1 00:00:00,320 --> 00:00:04,519 Speaker 1: What's up everyone, and welcome back to the Epstein Chronicles. 2 00:00:04,559 --> 00:00:07,200 In this episode, we're diving right back in to the 3 00:00:07,280 --> 00:00:13,240 Jennifer ARREOs complaint against the Jeffrey Epstein State number forty 4 00:00:13,320 --> 00:00:17,480 nine at all times relevant to plaintiffs fraudulent conveyance claims. 5 00:00:17,760 --> 00:00:24,000 Defendant LSJLLC is and was the limited liability company owned 6 00:00:24,000 --> 00:00:27,879 by Jeffrey Epstein, formed and organized under the laws of 7 00:00:27,920 --> 00:00:31,559 the State of Delaware, with its principal address at sixty 8 00:00:31,559 --> 00:00:35,759 one hundred Red Hood, Quarter B three, Saint Thomas, Virgin Islands, 9 00:00:36,359 --> 00:00:39,320 which is the entity under which a high speed thirty 10 00:00:39,359 --> 00:00:44,240 seven foot runabout motor vessel builder hull number mx J 11 00:00:44,679 --> 00:00:50,880 thirty seven zero five three F five eight five was registered, and, 12 00:00:51,000 --> 00:00:55,439 upon information and belief, additional aircraft, motor vehicles and door 13 00:00:55,520 --> 00:00:59,920 boats are also registered number fifty at all times red 14 00:01:00,000 --> 00:01:04,840 relevant to Plaintiff's fraudulent conveyance claims. Zoro Management, LLC is 15 00:01:04,879 --> 00:01:08,760 a New Mexico foreign limited liability company with a principal 16 00:01:08,760 --> 00:01:12,319 address located at nine zero five to three A State 17 00:01:12,400 --> 00:01:16,439 Thomas Sweet one oh one, Saint Thomas, Virgin Islands, which 18 00:01:16,519 --> 00:01:19,959 was owned and managed by Jeffrey Epstein. And which held 19 00:01:20,000 --> 00:01:23,400 cash and assets that belonged to the estate of Jeffrey 20 00:01:23,400 --> 00:01:28,120 Epstein until being fraudulently transferred to the nineteen fifty three 21 00:01:28,200 --> 00:01:33,400 trust forty eight hours before Epstein committed suicide fifty one 22 00:01:33,519 --> 00:01:37,599 at all times relevant to Plaintiff's fraudulent conveyance claims. Defendant 23 00:01:37,799 --> 00:01:43,400 igy AHY Saint Thomas Holdings, LLC. American Yacht Harbor, which 24 00:01:43,439 --> 00:01:46,200 does business as American Yacht Harbor, a port in the 25 00:01:46,239 --> 00:01:50,200 Virgin Islands that has slips for yachts, sailboats, and pleasure crafts, 26 00:01:50,560 --> 00:01:53,560 as well as strip malls of offices, was fifty percent 27 00:01:53,599 --> 00:01:58,239 owned by Jeffrey Epstein. Fifty two. Plaintiff intends to amend 28 00:01:58,480 --> 00:02:03,000 this complaint to add or substitute additional parties as discovery 29 00:02:03,079 --> 00:02:07,680 reveals the identities of other negligent corporate or individual actors. 30 00:02:08,240 --> 00:02:13,240 Fifty three. Jeffrey Epstein was an officer, director, or employee 31 00:02:13,479 --> 00:02:17,680 of many corporate entities and trust registered in various states 32 00:02:18,080 --> 00:02:21,039 throughout the United States, any one of which may also 33 00:02:21,120 --> 00:02:25,080 bear legal responsibility for the crimes he committed against plaintiff 34 00:02:25,599 --> 00:02:29,719 fifty four. Additionally, individuals who worked at Epstein's and y 35 00:02:29,800 --> 00:02:33,680 residents where he committed sexual violations against plaintiff, as well 36 00:02:33,719 --> 00:02:38,199 as others who assisted him in committing such violations, were employed, through, 37 00:02:38,639 --> 00:02:43,199 or worked for numerous other corporate entities, private foundations, and 38 00:02:43,240 --> 00:02:48,240 trusts whose negligence and or intentional tortious conduct caused or 39 00:02:48,280 --> 00:02:52,000 contributed to the sexual violations that caused harm to plaintiff. 40 00:02:52,719 --> 00:02:57,120 Fifty five. The complete realm of those individuals and companies 41 00:02:57,280 --> 00:03:01,319 whose negligence or intentional acts contribute to the sexual crimes 42 00:03:01,520 --> 00:03:06,520 committed by Jeffrey Epstein against Plaintiff a minor are currently unknown. 