Epstein Chronicles.
Speaker 1: In this episode, we're going to hear the allegations from
Speaker 1: Jane Doe number seventeen, and we're going to keep the
Speaker 1: discuss bus rolling. The complaint. Plaintiff Jane Doe seventeen buy
Speaker 1: and through the undersigned Council in support of her claims
Speaker 1: against defendant alleges and states as follows. One, This action
Speaker 1: is brought inter ally a pursuant to common law, statutory law,
Speaker 1: and US Code eighteen section fifteen ninety one and fifteen
Speaker 1: ninety five. Therefore, jurisdiction is proper under US Code twenty
Speaker 1: eight thirteen thirty one, and the damages sought exceed the
Speaker 1: jurisdictional requirements of this Court. Two Plaintiff files this complaint
Speaker 1: under a pseudonym in order to protect her identity, because
Speaker 1: the complaint makes allegations of a sensitive sexual nature, the
Speaker 1: disclosure of which, in association with her name, would further
Speaker 1: cause her harm. Three Plaintiff is currently resident and domiciled
Speaker 1: in the state of Florida and over the age of
Speaker 1: eighteen four. At all times material, Jeffrey Epstein was a
Speaker 1: citizen of the United States and resident of the US
Speaker 1: Virgin Islands. Epstein was a man of extreme wealth who
Speaker 1: frequently traveled between and regularly stayed in his numerous residences,
Speaker 1: including in New York within the Southern District of New
Speaker 1: York at nine East seventy first Street, New York, New York.
Speaker 1: In pom Beach, Florida at three fifty eight l Brio Way,
Speaker 1: pom Beach, Florida, in New Mexico at forty nine Zora
Speaker 1: Ranch Road, Stanley, New Mexico, in Paris, France at twenty
Speaker 1: two Avenue Fought, Paris, France, and in the United States
Speaker 1: Virgin Islands at Little Saint James Island, number five. At
Speaker 1: all times material to this cause of action. Epstein was
Speaker 1: an adult male born on January twentieth, nineteen fifty three,
Speaker 1: who died on August tenth, twenty nineteen six. Defendant Darren
Speaker 1: Ky and Richard D. Con as joint personal representatives of
Speaker 1: the Estate of Jeffrey e Epstein. A State of Jeffrey
Speaker 1: e Epstein was opened and domiciled in the United States
Speaker 1: Virgin Islands, Saint Thomas Division, and is the legal entity
Speaker 1: responsible for intentional, criminal, or tortious conduct committed by Epstein
Speaker 1: as described in this complaint seven. At all times material
Speaker 1: here too. Defendant ninety seventy first Street Corporation was a
Speaker 1: domestic business corporation conducting business in New York, with its
Speaker 1: principal place of business located at five seventy five Lexington,
Speaker 1: fourth Floor, New York eight. At all times material here too.
Speaker 1: Defendant Laurel Incorporated was and is the US Virgin Islands
Speaker 1: corporation conducting business in multiple locations, including New York and
Speaker 1: Florida number nine. At all times material here too. Defendant
Speaker 1: Financial Trust Company Incorporated was and it is the US
Speaker 1: Virgin Islands corporation conducting business in multiple locations, including New
Speaker 1: York number ten. At all times material here too. Defendant
Speaker 1: nes LLC nes was and is a domestic limited liability
Speaker 1: company registered in and conducting business in multiple locations, including
Speaker 1: New York eleven at all times material here too. Defendant
Speaker 1: Maple Incorporated was and is a US Virgin Island corporation
Speaker 1: conducting business in New York number twelve. At all times
Speaker 1: material here too. Lsje LLC LSJ was and is a
Speaker 1: US Virgin Islands corporation conducting business in the United States
Speaker 1: Virgin Islands conducting business in New York thirteen at all
Speaker 1: times material here too. Defendant HBRK Associates was and is
Speaker 1: a domestic business corporation registered in and conducting business and
Speaker 1: multiple locations, including New York, with a registered agent located
Speaker 1: at thirteen sixty five York Avenue, Apartment twenty eight, New
Speaker 1: York fifteen. At all times material here too. Defendant Cypress
Speaker 1: Incorporated was and is the US Virgin Islands corporation conducting
Speaker 1: business in New York and New Mexico sixteen at all
Speaker 1: times material here too. Defendant Jege Incorporated is the US
Speaker 1: Virgin Islands corporation conducting business throughout the United States of America,
Speaker 1: including but not limited to Florida, New York, and the
Speaker 1: Virgin Islands, United States. Seventeen Corporate defendants nine East Laurel
Speaker 1: Financial Trust, NES maple Ls, je HBRK, Jege, Nautilus, and Cypress,
Speaker 1: referred to as corporate defendants, each performed business in whole
Speaker 1: or in part in New York eighteen. Plaintiff intends to
Speaker 1: amend this complaint to add or substitute additional parties as
Speaker 1: discovery reveals the identity of other tortious corporate or individual
Speaker 1: actors nineteen. Epstein, the leader of a complex commercial sex
Speaker 1: trafficking and abuse ring, was an officer, director, or employee
Speaker 1: of many corporate entities registered in various states throughout the
Speaker 1: United States, one or more of which may also be
Speaker 1: legally responsible for the crimes and torts he committed against
Speaker 1: young females, including Plaintiff twenty Additionally, individuals who worked at
Speaker 1: the residences where sexual crime acts were committed, or friends
Speaker 1: or acquaintances who assisted Epstein in committing such violations, or
Speaker 1: those of his wealthy, famous, or socially powerful friends with
Speaker 1: whom Epstein caused Plaintiff to be sexually abused by, or
Speaker 1: those who were employed, through, or worked for numerous other
Speaker 1: corporate entities whose participation caused or contributed to causing the
Speaker 1: sexual violations that caused arm to plaintiff may additionally be
Speaker 1: added as defendants twenty one. A substantial part of the acts, events,
Speaker 1: and omissions giving rise to this cause of action occurred
Speaker 1: in the Southern District of New York. Venue is proper
Speaker 1: in this district according to US Code twenty eight thirteen
Speaker 1: ninety one B two twenty two. At all times material
Speaker 1: to this cause of action Epstein legally represented now through
Speaker 1: Darren k Endyke and Richard D. Con as joint personal
Speaker 1: representatives of the Estate of Jeffrey e Epstein, referred to
Speaker 1: herein as a state of Jeffrey e Epstein and corporate
Speaker 1: defendants owe a duty to plaintiff to treat her in
Speaker 1: a non negligent manner and not to commit or conspire
Speaker 1: to commit, or cause to be committed intentional, criminal, fraudulent,
Speaker 1: or tortious acts against plaintiff, including any acts that would
Speaker 1: cause plaintiff to be harmed through conduct committed against her
Speaker 1: in violation of common law battery New York Penal Code
Speaker 1: Section one thirty dot twenty or New York Penal Law
Speaker 1: Section one thirty dot thirty five or New York Penal
Speaker 1: Law Section three thirty dot five zero or New York
Speaker 1: Penal Law one thirty dot five to two or New
Speaker 1: York Penal Law one thirty dot sixty six, any violation
Speaker 1: of US Code eighteen, Section fifteen ninety one or section
Speaker 1: fifteen ninety five the factual allegations twenty three at all
Speaker 1: times material to this cause of action. Epstein was an
Speaker 1: adult male over forty five years old. Epstein was a
Speaker 1: tremendously wealthy individual widely recognized as a billionaire, who used
Speaker 1: his wealth, power, resources, and connections to commit illlegal sexual
Speaker 1: crimes in violation of federal and state laws, and who
Speaker 1: employed or conspired with other individuals and corporate entities to
Speaker 1: assist them in committing those crimes or torts, or who
Speaker 1: facilitated or enabled those acts to occur. Twenty four. Epstein
Speaker 1: displayed enormous wealth power and influence to his employees, to
Speaker 1: the employees of the corporate or company entities who worked
Speaker 1: at his direction, to the victims pro cured for sexual purposes,
Speaker 1: and to the public in order to advance, carry out,
Speaker 1: and conceal his crimes and torts twenty five. At all
Speaker 1: relevant times, Epstein had access to numerous mansions, as well
Speaker 1: as a fleet of airplanes, motor vehicles, boats, and one
Speaker 1: or more helicopters. For example, he regularly traveled by private
Speaker 1: jet aboard a Boeing Aircraft of making model B seven
Speaker 1: twenty seven thirty one H with a tail number of
Speaker 1: N nine zero eight JE or a Gulfstream Jet of
Speaker 1: making model G eleven five nine B with tail number
Speaker 1: N nine oh nine JE. Twenty six. Epstein also inhabited
Speaker 1: and frequently traveled between numerous properties and homes, each of
Speaker 1: which he admitted to being owned or controlled by them,
Speaker 1: including a Manhattan town home located at nine e seventy
Speaker 1: first Street, New York, valued conservatively by Epstein's own admission
Speaker 1: at fifty five million, nine hundred and thirty one thousand dollars,
Speaker 1: but valued by the US Attorney's Office for this district
Speaker 1: at seventy seven million. A ranch located at forty nine
Speaker 1: Zoro Ranch Road in Stanley, New Mexico, valued conservatively by
Speaker 1: Epstein's own admission at seventeen million, two hundred and forty
Speaker 1: six thousand, two hundred and eight dollars. Home located at
Speaker 1: three fifty eight lbri O Way, Palm Beach, Florida, valued
Speaker 1: conservatively by Epstein's own admission at twelve million, three hundred
Speaker 1: and eighty thousand, two hundred and nine dollars. An apartment
Speaker 1: located at twenty two Avenue Foch, Paris, France, valued conservatively
Speaker 1: by Epstein's own admission at eight million, six hundred and
Speaker 1: seventy two thousand, eight hundred and twenty dollars. An island
Speaker 1: located at Great Saint James Island number six A USVII
Speaker 1: zero zero eight zero two parcels A, B and C,
Speaker 1: and An Island, Little Saint James Island number six B
Speaker 1: USVII zero zero eight zero two parcels A, B and C.
