Speaker 1: What's up, everyone, and welcome to another episode of the
Speaker 1: Epstein Chronicles. In this episode, we're going to get right
Speaker 1: back to Jane Doe one oh six and her allegations
Speaker 1: against Jeffrey Epstein. A similar pattern of grooming continued and
Speaker 1: the sexual exploitation progressively escalated over the course of approximately
Speaker 1: seventeen months, during which defendant would often travel to Palm Beach.
Speaker 1: Prior to arriving, and while in Palm Beach, Defendant and
Speaker 1: or his agents would frequently call plaintiff at her home
Speaker 1: telephone number and or other telephone numbers, arranging for encounters
Speaker 1: with her for defendant, sometimes twice daily. While usually such
Speaker 1: contacts were made by his assistants, Defendant personally called plaintiff
Speaker 1: repeatedly despite being told to leave plaintiff alone. After the
Speaker 1: first few encounters, Defendant core's plaintiff to remove all her clothing,
Speaker 1: and Defendant penetrated minor plaintiffs vagina digitally. Defendant sexually abused
Speaker 1: and or battered and or exploited plaintiff at least one
Speaker 1: hundred times between approximately January two thousand and four and
Speaker 1: May two thousand and five. Such exploitation included, but was
Speaker 1: not limited to defendant sexual abuse and battery of plaintiff
Speaker 1: with vibrators, back massager, his fingers, and his penis. At times,
Speaker 1: defendant manipulated plaintiff to interact sexually with another female. During
Speaker 1: one encounter, defendant penetrated the minor plaintiff's vagino with his penis,
Speaker 1: all while narrating and demonstrating his sexual battery of plaintiff
Speaker 1: to another female president in the room. While some of
Speaker 1: the precise dates that defendants' acts of sexual exploitation occurred
Speaker 1: are unknown to plaintiff, these dates are known to defendant
Speaker 1: as he and or his assistants kept written records, some
Speaker 1: of which are in the custody of law enforcement, of
Speaker 1: each instance in which he committed lout acts upon minor girls,
Speaker 1: including the then minor a plaintiff. So, if you're looking
Speaker 1: for a list, how about we get this? Huh? Is
Speaker 1: anybody going to explore what's going on here? Or are
Speaker 1: we just going to be told to move on. Defendant's
Speaker 1: preference for underage girls was well known to those who
Speaker 1: regularly procured them for him. The above described acts of
Speaker 1: abuse began to occur during a time when defendant knew
Speaker 1: that plaintiff was a minor. Defendant at all times material
Speaker 1: to this cause of action knew and or should have
Speaker 1: known that plaintiff's age of minority. In fact, Defendant repeatedly
Speaker 1: urged the minor plaintiff to become legally emancipated in order
Speaker 1: to accompany him as he traveled both nationally and internationally. Additionally, Defendant,
Speaker 1: knowing that plaintiff was merely seventeen years old, lured her
Speaker 1: by inviting her to stay with them in his mansion
Speaker 1: in Manhattan and or arranging and paying for airplane tickets,
Speaker 1: theater tickets, and a personal chauffeur as gifts for her
Speaker 1: upcoming birthday. As part of defendant's persistent process of grooming
Speaker 1: plaintiff and a mersinger in his lude and abusive lifestyle,
Speaker 1: Defendant regularly showered the adolescent plaintiff with gifts, including, but
Speaker 1: not limited to, lingerie flowers, bikini bathing suits, art books, purses,
Speaker 1: envelopes of US currency, use of a car, and other accouterments.
Speaker 1: Defendant possessed photographs of nude underage girls, some of which
Speaker 1: may have been taken with hidden cameras set up in
Speaker 1: his residence in Palm Beach On the day of defendant's arrest,
Speaker 1: police found two hidden cameras and photographs of underage girls
Speaker 1: indefendant's mansion. Defendant took lude photographs of plaintiff with his
Speaker 1: hidden cameras and transported luded photographs of plaintiffs and other
Speaker 1: victims elsewhere using a facility or a means of interstate
Speaker 1: and foreign commerce. On one occasion, defendant manipulated the minor
Speaker 1: plaintiff to posed nude for him and photographer using several
Speaker 1: roles of film. One or more of those photographs of
Speaker 1: plaintiff were taken by the defendant when she was a miner,
Speaker 1: were confiscated by the pom Beach Police Department during its
Speaker 1: execution of a search warrant of defendant's pom Beach mansion
Speaker 1: on October twentieth, two thousand and five. Defendant was particularly
Speaker 1: skillful at discerning his minor victims respect of hopes, dreams,
Speaker 1: and ambitions, as he did with many of his victims.
