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<v Speaker 1>What's up, everyone, and welcome to another episode of the

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<v Speaker 1>Epstein Chronicles. In this episode, we're going to get right

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<v Speaker 1>back to Jane Doe one oh six and her allegations

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<v Speaker 1>against Jeffrey Epstein. A similar pattern of grooming continued and

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<v Speaker 1>the sexual exploitation progressively escalated over the course of approximately

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<v Speaker 1>seventeen months, during which defendant would often travel to Palm Beach.

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<v Speaker 1>Prior to arriving, and while in Palm Beach, Defendant and

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<v Speaker 1>or his agents would frequently call plaintiff at her home

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<v Speaker 1>telephone number and or other telephone numbers, arranging for encounters

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<v Speaker 1>with her for defendant, sometimes twice daily. While usually such

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<v Speaker 1>contacts were made by his assistants, Defendant personally called plaintiff

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<v Speaker 1>repeatedly despite being told to leave plaintiff alone. After the

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<v Speaker 1>first few encounters, Defendant core's plaintiff to remove all her clothing,

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<v Speaker 1>and Defendant penetrated minor plaintiffs vagina digitally. Defendant sexually abused

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<v Speaker 1>and or battered and or exploited plaintiff at least one

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<v Speaker 1>hundred times between approximately January two thousand and four and

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<v Speaker 1>May two thousand and five. Such exploitation included, but was

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<v Speaker 1>not limited to defendant sexual abuse and battery of plaintiff

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<v Speaker 1>with vibrators, back massager, his fingers, and his penis. At times,

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<v Speaker 1>defendant manipulated plaintiff to interact sexually with another female. During

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<v Speaker 1>one encounter, defendant penetrated the minor plaintiff's vagino with his penis,

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<v Speaker 1>all while narrating and demonstrating his sexual battery of plaintiff

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<v Speaker 1>to another female president in the room. While some of

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<v Speaker 1>the precise dates that defendants' acts of sexual exploitation occurred

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<v Speaker 1>are unknown to plaintiff, these dates are known to defendant

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<v Speaker 1>as he and or his assistants kept written records, some

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<v Speaker 1>of which are in the custody of law enforcement, of

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<v Speaker 1>each instance in which he committed lout acts upon minor girls,

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<v Speaker 1>including the then minor a plaintiff. So, if you're looking

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<v Speaker 1>for a list, how about we get this? Huh? Is

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<v Speaker 1>anybody going to explore what's going on here? Or are

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<v Speaker 1>we just going to be told to move on. Defendant's

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<v Speaker 1>preference for underage girls was well known to those who

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<v Speaker 1>regularly procured them for him. The above described acts of

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<v Speaker 1>abuse began to occur during a time when defendant knew

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<v Speaker 1>that plaintiff was a minor. Defendant at all times material

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<v Speaker 1>to this cause of action knew and or should have

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<v Speaker 1>known that plaintiff's age of minority. In fact, Defendant repeatedly

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<v Speaker 1>urged the minor plaintiff to become legally emancipated in order

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<v Speaker 1>to accompany him as he traveled both nationally and internationally. Additionally, Defendant,

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<v Speaker 1>knowing that plaintiff was merely seventeen years old, lured her

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<v Speaker 1>by inviting her to stay with them in his mansion

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<v Speaker 1>in Manhattan and or arranging and paying for airplane tickets,

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<v Speaker 1>theater tickets, and a personal chauffeur as gifts for her

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<v Speaker 1>upcoming birthday. As part of defendant's persistent process of grooming

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<v Speaker 1>plaintiff and a mersinger in his lude and abusive lifestyle,

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<v Speaker 1>Defendant regularly showered the adolescent plaintiff with gifts, including, but

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<v Speaker 1>not limited to, lingerie flowers, bikini bathing suits, art books, purses,

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<v Speaker 1>envelopes of US currency, use of a car, and other accouterments.