Speaker 1: See Jeffrey Epstein Asset Summary June thirtieth, two thousand, nineteen,
Speaker 1: filed in Case number one nineteen dash cr DASH zero
Speaker 1: zero four to nine zero dash RMB on July fifteenth,
Speaker 1: twenty nineteen twenty seven. Epstein controlled or was affiliated with
Speaker 1: the corporation or business entities that owned, managed, or maintained
Speaker 1: each of the real properties listed in the preceding paragraph
Speaker 1: and numerated in Exhibit A twenty eight. The allegations here
Speaker 1: in concerned Epstein's tortious conduct committed against plaintiff while that
Speaker 1: the residence is owned by defendant nine East, New York,
Speaker 1: defendant Laurel in Florida, Defendant Cyprus in New Mexico, and
Speaker 1: defendant's LSJE and Nautilus in the US Virgin Islands. Many
Speaker 1: such acts were facilitated by defendant nes or, defendant HBRK
Speaker 1: or defendant JEGE twenty nine. Epstein had a compulsive sexual
Speaker 1: preference for young females as young as fourteen years old,
Speaker 1: and acted on that sexual preference for decades. Thirty Epstein
Speaker 1: enjoyed sexual contact with young females, including minor children, and
Speaker 1: also took pleasure corrupting vulnerable and innocent young females, including
Speaker 1: minor children, into engaging in sexual acts with them. Thirty one.
Speaker 1: Epstein directed a complex system of individuals, including employees and
Speaker 1: associates of defendants entities, to work in concert and that
Speaker 1: is direction, for the purpose of harming young females through
Speaker 1: sexual exploitation, abuse, and trafficking. Thirty two. It was widely
Speaker 1: known among individuals regularly in Epstein's presence that he obtained
Speaker 1: pleasure from corrupting and inducing vulnerable young girls into engaging
Speaker 1: into uncomfortable and unwanted sexual acts for his own gratification.
Speaker 1: Thirty three. Epstein's illegal sexual activities were investigated by law
Speaker 1: enforcement on at least two occasions, once in two thousand
Speaker 1: and five and two thousand and eight by the United
Speaker 1: States Attorney for the Southern District of Florida and more
Speaker 1: recently by the United Nited States Attorney for the Southern
Speaker 1: District of New York. Thirty four. On July sewo twenty nineteen,
Speaker 1: the United States Attorney's Office for the Southern District of
Speaker 1: New York filed a sealed two count indictment, including one
Speaker 1: count of sex trafficking conspiracy and one count of sex
Speaker 1: trafficking for violations of US Code eighteen fifteen ninety one,
Speaker 1: in part due to Epstein's criminal activities against children in
Speaker 1: the New York mansion located at ninety seventy first Street
Speaker 1: thirty five. In addition to the allegations in the criminal
Speaker 1: indictment referenced above, Epstein also utilized a similar, if not
Speaker 1: the same scheme many years before the time period that
Speaker 1: was charged and many years after, as well as an
Speaker 1: additional location. Nationally and internationally, thirty six corporate defendants enabled
Speaker 1: Epstein to receive daily massages from young females, often miners,
Speaker 1: who were not experienced in massage. Rather than receive regular
Speaker 1: body massages, Epstein was predictably sexually abusing a young females,
Speaker 1: including plaintiff, in violation of New York Penal Code one
Speaker 1: point thirty thirty seven. Additionally, employees of the various corporate
Speaker 1: defendants performed actions or failed to perform actions that further
Speaker 1: places victims, including plaintiff in danger of being sexually abused
Speaker 1: by Epstein and assisted in the concealment of his sexually
Speaker 1: abusive acts. Thirty eight defendants employed many recruiters of young
Speaker 1: females or directed employees of his related companies to recruit
Speaker 1: young females in order to grow the enterprise and satisfy
Speaker 1: his insatiable sexual desire. Epstein and those working at his
Speaker 1: direction enabled victims themselves to elevate their status within the
Speaker 1: enterprise to that of a paid recruiter of other victims,
Speaker 1: an elevation only made possible through the assistance of defendants.
Speaker 1: Thirty nine recruiters were taught by Epstein or by employees
Speaker 1: of corporate defendants to inform target young females that Epstein
Speaker 1: possessed extraordinary wealth, power, resources, and influence, that he was
Speaker 1: a philanthropist who would help female victims advance her education,
Speaker 1: careers and lives, and that she only needed to provide
Speaker 1: Epstein with body massages in order to avail herself of
Speaker 1: his nearly unlimited assistance and influence. Forty Epstein and corporate
Speaker 1: defendants and their many employees fulfilled Epstein's compulsive need for
Speaker 1: sex with young females by praying on their personal, psychological, financial,
Speaker 1: and related vulnerabilities. Epstein and defendants tactics included promising the
Speaker 1: victim's money, shelter, transportation, gifts, employment, admission into educational institutions,
Speaker 1: professional licensure, protection, health care, and other things of value.
Speaker 1: Forty one. Epstein's sexual attraction to young, often underage females
Speaker 1: dated back to at least the mid nineties, and the
Speaker 1: number of victims increased substantially with the necessary assistance from
Speaker 1: the defendants and the defendants employees. Forty two. Defendants, at
Speaker 1: the direction of Epstein or in furtherance of his demands
Speaker 1: and with help from assistance associates and underlings and even
Speaker 1: other victims, recruited or procured dozens, if not hundreds of
Speaker 1: young females, including miners, for the purpose of Epstein's sexual gratification.
Speaker 1: Forty three. Epstein and employees of certain corporate defendants, including
Speaker 1: at least defendant HBRK, specifically targeted underprivileged, emotionally vulnerable, and
Speaker 1: or economically disadvantage young females to sexually molest and abuse
Speaker 1: forty four. Additionally, Epstein and corporate defendants, through employees inform
Speaker 1: young females, including plaintiff, that Epstein was wealthy, well connected,
Speaker 1: and had the power and ability to impact her life
Speaker 1: of any young female recruited or obtained to provide a massage.
Speaker 1: Forty five each of the corporate defendants committed acts of
Speaker 1: negligence that allowed for Epstein to commit acts of violation
Speaker 1: of New York Penal Law Section one thirty forty six
Speaker 1: each of the defendants emitted acts against plaintiff in violation
Speaker 1: of US Code eighteen, fifteen ninety one and fifteen ninety five.
Speaker 1: All right, folks, we're gonna wrap up part one here
Speaker 1: and we're gonna pick up in the next episode with
Speaker 1: Part two. All of the information that goes with this
Speaker 1: episode can be found in the description box. What's up everyone,
Speaker 1: and welcome back to the Epstein chronicles. In this episode,
Speaker 1: we're gonna pick up where we left off with Jane
Speaker 1: Doe number seventeen forty seven. Consistent with Epstein's foregoing plan
Speaker 1: scheme Enterprise, the plaintiff was recruited to provide Epstein with
Speaker 1: massages for monetary compensation. These massages provided to Abstein by
Speaker 1: a plaintiff progressed to instances of inappropriate sexual contact with
Speaker 1: a plaintiff by Epstein in touching, inappropriate vaginal penetration and
Speaker 1: outright rape. Plaintiff was sexually assaulted, violated, and otherwise degraded, injured, victimized,
Speaker 1: and sub rejected to outrageous, reckless abuse and insult forty eight.