Speaker 1: Defendant lord plaintiff early on with modeling opportunities and pressing
Speaker 1: her with his modeling business and contacts with supermodels, indicating
Speaker 1: that he could help her with her modeling career, and
Speaker 1: just interject right here, we're going to be talking about
Speaker 1: Jean Luke Brunel in the coming days and about this
Speaker 1: modeling agency MC squared. It's a very important part of
Speaker 1: the story. Knowing that the minor plaintiff was an excellent
Speaker 1: student and desire to attend NYU or Columbia University, defendant
Speaker 1: pretended to show great interest in her college admission and
Speaker 1: offered to help her with their application and to his
Speaker 1: sister with her tuition. Defendant had all plaintiff of his
Speaker 1: substantial connections within the academic community, a matter about which
Speaker 1: he often bragged. Defendant took it upon himself to take
Speaker 1: control of plaintiff's college application process and led plaintiff to
Speaker 1: believe that he was sincere about helping her. Even though
Speaker 1: that she had earned a Bright Future scholarship to the
Speaker 1: Florida college of her choice, defendant insisted that she would
Speaker 1: not need it and that with his involvement, she would
Speaker 1: be admitted into one or both of the universities in
Speaker 1: New York. As a result of the defendant's manipulation, plaintiff
Speaker 1: did not apply timely for the Bright Future scholarship or
Speaker 1: to any college, and therefore missed the fall semester of
Speaker 1: her freshman year when the Palm Beach Police Department executed
Speaker 1: the search warrant on defendant's mansion. Among the artifacts found
Speaker 1: and confiscated were plaintiff's highchool transcript. In June of two
Speaker 1: thousand and eight, after an investigation by the Palm Beach
Speaker 1: Police Department, the State Attorney's Office, the Federal Bureau of Investigation,
Speaker 1: and the United States Attorney's Office, defendant entered please of
Speaker 1: guilty to one count of solicitation of prostitution in violation
Speaker 1: of Florida Statute Section seven ninety six dot seven and
Speaker 1: one count the solicitation of a minor to engage in
Speaker 1: prostitution in violation of Florida Statutes seven ninety six three
Speaker 1: in the fifteenth Judicial Circuit in Palm Beach County, Florida.
Speaker 1: As a condition of that plea defendant entered into a
Speaker 1: non Prosecution Agreement addendum an affirmation collectively the NPA with
Speaker 1: the United States Attorney's Office for the Southern District of
Speaker 1: Florida on September twenty fourth, two thousand and seven, October
Speaker 1: twenty ninth, two thousand and seven, and December seventh, two
Speaker 1: thousand and seven, respectively. In doing so, defendant acknowledged that
Speaker 1: plaintiff was one of his victims and agreed to the
Speaker 1: following provisions of the MPa. If any of my acknowledged
Speaker 1: victims elects to file suit pursuant to US Code eighteen,
Speaker 1: section twenty two to fifty five, Epstein will not contest
Speaker 1: the jurisdiction of the United States District Court for the
Speaker 1: Southern District of Florida over his person and or subject
Speaker 1: matter and damages up to an amount agreed upon between
Speaker 1: the identified individual and Epstein, as long as the identified
Speaker 1: individual elects to proceed exclusively under US Code section twenty
Speaker 1: two to fifty five and agrees to waive any other
Speaker 1: claim for damages, whether pursuanto state, federal, or common law,
Speaker 1: except to those individuals who elect to proceed exclusively under
Speaker 1: US Code eighteen, section twenty two to fifty five. Has
Speaker 1: set a fourth in paragraph eight Supra. Neither Epstein's signature
Speaker 1: on this agreement, nor its terms, nor its resulting waivers
Speaker 1: or settlements by Epstein are to be construed as admissions
Speaker 1: of evidence or evidence of civil or criminal liability, or
Speaker 1: a way any jurisdictional or other defense as to any person,
Speaker 1: whether or not her name appears on the list provided
Speaker 1: by the United States. Plaintiff was among the individuals identified
Speaker 1: by the United States Attorney's Office as victims of defendant
Speaker 1: upon whose testimony it intended to base its federal prosecution
Speaker 1: of defendant for his legal conduct. Consequently, defendant is the
Speaker 1: stopped by a state court plea and the non prosecution
Speaker 1: agreement from denying the acts alleged in this complaint and
Speaker 1: must effectively admit liability to plaintiff Jane Doe Number one
Speaker 1: oh three cause of action for coercion and enticement of
Speaker 1: a minor to engage in prostitution or a sexual activity
Speaker 1: pursuant to US Code eighteen, section twenty two fifty five
Speaker 1: in violation of US Code eighteen, Section twenty four to
Speaker 1: twenty two B. Plaintiff hereby adopts, repeats, re alleges, and
Speaker 1: incorporates by reference the allegations contained in paragraphs one through
Speaker 1: twenty six above. Defendant used a facility or means of