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<v Speaker 1>Defendant possessed photographs of nude underage girls, some of which

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<v Speaker 1>may have been taken with hidden cameras set up in

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<v Speaker 1>his residence in Palm Beach On the day of defendant's arrest,

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<v Speaker 1>police found two hidden cameras and photographs of underage girls

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<v Speaker 1>indefendant's mansion. Defendant took lude photographs of plaintiff with his

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<v Speaker 1>hidden cameras and transported luded photographs of plaintiffs and other

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<v Speaker 1>victims elsewhere using a facility or a means of interstate

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<v Speaker 1>and foreign commerce. On one occasion, defendant manipulated the minor

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<v Speaker 1>plaintiff to posed nude for him and photographer using several

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<v Speaker 1>roles of film. One or more of those photographs of

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<v Speaker 1>plaintiff were taken by the defendant when she was a miner,

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<v Speaker 1>were confiscated by the pom Beach Police Department during its

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<v Speaker 1>execution of a search warrant of defendant's pom Beach mansion

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<v Speaker 1>on October twentieth, two thousand and five. Defendant was particularly

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<v Speaker 1>skillful at discerning his minor victims respect of hopes, dreams,

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<v Speaker 1>and ambitions, as he did with many of his victims.

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<v Speaker 1>Defendant lord plaintiff early on with modeling opportunities and pressing

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<v Speaker 1>her with his modeling business and contacts with supermodels, indicating

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<v Speaker 1>that he could help her with her modeling career, and

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<v Speaker 1>just interject right here, we're going to be talking about

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<v Speaker 1>Jean Luke Brunel in the coming days and about this

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<v Speaker 1>modeling agency MC squared. It's a very important part of

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<v Speaker 1>the story. Knowing that the minor plaintiff was an excellent

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<v Speaker 1>student and desire to attend NYU or Columbia University, defendant

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<v Speaker 1>pretended to show great interest in her college admission and

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<v Speaker 1>offered to help her with their application and to his

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<v Speaker 1>sister with her tuition. Defendant had all plaintiff of his

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<v Speaker 1>substantial connections within the academic community, a matter about which

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<v Speaker 1>he often bragged. Defendant took it upon himself to take

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<v Speaker 1>control of plaintiff's college application process and led plaintiff to

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<v Speaker 1>believe that he was sincere about helping her. Even though

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<v Speaker 1>that she had earned a Bright Future scholarship to the

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<v Speaker 1>Florida college of her choice, defendant insisted that she would

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<v Speaker 1>not need it and that with his involvement, she would

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<v Speaker 1>be admitted into one or both of the universities in

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<v Speaker 1>New York. As a result of the defendant's manipulation, plaintiff

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<v Speaker 1>did not apply timely for the Bright Future scholarship or

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<v Speaker 1>to any college, and therefore missed the fall semester of

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<v Speaker 1>her freshman year when the Palm Beach Police Department executed

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<v Speaker 1>the search warrant on defendant's mansion. Among the artifacts found

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<v Speaker 1>and confiscated were plaintiff's highchool transcript. In June of two

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<v Speaker 1>thousand and eight, after an investigation by the Palm Beach

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<v Speaker 1>Police Department, the State Attorney's Office, the Federal Bureau of Investigation,

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<v Speaker 1>and the United States Attorney's Office, defendant entered please of

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<v Speaker 1>guilty to one count of solicitation of prostitution in violation

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<v Speaker 1>of Florida Statute Section seven ninety six dot seven and

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<v Speaker 1>one count the solicitation of a minor to engage in

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<v Speaker 1>prostitution in violation of Florida Statutes seven ninety six three

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<v Speaker 1>in the fifteenth Judicial Circuit in Palm Beach County, Florida.