Speaker 1: In this regard, the defendants willingly participated, contributed, cooperated, and
Speaker 1: assisted the inappropriate and the legal scheme by facilitating such
Speaker 1: scheme by and through the employees of the corporate defendant,
Speaker 1: such as the corporate defendants were acting jointly and in
Speaker 1: concert with the illegal scheme, with the goal designed to
Speaker 1: produce corrupt sexual gratification for Epstein and degradation for the
Speaker 1: targets and victims of the corrupt scheme set in motion
Speaker 1: with the active involvement of the corporate defendants and their
Speaker 1: employees forty nine. Epstein's abuse of plaintiff was not incidental
Speaker 1: or fleeting, but rather was borne out of a pathological
Speaker 1: desire to achieve corrupt and deviate sexual gratification through the
Speaker 1: subjugation and abuse of Epstein's targeted victims. The actions on
Speaker 1: behalf of the corporate defendants buy and through its employees, enhanced,
Speaker 1: facilitated and promoted the deviate sexual acts of Epstein and
Speaker 1: contributed a corrupting influence which ensnared unsuspecting women and girls
Speaker 1: in its reach. Fifty Epstein, by acting singularly and in
Speaker 1: concert with the corporate defendants, devised a sophisticated plan and
Speaker 1: modus operandi which subtly and pervasively over time, connived to
Speaker 1: influence the victims and subjects of the corrupt and deviant
Speaker 1: sexual scheme, to influence the will to resist the temptations
Speaker 1: both actual and promised on behalf of the scheme, and
Speaker 1: thereby manipulate the victims into acceptance of the scheme as
Speaker 1: being one that was acceptable and appropriate. By virtue of
Speaker 1: communications and representations made on behalf of Abstein by the
Speaker 1: corporate defendants and in fact Epstein himself, the scheme utilized
Speaker 1: a gradual wearing down of the victim's will to resist,
Speaker 1: and did so by virtue of offering positive and negative
Speaker 1: rewards for compliance with the schemes overall deviant methodology and
Speaker 1: goals fifty one. Once Epstein and the corporate defendants, victims
Speaker 1: were entrapped and the scheme's methodologies enabled, Epstein and the
Speaker 1: corporate defendants through the employees utilized techniques to further inhibit, indoctrinate,
Speaker 1: and threaten Epstein's victims such that compliance with the deviant
Speaker 1: scheme's goals could further be obtained. Fifty two. The deviant
Speaker 1: scheme was perpetrated over years by the actions of Epstein
Speaker 1: and the corporate defendants, such that victims were caught up
Speaker 1: in the scheme. Pressure, threats, and indoctrination techniques utilized to
Speaker 1: bring the victims to heal fifty three. For victims young, vulnerable,
Speaker 1: and struggling financially, the scheme's methodology was particularly effective fifty four.
Speaker 1: As part and parcel of the scheme's goals, Epstein's colleagues
Speaker 1: and acquaintances were involved in the scheme and benefited from
Speaker 1: the scheme by virtue of receiving sexual favors and inappropriate, illegal,
Speaker 1: and otherwise commercial sexual services provided by Epstein's victims, such
Speaker 1: that the corrupt intent of this scheme involved males other
Speaker 1: than Epstein himself. So is anyone going to get arrested
Speaker 1: or are we going to talk about the flight logs
Speaker 1: a little bit more? As a direct and proximate result
Speaker 1: of the methodology of the deviant scheme and the goals
Speaker 1: of sexual exploitation of the women recruited and victimized plaintiff
Speaker 1: with subject to unwonted touching of her breasts and genitals
Speaker 1: other sensitive areas of her body, required to perform acts
Speaker 1: of a sexual nature against her will and subjected to
Speaker 1: genital penetration, and otherwise sexually degraded, abused, insulted, coerced, and
Speaker 1: injured experience, resulting in confusion, emotional distress, mental pain and suffering, shame, humiliation,
Speaker 1: loss of the enjoyment of life, inconvenience, and other injuries
Speaker 1: to body, mind, and soul. Fifty five. Epstein and the
Speaker 1: corporate defendants buy And, through their employees and agents, substantially
Speaker 1: contributed to proximately cause injury to the plaintiff as aforementioned
Speaker 1: fifty six. Over the course of years, Epstein and the
Speaker 1: corporate defendants buy And, through its employees and agents, facilitated
Speaker 1: the multiple rapes conducted on the plaintiff, in addition to
Speaker 1: other deviant sexual acts against her will. Furthermore, the Plaintiff's
Speaker 1: virginity was forcefully taken from her against her will. Fifty seven.
Speaker 1: This fraudulent scheme of Epstein's constituted acts of coercion from
Speaker 1: beginning to end from two thousand and one through mid
Speaker 1: two thousand and six, inasmuch as the scheme was designed
Speaker 1: to end, in fact caused plaintiff to believe that her
Speaker 1: failure to perform any sex act required by Epstein would
Speaker 1: result in serious financial, reputational, physical and emotional harm. Tour
Speaker 1: count one battery against Darren ky Endyke and Richard D.
Speaker 1: Coon as joint personal representatives of the estate of Jeffrey Epstein,
Speaker 1: fifty eight. The plaintiff adopts and re alleges paragraphs one
Speaker 1: through fifty seven above fifty nine, Epstein committed a harmful
Speaker 1: or offensive touching against plaintiff sixty As a direct and
Speaker 1: proximate result of Epstein's battery, the plaintiff has in the
Speaker 1: past suffered and in the future will continue to suffer
Speaker 1: physical injury, pain, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment,
Speaker 1: loss of self esteem, loss of dignity, invasion of her privacy,
Speaker 1: and the loss of her capacity to enjoy life, as
Speaker 1: well as other damages. Plaintiff incurred medical and psychological expenses,
Speaker 1: and plaintiff will in the future suffer additional medical and
Speaker 1: psychological expenses. These injuries are permanent in nature, and plaintiff
Speaker 1: will continue to suffer these losses in the future. Wherefore,
Speaker 1: Plaintiff demands judgment against the Estate of Jeffrey E. Epstein
Speaker 1: for compensentory in general damages, attorney fees, punitive damages, and
Speaker 1: other and further relief. As this Court deems just and proper.
Speaker 1: Plaintiff hereby demands trial by jury on all issues triable
Speaker 1: as the right by a jury. Count two battery violation
Speaker 1: of Section one thirty against Darren kay Endyke and Richard D.
Speaker 1: Con as joint personal representatives of the Estate of Jeffrey Epstein,
Speaker 1: sixty one. The plaintiff adopts and re alleges Paragraphs one
Speaker 1: through fifty seven above sixty two. The intentional acts of
Speaker 1: Epstein against plaintiff constitute a sexual offense as defined in
Speaker 1: New York Penal Law Section one thirty, including but not
Speaker 1: limited to the following. A sexual misconduct is defined in
Speaker 1: section one thirty dot twenty. Inasmuch as Epstein engaged in
Speaker 1: sexual intercourse with plaintiff without Plaintiff's consent. B Rape in
Speaker 1: the first degree is defined in Section one thirty dot
Speaker 1: thirty five inasmuch as Epstein engaged in sexual intercourse with
Speaker 1: plaintiff by forcible compulsion see criminal sexual act in the
Speaker 1: first degree as defined in section one thirty dot five zero,
Speaker 1: inasmuch as Epstein engaged in oral sexual conduct with plaintiff
Speaker 1: by forcible compulsion d Forcible touching has defined in section
Speaker 1: one thirty dot fifty two, inasmuch as Epstein intentionally and
Speaker 1: for no legitimate purpose, engage the forcible sexual touching of
Speaker 1: plaintiff for the purpose of degrading or abusing her, or
Speaker 1: for the purpose of gratifying his own sexual desire n E.
Speaker 1: Aggravated sexual abuse in the third degree as defined in
Speaker 1: section one thirty dot sixty six, inasmuch as Epstein and
Speaker 1: started a foreign object in the vagina of plaintiff by
Speaker 1: forcible compulsion sixty three. As a direct and proximate result
Speaker 1: of Epstein's violations of New York Penal Law Section one thirty,
Speaker 1: plaintiff has in the past suffered, and in the future
Speaker 1: will continue to suffer physical injury, pain, emotional distress, psychological trauma,
Speaker 1: mental anguish, humiliate embarrassment, loss of self esteem, loss of dignity,
Speaker 1: invasion of her privacy and the loss of her capacity
Speaker 1: to enjoy life, as well as other damages. Plaintiff incurred
Speaker 1: medical and psychological expenses, and plaintiff in the future will
Speaker 1: suffer additional medical and psychological expenses. These injuries are permanent
Speaker 1: in nature, and Plaintiff will continue to suffer these losses
Speaker 1: in the future. Wherefore, Plaintiff demands judgment against the Estate
Speaker 1: of Jeffrey e Epstein for compensantory in general damages, attorney fees,
Speaker 1: punitive damages, and such other and further relief as this
Speaker 1: Court deems just and proper. Plaintiff hereby demands trial by
Speaker 1: jury on all issues triable as a right by a jury.
Speaker 1: Count three. Cause of action against Darren ky Endyke and
Speaker 1: Richard D. Con as joint personal representatives of the Estate
Speaker 1: of Jeffrey e Epstein, pursuanto US Code eighteen, Section fifteen
Speaker 1: ninety five, sixty four. Plaintiff adopts and re alleges Paragraphs
Speaker 1: one through fifty seven above sixty five. Epstein within the
Speaker 1: special maritime and territorial jurisdiction of the United States is
Speaker 1: interstate and foreign commerce and or affecting interstate and foreign
Speaker 1: commerce knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized, solicited, threatened, forced,
Speaker 1: and coerse plaintiff to engage in commercial sex acts sixty six.