43 00:03:07,039 --> 00:03:11,319 Fifty six. As Plaintiff learned through discovery the identities of 44 00:03:11,319 --> 00:03:15,879 additional individuals or corporate entities and the way those others 45 00:03:15,960 --> 00:03:20,120 caused or contributed to causing harm to plaintiff through negligence 46 00:03:20,159 --> 00:03:24,039 and or intentional acts, Plaintiff intends to amend this complaint 47 00:03:24,319 --> 00:03:27,719 to add those parties as well. Should discovery reveal that 48 00:03:27,759 --> 00:03:31,199 any of the currently named defendants are not the proper 49 00:03:31,199 --> 00:03:35,479 identity of the individuals or companies identified as current defendants, 50 00:03:35,759 --> 00:03:40,199 substitution of parties shall be requested to ensure accuracy and 51 00:03:40,240 --> 00:03:45,439 correctness of pleading Number fifty seven. Jeffrey Epstein committed repeated 52 00:03:45,479 --> 00:03:49,199 acts of sexual assault and battery upon Miss Areos while 53 00:03:49,240 --> 00:03:52,080 she was a fourteen fifteen year old high school student, 54 00:03:52,319 --> 00:03:57,560 including forcibly raping Missoreos. As such, Jeffrey Epstein has committed 55 00:03:57,560 --> 00:04:02,560 sexual assault, sexual battery, intendstional infliction of emotional distress, and 56 00:04:02,639 --> 00:04:07,319 negligent infliction of emotional distress Pursuant to New York common law. 57 00:04:07,840 --> 00:04:12,080 The damage Jeffrey Epstein inflicted upon plaintiff has been severe 58 00:04:12,319 --> 00:04:17,279 and lasting fifty eight Upon information and belief, Miss Maxwell, 59 00:04:17,439 --> 00:04:21,399 Miss Groff, Miss Espinoza, the recruiter, Miss Fontanea, and the 60 00:04:21,439 --> 00:04:26,800 corporate defendants and institutional defendants, The co conspirators participated with 61 00:04:27,079 --> 00:04:31,759 and assisted Epstein in maintaining and protecting his sex trafficking ring, 62 00:04:32,199 --> 00:04:35,720 ensuring that approximately three girls a day were made available 63 00:04:35,800 --> 00:04:40,079 to him for his sexual pleasure. The co conspirators provided 64 00:04:40,199 --> 00:04:44,839 organizational support to epstein sex trafficking ring, identifying and hiring 65 00:04:44,879 --> 00:04:49,399 the recruiters of underage girls for Epstein's sexual pleasure, scheduling 66 00:04:49,399 --> 00:04:54,480 appointments with these underage girls for Epstein's sexual pleasure, intimidating 67 00:04:54,480 --> 00:04:59,319 potential witnesses to epstein sex trafficking operation. And generally providing 68 00:04:59,319 --> 00:05:04,160 administrative oversight of a sex trafficking operation and ensuring it 69 00:05:04,240 --> 00:05:08,680 remained secret. Upon information and belief, the co conspirators conspired 70 00:05:08,720 --> 00:05:11,839 with Epstein in the implementation and the maintenance of his 71 00:05:11,879 --> 00:05:17,079 criminal enterprise, which in turn victimized Missus Areos fifty nine. 72 00:05:17,920 --> 00:05:21,720 Venue is proper in that all the illegal conduct described 73 00:05:21,759 --> 00:05:26,240 herein occurred within New York County sixty at all times 74 00:05:26,279 --> 00:05:30,920 relevant herein, Jeffrey Epstein legally represented now through Darren k 75 00:05:31,160 --> 00:05:34,879 Endyke and Richard D. Con as executors of the estate 76 00:05:35,000 --> 00:05:39,279 of Jeffrey E. Epstein, and the co conspirators owed a 77 00:05:39,319 --> 00:05:42,240 duty to plaintiff to treat her in a non negligent 78 00:05:42,319 --> 00:05:45,519 manner and not to commit or conspire to commit, or 79 00:05:45,639 --> 00:05:49,759 cause to be committed intentional, criminal, fraudulent, or tortious acts 80 00:05:49,839 --> 00:05:53,360 against plaintiff, including any acts that would cause plaintiff to 81 00:05:53,399 --> 00:05:57,680 be harmed through conduct committed against her in violation of 82 00:05:57,920 --> 00:06:01,360 New York Penal Law one point thirty New York Penal 83 00:06:01,439 --> 00:06:04,360 Law one thirty dot twenty five, New York Penal Law 84 00:06:04,439 --> 00:06:07,439 one thirty dot thirty five New York Penal Law one 85 00:06:07,560 --> 00:06:10,920 thirty dot fifty two or New York Penal Law sixty 86 00:06:10,959 --> 00:06:14,240 five or New York Penal Law one thirty dot sixty seven, 87 00:06:15,120 --> 00:06:20,399 Part three Factual allegations sixty one at all times relevant herein, 88 00:06:20,600 --> 00:06:24,079 Jeffrey Epstein was an adult male over forty eight years old. 89 00:06:24,480 --> 00:06:28,040 Epstein was extremely wealthy, and he was a financier. He 90 00:06:28,120 --> 00:06:31,639 used his wealth, his power, his resources, and connections to 91 00:06:31,639 --> 00:06:35,319 commit illegal sexual crimes in violation of Article one thirty 92 00:06:35,560 --> 00:06:39,319 and to employ and conspire with other individuals, corporate entities, 93 00:06:39,759 --> 00:06:43,240 private foundations, and trusts to assist them in committing those 94 00:06:43,279 --> 00:06:47,319 