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<v Speaker 1>As a condition of that plea defendant entered into a

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<v Speaker 1>non Prosecution Agreement addendum an affirmation collectively the NPA with

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<v Speaker 1>the United States Attorney's Office for the Southern District of

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<v Speaker 1>Florida on September twenty fourth, two thousand and seven, October

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<v Speaker 1>twenty ninth, two thousand and seven, and December seventh, two

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<v Speaker 1>thousand and seven, respectively. In doing so, defendant acknowledged that

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<v Speaker 1>plaintiff was one of his victims and agreed to the

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<v Speaker 1>following provisions of the MPa. If any of my acknowledged

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<v Speaker 1>victims elects to file suit pursuant to US Code eighteen,

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<v Speaker 1>section twenty two to fifty five, Epstein will not contest

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<v Speaker 1>the jurisdiction of the United States District Court for the

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<v Speaker 1>Southern District of Florida over his person and or subject

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<v Speaker 1>matter and damages up to an amount agreed upon between

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<v Speaker 1>the identified individual and Epstein, as long as the identified

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<v Speaker 1>individual elects to proceed exclusively under US Code section twenty

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<v Speaker 1>two to fifty five and agrees to waive any other

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<v Speaker 1>claim for damages, whether pursuanto state, federal, or common law,

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<v Speaker 1>except to those individuals who elect to proceed exclusively under

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<v Speaker 1>US Code eighteen, section twenty two to fifty five. Has

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<v Speaker 1>set a fourth in paragraph eight Supra. Neither Epstein's signature

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<v Speaker 1>on this agreement, nor its terms, nor its resulting waivers

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<v Speaker 1>or settlements by Epstein are to be construed as admissions

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<v Speaker 1>of evidence or evidence of civil or criminal liability, or

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<v Speaker 1>a way any jurisdictional or other defense as to any person,

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<v Speaker 1>whether or not her name appears on the list provided

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<v Speaker 1>by the United States. Plaintiff was among the individuals identified

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<v Speaker 1>by the United States Attorney's Office as victims of defendant

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<v Speaker 1>upon whose testimony it intended to base its federal prosecution

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<v Speaker 1>of defendant for his legal conduct. Consequently, defendant is the

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<v Speaker 1>stopped by a state court plea and the non prosecution

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<v Speaker 1>agreement from denying the acts alleged in this complaint and

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<v Speaker 1>must effectively admit liability to plaintiff Jane Doe Number one

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<v Speaker 1>oh three cause of action for coercion and enticement of

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<v Speaker 1>a minor to engage in prostitution or a sexual activity

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<v Speaker 1>pursuant to US Code eighteen, section twenty two fifty five

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<v Speaker 1>in violation of US Code eighteen, Section twenty four to

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<v Speaker 1>twenty two B. Plaintiff hereby adopts, repeats, re alleges, and

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<v Speaker 1>incorporates by reference the allegations contained in paragraphs one through

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<v Speaker 1>twenty six above. Defendant used a facility or means of

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<v Speaker 1>interstate and or foreign commerce to knowingly persuade, induce, entice,

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<v Speaker 1>or coerce plaintiff when she was under the age of eighteen,

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<v Speaker 1>to engage in prostitution and or sexual activity for which

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<v Speaker 1>any person can be charged with a criminal offense or

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<v Speaker 1>attempted to do so pursu into US Code eighteen, section

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<v Speaker 1>twenty two to fifty five. In violation of US Code

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<v Speaker 1>eighteen Section twenty four to twenty two b, plaintiff was

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<v Speaker 1>a victim of one or more offenses enumerated in US

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<v Speaker 1>Code section twenty two to fifty five, and as such

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<v Speaker 1>asserts a cause of action against defendant pursuant to this

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<v Speaker 1>section of the United States Code. As a direct and

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<v Speaker 1>proximate result of the offenses enumerated in US Code eighteen,

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<v Speaker 1>section twenty two to fifty five being committed against the

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<v Speaker 1>then minor plaintiff by defendant, Plaintiff has in the past

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<v Speaker 1>suffered and will in the future continue to suffer physical injury,

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<v Speaker 1>pain and suffering, emotional dist psychological and or psychiatric trauma,

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<v Speaker 1>mental anguish, humiliation, confusion, embarrassment, loss of educational opportunity, loss

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<v Speaker 1>of self esteem, loss of dignity, invasion of her privacy,

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<v Speaker 1>separation from her family, and other damages associated with defendant

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<v Speaker 1>manipulating and luring her into a perverse and unhealthy way