Speaker 1: Such actions were undertaken knowing that his use of force,
Speaker 1: threats of force, fraud, coercion, and or a combination of
Speaker 1: such means would be used, and were in fact used
Speaker 1: in order to cause plaintiff to engage in commercial sex acts.
Speaker 1: In doing so, Epstein violated US Code eighteen, fifteen ninety one,
Speaker 1: sixty seven. Furthermore, Epstein attempted to violate US Code eighteen,
Speaker 1: section fifteen ninety one. In doing so, violated section eighteen
Speaker 1: of US Code fifteen ninety four A. Sixty eight. Epstein
Speaker 1: conspired with each member of the enterprise and with other
Speaker 1: persons known and unknown, to violate US Code eighteen fifteen
Speaker 1: ninety one. In doing so, violated eighteen fifteen ninety four C.
Speaker 1: Sixty nine. By virtue of Epstein's violations of US Code eighteen,
Speaker 1: section fifteen ninety one, fifteen ninety three A, and fifteen
Speaker 1: ninety four, defendants Darren K. Endike and Richard D. Con
Speaker 1: as joint personal representatives of the estate of Jeffrey E.
Speaker 1: Epstein is subject to civil causes of action under US
Speaker 1: Code eighteen, Section fifteen ninety five by plaintiff who is
Speaker 1: a victim of the violations seventy Certain property of Epstein's
Speaker 1: was essential to the commission of the federal crimes and
Speaker 1: torts described herein, including the Palm Beach, Florida estate located
Speaker 1: at three fifty eight Elbrio Way, pom Beach, Florida, the
Speaker 1: use of multiple private aircrafts, including a Boeing aircraft and
Speaker 1: the Gulfstream aircas Such real property and aircraft, along with
Speaker 1: other of Epstein's property, were used as the means and
Speaker 1: instruments of Epstein's tortious and criminal offenses, and as such
Speaker 1: are subject to forfeiture seventy one. Additionally, Epstein's New York
Speaker 1: townhouse located at ninety seventy first Street in the Southern
Speaker 1: District of New York, Epstein's private island located in the
Speaker 1: United States Virgin Islands, and Epstein's New Mexico estate were
Speaker 1: used as means and instruments of Epstein's tortious and criminal
Speaker 1: offenses as they relate to plaintiff, and as such are
Speaker 1: subject to forfeiture seventy two as a direct and approximate
Speaker 1: result of Epstein's commission of the aforementioned criminal offenses enumerated
Speaker 1: in US Code eighteen, section fifteen ninety one, fifteen ninety
Speaker 1: three A, and fifteen ninety four, and the associated civil
Speaker 1: remedies provided in section fifteen ninety five. Plaintiff has in
Speaker 1: the past suffered and will continue to suffer injury and pain,
Speaker 1: emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
Speaker 1: loss of self esteem, loss of dignity, loss of enjoyment
Speaker 1: of life, invasion of privacy, and other damages associated with
Speaker 1: Epstein's actions. Plaintiff will incur further medical and psychological expenses.
Speaker 1: These injuries are permanent in nature, and Plaintiff will continue
Speaker 1: to suffer from them in the future. In addition to
Speaker 1: these losses, Plaintiff has incurred attorney's fees and will be
Speaker 1: required to do so in the future, for which Epstein
Speaker 1: is liable pursuant to US Code eighteen fifteen ninety five. Wherefore,
Speaker 1: Plaintiff demands judgment against the estate of Jeffrey E. Epstein
Speaker 1: for competentory damages and general damages, attorney fees pursuant to
Speaker 1: US Code eighteen, Section fifteen ninety five, punitive damages forfeiture
Speaker 1: of Epstein's assets, and such other and further relief as
Speaker 1: this Court deems just and proper. Plaintiff hereby demands trial
Speaker 1: by jury on all issues, trial as of right by
Speaker 1: a jury. All right, folks, we're going to wrap up.
Speaker 1: We'll part two here and in the next episode we'll
Speaker 1: pick up where we left off. All of the information
Speaker 1: that goes with this episode can be found in the
Speaker 1: description box. What's up, everyone, and welcome back to the
Speaker 1: Epstein Chronicles. This episode, we're going to pick back up
Speaker 1: with Jane Doe seventeen and her allegations against Jeffrey Epstein
Speaker 1: and Jeffrey Epstein's estate. Count number four Cause of Action
Speaker 1: against ninety seventy First Street Corporation pursuant to US Code eighteen,
Speaker 1: Section fifteen ninety five. Seventy three Plaintiff adopts and realleges
Speaker 1: Paragraphs one through fifty seven above seventy four. Defendant buy
Speaker 1: and through its management and personnel within the special maritime
Speaker 1: and territorial jurisdiction of the United States in interstate and
Speaker 1: foreign commerce and or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
Speaker 1: solicited by any means. Plaintiff. From two thousand and one
Speaker 1: through two thousand and six, seventy five, Defendant buy And,
Speaker 1: through its management and personnel, knew what means of fraud
Speaker 1: or coercion, and or a combination of such means would
Speaker 1: be used and were in fact used in order to
Speaker 1: cause Plaintiff to engage in commercial sex acts. In doing so,
Speaker 1: Defendant Corporation violated US Code eighteen, section fifteen ninety one
Speaker 1: seventy six. Furthermore, Defendant Corporation attempted to violate US Code eighteen,
Speaker 1: section fifteen ninety one. In so doing, violated US Code eighteen,
Speaker 1: fifteen ninety four a. Seventy seven. Defendant buy And, through
Speaker 1: its management and personnel, conspired with other members of the
Speaker 1: enterprise and with other persons and companies known and unknown,
Speaker 1: to violate US Code eighteen, section fifteen ninety one. In
Speaker 1: doing so, Defendant violated US Code eighteen, section fifteen ninety
Speaker 1: four c. Seventy eight By virtue of its violations of
Speaker 1: US Code eighteen, Section fifteen ninety one and fifteen ninety
Speaker 1: three A and fifteen ninety four. Defendant is subject to
Speaker 1: civil causes of action under US Code eighteen fifteen ninety
Speaker 1: five by plaintiff who is a victim of their violations.
Speaker 1: Seventy nine. Defendant buy And, through its management and personnel,
Speaker 1: participated in a venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining,
Speaker 1: and maintaining plaintiff, knowing that fraud or coercion would be
Speaker 1: used to cause plaintiff to commit a commercial sex act
Speaker 1: eighty As a direct and proximate result of defendant corporations
Speaker 1: commission of the aforementioned criminal offenses enumerated in US Code eighteen,
Speaker 1: section fifteen ninety one, fifteen ninety three A, and fifteen
Speaker 1: ninety four, and the associated civil remedies provided in section
Speaker 1: fifteen ninety five. Plaintiff has in the has suffered, and
Speaker 1: will continue to suffer injury and pain, emotional distress, psychological
Speaker 1: and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of
Speaker 1: self esteem, loss of dignity, loss of enjoyment of life,
Speaker 1: invasion of privacy, and other damages, associated with defendant's actions
Speaker 1: eighty one, Plaintiff will incur further medical and psychological expenses.
Speaker 1: These injuries are permanent in nature, and Plaintiff will continue
Speaker 1: to suffer from them in the future. In addition to
Speaker 1: these losses, Plaintiff has incurred attorney's fees and will continue
Speaker 1: to do so in the future for which defendant is
Speaker 1: liable pursu into US Code eighteen, section fifteen ninety five. Wherefore,
Speaker 1: Plaintiff demands judgment against ninety seventy First Street Corporation for
Speaker 1: compensatory and general damages, attorney fees pursu into US Code eighteen,
Speaker 1: section fifteen ninety five, forfeiture of Defendant's assets, punitive damages,
Speaker 1: and such other and further relief as this Court deems
Speaker 1: just and proper. Plaintiff hereby demands trial by jury on
Speaker 1: all issues triable as of a right by a jury.
Speaker 1: Count number five. Cause of action against Laurel Incorporated pursu
Speaker 1: into US Code eighteen, fifteen ninety five. Eighty two. Plaintiff
Speaker 1: adopts and realleges Paragraphs one through fifty seven above. Eighty three.
Speaker 1: Defendant buy and through its management and personnel within the
Speaker 1: Special Maritime and territorial jurisdiction of the United States in
Speaker 1: interstate and foreign commerce, and or affecting interstate and foreign commerce,
Speaker 1: knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized, solicited
Speaker 1: by any means Plaintiff From two thousand and one through
Speaker 1: two thousand and six eighty four, Defendant buy And, through
Speaker 1: its management and personnel, knew that means of fraud and coercion,
Speaker 1: and or a combination of such means would be used,
Speaker 1: and were in fact used, in order to cause plaintiff
Speaker 1: to engage in commercial sex. In doing so, Defending Corporation
Speaker 1: violated US Code eighteen, section fifteen ninety one eighty five. Furthermore,
Speaker 1: Defending Corporation attempted to violate US Code eighteen, section fifteen
Speaker 1: ninety one. In so doing, violated US Code eighteen, section
Speaker 1: fifteen ninety four a. Eighty six. Defendant Buying, through its
Speaker 1: management and personnel, conspired with other members of the enterprise
Speaker 1: and with other persons and companies known and unknown, to
Speaker 1: violate US Code eighteen, section fifteen ninety one. In doing so,
Speaker 1: Defendant violated US Code eighteen, section fifteen ninety four c.