Speaker 1: interstate and or foreign commerce to knowingly persuade, induce, entice,
Speaker 1: or coerce plaintiff when she was under the age of eighteen,
Speaker 1: to engage in prostitution and or sexual activity for which
Speaker 1: any person can be charged with a criminal offense or
Speaker 1: attempted to do so pursu into US Code eighteen, section
Speaker 1: twenty two to fifty five. In violation of US Code
Speaker 1: eighteen Section twenty four to twenty two b, plaintiff was
Speaker 1: a victim of one or more offenses enumerated in US
Speaker 1: Code section twenty two to fifty five, and as such
Speaker 1: asserts a cause of action against defendant pursuant to this
Speaker 1: section of the United States Code. As a direct and
Speaker 1: proximate result of the offenses enumerated in US Code eighteen,
Speaker 1: section twenty two to fifty five being committed against the
Speaker 1: then minor plaintiff by defendant, Plaintiff has in the past
Speaker 1: suffered and will in the future continue to suffer physical injury,
Speaker 1: pain and suffering, emotional dist psychological and or psychiatric trauma,
Speaker 1: mental anguish, humiliation, confusion, embarrassment, loss of educational opportunity, loss
Speaker 1: of self esteem, loss of dignity, invasion of her privacy,
Speaker 1: separation from her family, and other damages associated with defendant
Speaker 1: manipulating and luring her into a perverse and unhealthy way
Speaker 1: of life. The then minor plaintiff incurred medical and psychological expenses,
Speaker 1: and plaintiff will in the future. In co additional medical
Speaker 1: and psychological expenses, Plaintiff is suffered a loss of income,
Speaker 1: a loss of the capacity to earn income in the future,
Speaker 1: and a loss of capacity to enjoy life. These injuries
Speaker 1: are permanent in nature, and plaintiff will continue to suffer
Speaker 1: the losses in the future. Wherefore, a plaintiff demands judgment
Speaker 1: against defendant for all damages available under US Code eighteen,
Speaker 1: section twenty two fifty five, including without limitations, actual and
Speaker 1: compensatory de images, attorney fees, cost of suit, and such
Speaker 1: other relief as this Court deems just and proper, and
Speaker 1: hereby demands trial by jury on all issues triable as
Speaker 1: a right by a jury. Count two Cause of action
Speaker 1: for travel with intent to engage an illicit sexual conduct
Speaker 1: pursuant to US Code eighteen section twenty two to fifty
Speaker 1: five in violation of US Code eighteen Section twenty four
Speaker 1: to twenty three B. Plaintiff hereby adopts repeats three alleges
Speaker 1: and incorporates by reference the allegations contained in paragraphs one
Speaker 1: through twenty six above. Defendant traveled in interstate and or
Speaker 1: of foreign commerce for the purpose of engaging in illicit
Speaker 1: sexual conduct as defined in US Code eighteen, section twenty
Speaker 1: four to twenty three F with minor females, including the
Speaker 1: then minor plaintiff in violation of US Code eighteen section
Speaker 1: twenty four to twenty three B. Plaintiff was a victim
Speaker 1: of one or more offensive enumerated in US US Code eighteen,
Speaker 1: section twenty two to fifty five, and as such asserts
Speaker 1: a cause of action against defendant pursuant to this section
Speaker 1: of the United States Code. As a direct and approximate
Speaker 1: result of the offenses enumerated in US Code eighteen, section
Speaker 1: twenty two fifty five being committed against the then minor
Speaker 1: plaintiff by defendant, Plaintiff has in the past suffered and
Speaker 1: will in the future continue to suffer physical injury, pen
Speaker 1: and suffering, emotional distress, psychological and or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
Speaker 1: loss of educational opportunity, loss of self esteem, loss of dignity,
Speaker 1: invasion of her privacy, separation from her family, and other
Speaker 1: damages associated with defendants manipulating and luring her into a
Speaker 1: perverse and unhealthy way of life. The then minor. Plaintiff
Speaker 1: incurred medical and psychological expenses, and Plaintiff will in the
Speaker 1: future incur additional medical and psychological expenses. Plaintiff has suffered
Speaker 1: a loss of income, a loss of the capacity to
Speaker 1: earn income in the future, and a loss of capacity
Speaker 1: to enjoy life. These injuries are permanent in nature, and
Speaker 1: plaintiff will continue to suffer these losses in the future. Wherefore,
Speaker 1: Plaintiff demands judgment against defendant for all damages available under
Speaker 1: US Code eighteen, Section twenty two fifty five, including without limitation,
Speaker 1: actual and competsratory damages, attorney fees, cost of suit, and
Speaker 1: such other further relief as this Court deems just and proper,
Speaker 1: and hereby demands trial by jury on all issues triable
Speaker 1: as the right by a jury. All right, we're going
Speaker 1: to wrap up right here, and in the next episode,
Speaker 1: we're going to pick up with account number three. All
Speaker 1: of the information that goes with this episode can be
Speaker 1: found in the description box.