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<v Speaker 1>of life. The then minor plaintiff incurred medical and psychological expenses,

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<v Speaker 1>and plaintiff will in the future. In co additional medical

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<v Speaker 1>and psychological expenses, Plaintiff is suffered a loss of income,

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<v Speaker 1>a loss of the capacity to earn income in the future,

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<v Speaker 1>and a loss of capacity to enjoy life. These injuries

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<v Speaker 1>are permanent in nature, and plaintiff will continue to suffer

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<v Speaker 1>the losses in the future. Wherefore, a plaintiff demands judgment

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<v Speaker 1>against defendant for all damages available under US Code eighteen,

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<v Speaker 1>section twenty two fifty five, including without limitations, actual and

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<v Speaker 1>compensatory de images, attorney fees, cost of suit, and such

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<v Speaker 1>other relief as this Court deems just and proper, and

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<v Speaker 1>hereby demands trial by jury on all issues triable as

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<v Speaker 1>a right by a jury. Count two Cause of action

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<v Speaker 1>for travel with intent to engage an illicit sexual conduct

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<v Speaker 1>pursuant to US Code eighteen section twenty two to fifty

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<v Speaker 1>five in violation of US Code eighteen Section twenty four

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<v Speaker 1>to twenty three B. Plaintiff hereby adopts repeats three alleges

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<v Speaker 1>and incorporates by reference the allegations contained in paragraphs one

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<v Speaker 1>through twenty six above. Defendant traveled in interstate and or

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<v Speaker 1>of foreign commerce for the purpose of engaging in illicit

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<v Speaker 1>sexual conduct as defined in US Code eighteen, section twenty

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<v Speaker 1>four to twenty three F with minor females, including the

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<v Speaker 1>then minor plaintiff in violation of US Code eighteen section

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<v Speaker 1>twenty four to twenty three B. Plaintiff was a victim

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<v Speaker 1>of one or more offensive enumerated in US US Code eighteen,

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<v Speaker 1>section twenty two to fifty five, and as such asserts

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<v Speaker 1>a cause of action against defendant pursuant to this section

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<v Speaker 1>of the United States Code. As a direct and approximate

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<v Speaker 1>result of the offenses enumerated in US Code eighteen, section

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<v Speaker 1>twenty two fifty five being committed against the then minor

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<v Speaker 1>plaintiff by defendant, Plaintiff has in the past suffered and

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<v Speaker 1>will in the future continue to suffer physical injury, pen

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<v Speaker 1>and suffering, emotional distress, psychological and or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,

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<v Speaker 1>loss of educational opportunity, loss of self esteem, loss of dignity,

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<v Speaker 1>invasion of her privacy, separation from her family, and other

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<v Speaker 1>damages associated with defendants manipulating and luring her into a

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<v Speaker 1>perverse and unhealthy way of life. The then minor. Plaintiff

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<v Speaker 1>incurred medical and psychological expenses, and Plaintiff will in the

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<v Speaker 1>future incur additional medical and psychological expenses. Plaintiff has suffered

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<v Speaker 1>a loss of income, a loss of the capacity to

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<v Speaker 1>earn income in the future, and a loss of capacity

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<v Speaker 1>to enjoy life. These injuries are permanent in nature, and

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<v Speaker 1>plaintiff will continue to suffer these losses in the future. Wherefore,

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<v Speaker 1>Plaintiff demands judgment against defendant for all damages available under

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<v Speaker 1>US Code eighteen, Section twenty two fifty five, including without limitation,

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<v Speaker 1>actual and competsratory damages, attorney fees, cost of suit, and

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<v Speaker 1>such other further relief as this Court deems just and proper,

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<v Speaker 1>and hereby demands trial by jury on all issues triable

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<v Speaker 1>as the right by a jury. All right, we're going

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<v Speaker 1>to wrap up right here, and in the next episode,

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<v Speaker 1>we're going to pick up with account number three. All

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<v Speaker 1>of the information that goes with this episode can be

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<v Speaker 1>found in the description box.