Speaker 1: Eighty seven by virtue of its violations of US Code eighteen,
Speaker 1: section fifteen ninety one, fifteen ninety three A, and fifteen
Speaker 1: ninety four. Defending is subject to civil causes of action
Speaker 1: under US Code eighteen, section fifteen ninety five by plaintiff
Speaker 1: who is a victim of their violations. Eighty eight. Defendant Buying,
Speaker 1: through its management and personnel, participated in a venture with
Speaker 1: Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and maintaining plaintiff,
Speaker 1: knowing that fraud or coercion would be used to cause
Speaker 1: plaintiff to commit a commercial sex act eighty nine As
Speaker 1: a direct and proximate result of defendants corporation, commission of
Speaker 1: the aforementioned criminal offenses enumerated in US Code eighteen, section
Speaker 1: fifteen ninety one, fifteen ninety three A, and fifteen ninety four,
Speaker 1: and the associated civil remedies provided in section fifteen ninety five,
Speaker 1: Plaintiff has in the past suffered and will continue to
Speaker 1: suffer injury and pain, emotional distress, psychological and psychiatric trauma,
Speaker 1: mental anguish, humiliation, confusion, embarrassment, loss of self esteem, loss
Speaker 1: of dignity, loss of enjoyment, of life, invasion of privacy,
Speaker 1: and other damages associated with the defendant's actions. Ninety Plaintiff
Speaker 1: will incur further medical and psychological expenses. These injuries are
Speaker 1: permanent in nature, and plaintiff will continue to suffer from
Speaker 1: them in the future. In addition to these losses, Plaintiff
Speaker 1: has incurred attorney's fees and will continue to do so
Speaker 1: in the future for which defendant is liable pursuant to
Speaker 1: US Code eighteen, section fifteen ninety five. Wherefore, Plaintiff demands
Speaker 1: judgment against Laurel Incorporated for compensatory and general damages, attorney
Speaker 1: fees pursuant to US Code eighteen, fifteen ninety five, forfeiture
Speaker 1: of defendants assets, punitive damages, and such other and further
Speaker 1: relief as this Court deems just and proper. Plaintiff hereby
Speaker 1: demands trial by jury on all issues triable as of
Speaker 1: the right by a jury. Count number six Cause of
Speaker 1: Action against Financial Trust Company Incorporated, pursuant to US Code eighteen,
Speaker 1: section fifteen ninety five. Ninety one. Plaintiff adopts and re
Speaker 1: alleges Paragraphs one through fifty seven above. Ninety two. Defendant,
Speaker 1: by and through its management and personnel within the special
Speaker 1: maritime and territorial jurisdiction of the United States, an interstate
Speaker 1: and foreign commerce and or affecting interstate and foreign commerce,
Speaker 1: knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized, solicited
Speaker 1: by any means the plaintiff. Ninety three. Defendant Buying through
Speaker 1: its management and personnel knew that means of fraud or coercion,
Speaker 1: and or a combination of such means would be used,
Speaker 1: and were in fact used, in order to cause Plaintiff
Speaker 1: to engage in commercial sex acts. In doing so, Defendant
Speaker 1: Corporation violated US Code eighteen, section fifteen ninety one. Ninety four.
Speaker 1: Defendant Buying through its management and personnel knowingly benefited financially
Speaker 1: and by receiving things of value from participating in a
Speaker 1: venture with Epstein sex Trafficking Venture Enterprise which had engage
Speaker 1: in acts of violation of US Code eighteen, section fifteen
Speaker 1: ninety two and fifteen ninety five A, knowing that the
Speaker 1: venture had engaged in such violations. In doing so, Defendant
Speaker 1: Corporations violated US Code eighteen, section fifteen ninety three A
Speaker 1: ninety five. Furthermore, Defendant corporation attempted to violate US Code
Speaker 1: eighteen fifteen ninety one. In so doing, violated US Code
Speaker 1: eighteen section fifteen ninety four A. Ninety six. Defendant buy And,
Speaker 1: through its management and personnel, conspired with other members of
Speaker 1: the enterprise and with other persons and companies known and unknown,
Speaker 1: to violate US Code eighteen, section fifteen ninety one. In
Speaker 1: doing so, Defendant violated US Code eighteen fifteen ninety four C.
Speaker 1: Ninety seven. By virtue of their violations of US Code
Speaker 1: eighteen section fifteen ninety one, fifteen ninety three A, and
Speaker 1: fifteen ninety four, Defendant is subject to civil causes of
Speaker 1: action under US Code eighteen fifteen ninety five by plaintiff
Speaker 1: who was a victim of their violations. Number ninety eight.
Speaker 1: Defendant buy And, through its management and personnel, participated in
Speaker 1: a venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining,
Speaker 1: and maintaining plaintiff, knowing that fraud or coercion would be
Speaker 1: used to cause plaintiff to commit a commercial sex Act
Speaker 1: ninety nine. As a direct and proximate result of defendants
Speaker 1: corporation commission of the aforementioned criminal offenses enumerated in US
Speaker 1: Code eighteen, section fifteen ninety one, fifteen ninety three A,
Speaker 1: and fifteen ninety four, and the associated civil remedies provided
Speaker 1: in fifteen ninety five. Plaintiff has in the past suffered
Speaker 1: and will continue to suffer injury and pain, emotional distress,
Speaker 1: psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss
Speaker 1: of self esteem, loss of dignity, loss of enjoyment of life,
Speaker 1: invasion of privacy, and other damages associated with the defendant's actions.
Speaker 1: One hundred stiff will incur further medical and psychological expenses.
Speaker 1: These injuries are permanent in nature, and plaintiff will continue
Speaker 1: to suffer from them in the future. In addition to
Speaker 1: these losses, Plaintiff has incurred attorney's fees and will continue
Speaker 1: to do so in the future, for which defendant is
Speaker 1: liable pursue it to US Code eighteen, section fifteen ninety five, Wherefore,
Speaker 1: Plaintiff demands judgment against defendant Financial Trust Company, Incorporated, for
Speaker 1: compensatory in general damages attorney fees pursu into US Code
Speaker 1: eighteen fifteen ninety five forfeiture of the defendants assets, punitive damages,
Speaker 1: and other such and further relief as this Court deems
Speaker 1: just and proper. Plaintiff hereby demands trial by jury on
Speaker 1: all issues triable as of right by a jury. Count
Speaker 1: number seven. Cause of Action against nes LLC. Pursu into
Speaker 1: US Code eighteen, Section fifteen ninety five, Sec. One oh one.
Speaker 1: Plaintiff adopts and reallegeswer Paragraphs one through fifty seven above.
Speaker 1: One oh two. Defendant buy And, through its management and personnel,
Speaker 1: within the special maritime and territorial jurisdiction of the United States,
Speaker 1: an interstate and foreign commerce, and or affecting interstate and
Speaker 1: foreign commerce, knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
Speaker 1: solicited by any means the plaintiff. One O three. Defendant
Speaker 1: buy And, through its management and personnel, knew that means
Speaker 1: of fraud or coercion, and or a combination of such
Speaker 1: means would be used, and were in fact used, in
Speaker 1: order to cause Plaintiff to engage in commercial sex acts.
Speaker 1: In doing so, Defendant Corporation violated US Code eighteen, Section
Speaker 1: fifteen ninety one one oh four. Furthermore, Defendant Corporation attempted
Speaker 1: to violate US Code eighteen, section fifteen ninety one. In
Speaker 1: so doing, violated US Code eighteen fifteen ninety four A.
Speaker 1: One oh five. Buying, through its management and personnel, conspired
Speaker 1: with other members of the enterprise and with other persons
Speaker 1: and companies known and unknown, to violate US Code eighteen,
Speaker 1: section fifteen ninety one. In doing so, Defendant violated US
Speaker 1: Code eighteen section fifteen ninety four C. One O six.
Speaker 1: By virtue of their violations of US Code eighteen section
Speaker 1: fifteen ninety one, fifteen ninety three A, and fifteen ninety four,
Speaker 1: Defendant is subject to civil causes of action under US
Speaker 1: Code eighteen fifteen ninety five by plaintiff who is a
Speaker 1: victim of their violations. One oh seven. Defendant, buy And,
Speaker 1: through its management and personnel, participated in a venture with
Speaker 1: Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and maintaining plaintiff,
Speaker 1: knowing that fraud or coercion would be used to cause
Speaker 1: plaintiff to commit a commercial sex act one O eight.
Speaker 1: As a direct and proximate result of defendants corporation commission
Speaker 1: of the aforementioned criminal offenses, enumerated in US Code eighteen,
Speaker 1: section fifteen ninety one, fifteen ninety three A, and fifteen
Speaker 1: ninety four, and the associated civil remedies provided in section
Speaker 1: fifteen ninety five. Plaintiff has in the past suffered and
Speaker 1: will continue to suffer injury and pain, emotional distress, psychological
Speaker 1: and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of
Speaker 1: self esteem, loss of dignity, loss of enjoyment of life,
Speaker 1: invasion of privacy, and other damages associated with the defendant's actions.
Speaker 1: Se one oh nine, Plaintiff will incur further medical and
Speaker 1: psychological expenses. These injuries are permanent in nature, and plaintiff
Speaker 1: will continue to suffer them in the future. In addition
Speaker 1: to these losses, Plaintiff has incurred attorney's fees and will
Speaker 1: continue to do so in the future for which defendant
Speaker 1: is liable pursue it to US Code eighteen, section fifteen
Speaker 1: ninety five, wherefore, plaintiff demands judgment against the f defendant,
Speaker 1: and he has incorporated for compensatory in general damages attorney
Speaker 1: fees pursu into US Code eighteen, section fifteen ninety five
Speaker 1: forfeiture of defendant's assets punitive damages, and such other and
Speaker 1: further relief as this Court deems just and proper. Plaintiff
Speaker 1: hereby demands trial by jury on all issues triable as
Speaker 1: a right by a jury. All right, folks, that's gonna
Speaker 1: do it for this one. In the next episode, we're
Speaker 1: gonna pick up where we left off and continue on
Speaker 1: with Jane Doe seventeen and her allegations against Jeffrey Epstein's estate.
Speaker 1: All of the information that goes with this episode can
Speaker 1: be found in the description box. What's up everyone, and
Speaker 1: welcome back to the Epstein Chronicles. We're gonna pick right
Speaker 1: back up where we left off with Jane Doe and
Speaker 1: her complaints against Jeffrey Epstein and his a State count
Speaker 1: Number eight Cause of Action against Maple Incorporated, pursu into
Speaker 1: US Code eighteen, Section fifty feteen ninety five, Number one ten.
Speaker 1: Plaintiff adopts and re alleges Paragraphs one through fifty seven
Speaker 1: above one eleven. Defendant buy and through its management and
Speaker 1: personnel within the special maritime and territorial jurisdiction of the
Speaker 1: United States and interstate and foreign commerce, and or affecting
Speaker 1: interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
Speaker 1: solicited by any means Plaintiff from two thousand and one
Speaker 1: through two thousand and six one twelve, Defendant buy And,
Speaker 1: through its management and personnel, knew that means of fraud
Speaker 1: or coercion, and or a combination of such means would
Speaker 1: be used and were in fact used in order to
Speaker 1: cause plaintiff to engage in commercial sex acts. In doing so,
Speaker 1: Defendant Corporation violated US Code eighteen, section fifteen ninety one
Speaker 1: one thirteen. Furthermore, Defendant Corporation attempted to violate US Code eighteen,
Speaker 1: section fifteen ninety In doing so, violated US Code eighteen
Speaker 1: section fifteen ninety four A one fourteen. Defendant Buying, through
Speaker 1: its management and personnel, conspired with other members of the
Speaker 1: enterprise and with other persons and companies known and unknown,
Speaker 1: to violate US Code eighteen section fifteen ninety one. In
Speaker 1: doing so, Defendant violated eighteen US Code section fifteen ninety
Speaker 1: four C one fifteen by virtue of its violations of
Speaker 1: US Code eighteen section fifteen ninety one, section fifteen ninety
Speaker 1: three A and fifteen ninety four. Defendant is subject to
Speaker 1: civil causes of action under US Code eighteen, Section fifteen
Speaker 1: ninety five by plaintiff who is a victim of their violations.
Speaker 1: One sixteen. Defendant Buying, through its management and personnel, participated
Speaker 1: in a venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining,
Speaker 1: and maintaining plaintiff, knowing that fraud and or coercion would
Speaker 1: be used to cause plaintiff to commit a commercial sex
Speaker 1: act one seventeen. As a direct and proximate result of
Speaker 1: defendants corporations commission of the aforementioned criminal offenses enumerated in
Speaker 1: US Code eighteen, Section fifteen ninety one, fifteen ninety three A,
Speaker 1: and fifteen ninety four, and the associated civil remedies provided
Speaker 1: in section fifteen ninety five. Plaintiff has in the past
Speaker 1: suffered and will continue to suffer injury and pain, emotional distress,
Speaker 1: psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss
Speaker 1: of self esteem, loss of enjoyment of life, invasion of privacy,
Speaker 1: and other damages associated with the defendant's actions. One eighteen,
Speaker 1: Plaintiff will incur further medical and psychological expenses. These injuries
Speaker 1: are permanent in nature, and Plaintiff will continue to suffer
Speaker 1: from them in the future. In addition to these losses,
Speaker 1: Plaintiff has incurred attorney's fees and will continue to douce
Speaker 1: z in the future for which Defendant is liable pursuing
Speaker 1: to US Code eighteen, section fifteen ninety five. Wherefore, Plaintiff
Speaker 1: demands judgment against Maple Incorporated for competsentory and general damages,
Speaker 1: attorney fees pursuing to US Code eighteen, section fifteen ninety five,
Speaker 1: forfeiture of defendants assets, punitive damages, and such other and
Speaker 1: further relief as this Court deems justin proper. Plaintiff hereby
Speaker 1: demands trial by jury on all issues triable as of
Speaker 1: right by a jury. Count nine Cause of action against
Speaker 1: eld sje Llc pursuing to US Code eighteen, section fifteen
Speaker 1: ninety five one nineteen. Plaintiff adopts and re alleges Paragraphs
Speaker 1: one through fifty seven above. One twenty Defendant buying through
Speaker 1: its management and personnel within the special maritime and territorial
Speaker 1: jurisdiction of the United States in interstate and foreign commerce
Speaker 1: and or affecting interstate and foreign commerce knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
Speaker 1: solicited by any means. Plaintiff from two thousand and one
Speaker 1: through two thousand and six one twenty one, Defendant buy And,
Speaker 1: through its management and personnel, knew that means of fraud
Speaker 1: or coercion, and or combinations of such means would be used,
Speaker 1: and were in fact used, in order to cause Plaintiff
Speaker 1: to engage in commercial sex acts. In doing so, Defendant
Speaker 1: Corporation violated US Code eighteen, section fifteen ninety one one
Speaker 1: twenty two. Furthermore, Defendant Corporation attempted to violate US Code eighteen,
Speaker 1: section fifteen ninety one. In so doing, violated US Code
Speaker 1: eighteen section fifteen ninety four A one twenty three. Defendant
Speaker 1: buy And, through its management and personnel, conspired with other
Speaker 1: members of the enterprise and with other persons and companies
Speaker 1: known and unknown, to violate US Code eighteen section fifteen
Speaker 1: ninety one. In doing so, Defendant violated US Code eighteen
Speaker 1: section fifteen ninety four C. One twenty four by virtue
Speaker 1: of its violations of US Code eighteen section fifteen ninety one,
Speaker 1: fifteen ninety three A, and fifteen ninety four. Defendant is
Speaker 1: subject to civil causes of action under US Code eighteen,
Speaker 1: section fifteen ninety five by plaintiff who is a victim
Speaker 1: of their violations. One twenty five. Defendant buy And, through
Speaker 1: its management and personnel, participated in a venture with Epstein's
Speaker 1: enterprise by knowingly recruiting, transporting, soliciting, obtaining, and maintaining plaintiff,
Speaker 1: knowing that fraud or coercion would be used to cause
Speaker 1: plaintiff to commit a commercial sex act one twenty six.
Speaker 1: As a direct and proximate result of defendants corporation, commission
Speaker 1: of the aforementioned criminal offenses enumerated in US Code eighteen,
Speaker 1: Section fifteen ninety one, fifteen ninety three a n. Fifteen
Speaker 1: ninety four, and the associated civil remedies provided in section
Speaker 1: fifteen ninety five, Plaintiff has in the past suffered and
Speaker 1: will continue to suffer injury and pain, emotional distress, psychological
Speaker 1: and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of
Speaker 1: self esteem, loss of enjoyment of life, invasion of privacy,
Speaker 1: and other damages associated with the defendant's actions. One twenty seven,
Speaker 1: Plaintiff will incur further medical and psychological expenses. These injuries
Speaker 1: are permanent in nature, and Plaintiff will continue to suffer
Speaker 1: from them in the future. In addition to these losses,
Speaker 1: Plaintiff has incurred attorney fees and will continue to do
Speaker 1: so in the future for which Defendant is liable pursu
Speaker 1: into US Code eighteen, section fifteen ninety five, wherefore, Plaintiff
Speaker 1: demands judgment against LSJE Llc for compensatory and general damages,
Speaker 1: attorney fees, pursue it to US Code eighteen, section fifteen
Speaker 1: ninety five forfeiture of Defendant's assets, punitive damages, and such
Speaker 1: other and further relief as this Court deems just and proper.
Speaker 1: Plaintiff hereby demands trial by jury on all issues triable
Speaker 1: as of a right by a jury. Count ten Cause
Speaker 1: of action against HBRK Associates, Incorporated. Pursuing the US Code eighteen,
Speaker 1: section fifteen ninety five. One twenty eight. Plaintiff adopts and
Speaker 1: realleges Paragraphs one through fifty seven above. One twenty nine.
Speaker 1: Defendant buying through its management and personnel within the special
Speaker 1: Maritime and Territorial jurisdiction of the United States in interstate
Speaker 1: and foreign commerce and or affecting interstate and foreign commerce,
Speaker 1: knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized, solicited
Speaker 1: by any means the plaintiff one thirty Defendant Buying, through
Speaker 1: its management and personnel, knew that means of fraud and
Speaker 1: or coercion, and or combinations of such means would be used,
Speaker 1: and were in fact used, in order to cause Plaintiff
Speaker 1: to engage in commercial sex acts. In doing so, Defendant
Speaker 1: Corporation violated US Code eighteen, section fifteen ninety one. One
Speaker 1: thirty one. Defendant Buying, through its management and personnel, knowingly
Speaker 1: benefited financially and by receiving things of value from participating
Speaker 1: in a venture with Epstein sex trafficking Venture Enterprise which
Speaker 1: had engaged in acts of violation of US Code eighteen,
Speaker 1: section fifteen ninety two and fifteen ninety five, knowing that
Speaker 1: the venture had engaged in such violations. In doing so,
Speaker 1: Defendant Corporation violated US Code eighteen, section fifteen ninety three
Speaker 1: A one thirty two. Furthermore, Defendant Corporation attempted to violate
Speaker 1: US Code eighteen, section fifteen ninety one. In so doing,
Speaker 1: defendant violated US Code eighteen, section fifteen ninety four A.
Speaker 1: One thirty three. Defendant Buying, through its management and personnel,
Speaker 1: conspired with other members of the enterprise and with other
Speaker 1: persons and companies known and unknown to violate US Code eighteen,
Speaker 1: section fifteen ninety one. In doing so, Defendant violated US
Speaker 1: Code eighteen fifteen ninety four C. One thirty four. By
Speaker 1: virtue of their violations of US Code eighteen fifteen ninety one,
Speaker 1: fifteen ninety three A, and fifteen ninety four, Defendant is
Speaker 1: subject to civil causes of action under US Code eighteen,
Speaker 1: section fifteen ninety five by plaintiff who is a victim
Speaker 1: of their violations. One thirty five. Defendant buy And, through
Speaker 1: its management and personnel, participated in a venture with Epstein's
Speaker 1: enterprise by knowingly recruiting, transporting, soliciting, obtaining, and maintaining plaintiff,
Speaker 1: knowing that fraud or coercion would be used to cause
Speaker 1: plaintiff to commit a commercial sex act one thirty six.
Speaker 1: As a direct and proximate result of defendant corporations commission
Speaker 1: of the aforementioned criminal offenses, enumerated in US Code eighteen
Speaker 1: sections fifteen ninety one, fifteen ninety three A, and fifteen
Speaker 1: ninety four, and the associated civil remedies provided in section
Speaker 1: fifteen ninety five. Plaintiff has in the past suffered and
Speaker 1: will continue to suffer injury and pain, emotional distress, psychological
Speaker 1: and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of
Speaker 1: self esteem, loss of enjoyment of life, invasion of privacy,
Speaker 1: and other damages associated with defendant's actions. One thirty seven.
Speaker 1: Plaintiff will incur further medical and psychological expenses. These injuries
Speaker 1: are permanent in nature, and Plaintiff will continue to suffer
Speaker 1: from them in the future. In addition to the losses,
Speaker 1: Plaintiff has incurred attorney's fees and will continue to do
Speaker 1: so in the future for which Defendant is liable pursuant
Speaker 1: to US Code eighteen, Section fifteen ninety five one thirty eight. Wherefore,
Speaker 1: Plaintiff demands judgment against Defendant HBRK Associates, Incorporated for compensentory
Speaker 1: and general damages attorney fees pursuant to US Code eighteen,
Speaker 1: Section fifteen ninety five forfeiture of defendant's assets, punitive damages,
Speaker 1: and such other and further relief as this Court deems
Speaker 1: just and proper. Plaintiff hereby demands trial by jury on
Speaker 1: all issues triable as of a right by a jury.
Speaker 1: All right, folks, we're going to wrap up there, and
Speaker 1: in the next episode we're going to finish off Jane
Speaker 1: Doe seventeen and the allegations that she's making or made,
Speaker 1: i should say, against the estate. All of the information
Speaker 1: that goes with this episode can be found in the
Speaker 1: description box. What's up, everyone, and welcome back to the
Speaker 1: Epstein Chronicles. In this episode, we're going to finish off
Speaker 1: with Jane Doe seventeen and her allegations against Jeffrey Epstein
Speaker 1: and the Jeffrey Epstein Estate. So let's get right back
Speaker 1: to it. Count number eleven Cause of Action against Nautilus Incorporated.
Speaker 1: Pursuant to US Code eighteen, Section fifteen ninety five one
Speaker 1: thirty nine. Plaintiff adopts and realleges Paragraphs one through fifty
Speaker 1: seven above one for defendant buy and through its management
Speaker 1: and personnel within the special maritime and territorial jurisdiction of
Speaker 1: the United States in interstate and foreign commerce and or
Speaker 1: affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
Speaker 1: solicited by any means the plaintiff. One forty one. Defendant
Speaker 1: buy And, through its management and personnel, knew that means
Speaker 1: of fraud or coercion, and or combinations of such means
Speaker 1: would be used, and were in fact used, in order
Speaker 1: to cause Plaintiff to engage in commercial sex acts. In
Speaker 1: doing so, Defendant Corporation violated US Code eighteen, section fifteen
Speaker 1: ninety one. One forty two. Defendant buy And, through its
Speaker 1: management and personnel, knowingly benefited financially and receiving things of
Speaker 1: value from participating in a venture the Epstein sex Trafficking
Speaker 1: Venture Enterprise, which had engaged in acts in violation of
Speaker 1: US Code eighteen, section fifteen ninety two and fifteen ninety
Speaker 1: five A, knowing that the venture had engaged in such violations.
Speaker 1: In so doing, defending Corporation violated US Code eighteen, section
Speaker 1: fifteen ninety three A one forty three. Furthermore, Defendant Corporation
Speaker 1: attempted to violate US Code eighteen, fifteen ninety one. In
Speaker 1: so doing, Defendant violated US Code eighteen, section fifteen ninety
Speaker 1: four A. One forty four. Defendant buy And, through its
Speaker 1: management and personnel, conspired with other members of the enterprise
Speaker 1: and with other persons and companies known and unknown, to
Speaker 1: violate US Code eighteen, section fifteen ninety one. In doing so,
Speaker 1: defendant violated US Code eighteen section fifteen ninety four C.
Speaker 1: One forty five. By virtue of their violations of US
Speaker 1: Code eighteen section fifteen ninety one, fifteen ninety three A,
Speaker 1: and fifteen ninety four, defendant is subject to civil causes
Speaker 1: of action under US Code eighteen, section fifteen ninety five
Speaker 1: by plaintiff who is a victim of their violations. One
Speaker 1: forty six. Defendant buy And, through its management and personnel,
Speaker 1: participated in a venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining,
Speaker 1: and maintaining plaintiff, knowing that fraud or coercion would be
Speaker 1: used to cause plaintiff to commit a commercial sex act
Speaker 1: one forty seven. As a direct and proximate result of
Speaker 1: defendants corporations commission of the aforementioned criminal offenses enumerated in
Speaker 1: US Code eighteen sections fifteen ninety one, fifteen ninety three A,
Speaker 1: and fifteen ninety four, and the associates civil remedies provided
Speaker 1: in section fifteen ninety five. Plaintiff has in the past
Speaker 1: suffered and will continue to suffer injury and pain, emotional distress,
Speaker 1: psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss
Speaker 1: of self esteem, loss of dignity, loss of enjoyment of life,
Speaker 1: invasion of privacy, and other damages associated with the defendant's actions.
Speaker 1: One eight. Plaintiff will incur further medical fees and psychological expenses.
Speaker 1: These injuries are permanent in nature, and plaintiff will continue
Speaker 1: to suffer from them in the future. In addition to
Speaker 1: these losses, Plaintiff has incurred attorney's fees and will continue
Speaker 1: to do so in the future for which defendant is
Speaker 1: liable pursuant to US Code eighteen, section fifteen ninety five.
Speaker 1: One nine. Wherefore, a plaintiff demands judgment against defendant Nautilus
Speaker 1: Incorporated for a compensatory and general damages, attorney fees pursuant
Speaker 1: to US Code eighteen, section fifteen ninety five, forfeiture of
Speaker 1: defendant's assets, punitive damages, and such other and further relief
Speaker 1: as this Court deems just and proper. Plaintiff hereby demands
Speaker 1: trial by jury on all issues triable as of right
Speaker 1: by a jury. Count number twelve. Cause of Action against
Speaker 1: Cyprus Incorporated. Pursue into US Code eighteen, Section fifteen ninety five,
Speaker 1: Plaintiff adopts and re alleges Paragraphs one through fifty seven above.
Speaker 1: One fifty one. Defendant buy And, through its management and
Speaker 1: personnel within the special maritime and territorial jurisdiction of the
Speaker 1: United States in interstate and foreign commerce and or affecting
Speaker 1: interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
Speaker 1: solicited by any means the plaintiff. One fifty two. Defendant
Speaker 1: buy And, through its management and personnel, knew that means
Speaker 1: of fraud or coercion, and or a combination of such
Speaker 1: means would be used, and were in fact used, in
Speaker 1: order to cause Plaintiff to engage in commercial sex acts.
Speaker 1: In doing so, defending corporation violated US Code eighteen, Section
Speaker 1: fifteen ninety one. One fifty three Defendant buy And, through
Speaker 1: its management and personnel, knowingly benefited financially and by receiving
Speaker 1: things of value from participating in a venture the Epstein
Speaker 1: Sex Trafficking Venture Enterprise, which had engaged in acts in
Speaker 1: violation of US Code eighteen, section fifteen ninety two and
Speaker 1: fifteen ninety five A. Knowing that the venture had engaged
Speaker 1: in such violations. In doing so, Defending Corporation violated US
Speaker 1: Code eighteen, section fifteen ninety three A one fifty four. Furthermore,
Speaker 1: Defending Corporation attempted to violate US Code eighteen, section fifteen
Speaker 1: ninety one. In doing so, Defendant biolated US Code eighteen
Speaker 1: section fifteen ninety four A one fifty five. Defendant buy And,
Speaker 1: through its management and personnel, conspired with other members of
Speaker 1: the enterprise and with other persons and companies known and unknown,
Speaker 1: to violate US Code eighteen, section fifteen ninety one. In
Speaker 1: doing so, Defendant violated US Code eighteen section fifteen ninety
Speaker 1: four C. One fifty six. By virtue of their violations
Speaker 1: of US Code eighteen fifteen ninety one, fifteen ninety three A,
Speaker 1: and fifteen ninety four, Defendant is subject to civil causes
Speaker 1: of action under US Code eighteen, section fifteen ninety five
Speaker 1: by plaintiff who is a victim of their violations. One
Speaker 1: fifty seven. Defendant buy And, through its management and personnel,
Speaker 1: participated in a venture with Epstein's enterprise, knowingly recruiting, transporting, soliciting, obtaining,
Speaker 1: and maintaining plaintiff, knowing that fraud or coercion would be
Speaker 1: used to call plaintiff to commit a commercial sex act
Speaker 1: one fifty eight. As a direct and proximate result of
Speaker 1: defendants corporations commission of aforementioned criminal offenses enumerated in US
Speaker 1: Code eighteen, Section fifteen ninety one and fifteen ninety three
Speaker 1: A and fifteen ninety four, and the associated civil remedies
Speaker 1: provided in section fifteen ninety five. Plaintiff has in the
Speaker 1: past suffered and will continue to suffer injury and pain,
Speaker 1: emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
Speaker 1: loss of self esteem, loss of dignity, loss of enjoyment
Speaker 1: of life, invasion of privacy, and other damages associated with
Speaker 1: the defendant's actions. One fifty nine, Plaintiff will incur further
Speaker 1: medical and psychological expenses. These injuries are permanent in nature,
Speaker 1: and plaintiff will continue to suffer from them in the future.
Speaker 1: In addition to these losses, Plaintiff has incurred attorney's fees
Speaker 1: and will continue to do so in the future for
Speaker 1: which Defendant is liable pursuant to US Code eighteen, Section
Speaker 1: fifteen ninety five, one sixty Wherefore, Plaintiff demands judgment against
Speaker 1: Defendant Cyprus Incorporated, for compensatory and general damages, attorney fees
Speaker 1: pursuant to US Code eighteen, section fifteen ninety five, forfeiture
Speaker 1: of Defendant's assets, punitive damages, and such other and further
Speaker 1: relief as this Court deems just and proper. Plaintiff hereby
Speaker 1: demands trial by jury on all issues triable as right
Speaker 1: by a jury. Count thirteen. Cause of Action against Jege Incorporated,
Speaker 1: pursu into US Code eighteen, Section fifteen ninety five, one
Speaker 1: sixty one. Plaintiff adopts and re alleges paragraphs one through
Speaker 1: fifty seven above. One sixty two. Defendant buy and, through
Speaker 1: its management and personnel within the special maritime and territorial
Speaker 1: jurisdiction of the United States, in interstate and foreign commerce
Speaker 1: and or affecting interstate and foreign commerce, knowingly recruited, enticed harbored, transported, provided, obtained, maintained, patronized,
Speaker 1: solicited by any means Plaintiff from two thousand and one
Speaker 1: through two thousand and six one sixty three. Defendant Buying
Speaker 1: through its management and personnel, knew that means of fraud
Speaker 1: or coercion, and or a combination of such means would
Speaker 1: be used, and were in fact used, in order to
Speaker 1: cause plaintiff to engage in commercial sex acts. In doing so,
Speaker 1: Defending Corporation violated US Code eighteen section fifteen ninety one
Speaker 1: one sixty four. Furthermore, Defendant Corporation attempted to violate US
Speaker 1: Code eighteen, section fifteen ninety one. In doing so, violated
Speaker 1: US Code eighteen section fifteen ninety four A one sixty five.
Speaker 1: Defendant Buying, through its management and personnel, conspired with other
Speaker 1: members of the enterprise and with other persons and companies
Speaker 1: known and unknown, to violate US Code eighteen section fifteen
Speaker 1: ninety one. In doing so, Defendant violated US Code eighteen
Speaker 1: section fifteen ninety four C. One sixty six by virtue
Speaker 1: of its violations of US Code eighteen section fifteen ninety one,
Speaker 1: fifteen ninety three A, and fifteen ninety four defending his
Speaker 1: subject to civil causes of action under US Code eighteen,
Speaker 1: section fifteen ninety five by plaintiff who was a victim
Speaker 1: of their violations. One sixty seven. Defendant buy And, through
Speaker 1: its management and personnel, participated in a venture with Epstein's
Speaker 1: enterprise by knowingly recruiting, transporting, soliciting, obtaining, and maintaining plaintiff,
Speaker 1: knowing that fraud or coercion would be used to cause
Speaker 1: plaintiff to commit a commercial sex act one sixty eight.
Speaker 1: As a direct and proximate result of defendants Corporation's commission
Speaker 1: of the aforementioned midal offenses enumerated in US Code eighteen,
Speaker 1: Section fifteen ninety one, fifteen ninety three A, and fifteen
Speaker 1: ninety four, and the associated civil remedies provided in section
Speaker 1: fifteen ninety five, Plaintiff has in the past suffered and
Speaker 1: will continue to suffer injury and pain, emotional distress, psychological
Speaker 1: and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of
Speaker 1: self esteem, loss of dignity, loss of enjoyment of life,
Speaker 1: invasion of privacy, and other damages associated with the defendant's actions.
Speaker 1: One sixty nine, Plaintiff will incur further medical and psychological expenses.
Speaker 1: These injuries are permanent in nature, and plaintiff will continue
Speaker 1: to suffer from them in the future. In addition to
Speaker 1: these losses, Plaintiff has incurred attorney fees and will continue
Speaker 1: to do so in the future for which defendant is
Speaker 1: liable pursu into US Code eighteen, section fifteen ninety five. Wherefore,
Speaker 1: Plaintiff demands judgment against JEGE Incorporated for compensentory and general damages,
Speaker 1: attorney fees pursuant to US Code eighteen, section fifteen ninety five,
Speaker 1: forfeiture of defendants assets, punitive damages, and such other and
Speaker 1: further relief as this Court deems just and proper. Plaintiff
Speaker 1: hereby demands trial by jury on all issues triable as
Speaker 1: of right by a jury. All right, folks, Well, that's
Speaker 1: going to wrap up Jane Doe number seventeen and her
Speaker 1: allegations against Jeffrey Epstein, and as a state, we have
Speaker 1: plenty more where that came from as well, including the
Speaker 1: Jeffrey Epstein deposition that we're going to get around to
Speaker 1: this weekend. So buckle up, get your bar bags ready,
Speaker 1: because the discuss bus is about to leave. The station.
Speaker 1: All of the information that goes with this episode can
Speaker 1: be found in the description box