sexual crimes or torts, or to facilitate or enable those 95 00:06:47,360 --> 00:06:52,160 acts to occur. Sixty two. Epstein displayed his enormous wealth, 96 00:06:52,240 --> 00:06:55,600 power and influence to his employees, to the employees of 97 00:06:55,639 --> 00:06:59,759 the corporate entities, private foundations and trusts who worked at 98 00:06:59,759 --> 00:07:03,959 his den to the victims procured for sexual purposes, and 99 00:07:04,000 --> 00:07:06,879 to the public in order to advance and carry out 100 00:07:07,079 --> 00:07:11,079 and conceal his crimes and torts. Sixty three at all 101 00:07:11,120 --> 00:07:15,160 times relevant Herein, Epstein had access to numerous mansions, a 102 00:07:15,199 --> 00:07:20,360 fleet of aeroplanes, motor vehicles, boats, and several helicopters. Sixty 103 00:07:20,399 --> 00:07:24,839 four at all times relevant herein Jeffrey Epstein traveled between 104 00:07:25,000 --> 00:07:29,639 and frequently inhabited and traveled between numerous properties and homes, 105 00:07:29,680 --> 00:07:33,560 including a Manhattan town home located at ninety seventy First 106 00:07:33,560 --> 00:07:37,959 Street in New York, valued conservatively by Jeffrey Epstein's owned 107 00:07:37,959 --> 00:07:41,079 admission at fifty five million, nine hundred and thirty one 108 00:07:41,079 --> 00:07:45,959 thousand dollars, a ranch located at forty nine Zoro Ranch Road, Stanley, 109 00:07:46,000 --> 00:07:50,519 New Mexico, valued conservatively by Jeffrey Epstein's owned admission at 110 00:07:50,560 --> 00:07:54,000 seventeen million, two hundred and forty six thousand, two hundred 111 00:07:54,000 --> 00:07:57,319 and eight dollars, a home located at three fifty eight 112 00:07:57,439 --> 00:08:01,959 Lbrio Way, Palm Beach, Florida, value conservatively by Jeffrey Epstein's 113 00:08:01,959 --> 00:08:05,439 own admission at twelve million, three hundred and eighty thousand, 114 00:08:05,560 --> 00:08:09,600 two hundred and nine dollars, an apartment located at twenty 115 00:08:09,600 --> 00:08:14,439 two Avenue Folk, Paris, France, valued conservatively by Jeffrey Epstein's 116 00:08:14,480 --> 00:08:18,079 own admission at eight million, six hundred and seventy two thousand, 117 00:08:18,360 --> 00:08:21,680 eight hundred and twenty dollars, and an island, Little Saint 118 00:08:21,759 --> 00:08:27,480 James Island number six b USVII zero zero eight zero two, A, B, 119 00:08:27,639 --> 00:08:32,840 and C. Number sixty five. Jeffrey Epstein was otherwise affiliated 120 00:08:33,000 --> 00:08:36,000 with the corporations or trusts that owned or controlled each 121 00:08:36,039 --> 00:08:40,360 of the real properties listed in the preceding paragraph sixty six. 122 00:08:41,120 --> 00:08:45,519 The allegations herein primarily concerned Jeffrey Epstein's conduct while at 123 00:08:45,519 --> 00:08:49,919 his New York residence and concern the various individuals, corporate entities, 124 00:08:50,080 --> 00:08:54,240 private foundations, and trusts which provided the opportunity for his 125 00:08:54,320 --> 00:08:59,039 illicit conduct to occur and remain concealed for years. Sixty seven. 126 00:08:59,559 --> 00:09:02,919 Epstein and had a compulsive sexual preference for young females 127 00:09:03,120 --> 00:09:06,679 at least as young as fourteen years old. Sixty eight. 128 00:09:07,519 --> 00:09:11,559 Epstein enjoyed sexual contact with young females, including minor children, 129 00:09:11,720 --> 00:09:15,799 and took pleasure corrupting vulnerable young females, including minor children, 130 00:09:16,120 --> 00:09:20,720 into engaging in sexual acts with them. Sixty nine. Epstein 131 00:09:20,759 --> 00:09:26,039 directed a complex system of individuals, including employees and associates 132 00:09:26,200 --> 00:09:30,360 of corporate defendants and institutional defendants, to work in concert 133 00:09:30,799 --> 00:09:33,879 and at his direction, for the purpose of harming teenage 134 00:09:33,919 --> 00:09:38,679 girls through sexual exploitation and abuse Number seventy. It was 135 00:09:38,720 --> 00:09:43,279 widely known among individuals regularly in Epstein's presence that he 136 00:09:43,320 --> 00:09:47,240 got pleasure out of corrupting vulnerable young females into engaging 137 00:09:47,279 --> 00:09:53,440 in uncomfortable and unwanted sexual acts for his gratification seventy one. 138 00:09:54,200 --> 00:09:57,080 According to a ruling by US District Judge Kenneth Merra 139 00:09:57,399 --> 00:10:02,039 in February twenty nineteen, from between about nineteen ninety nine 140 00:10:02,759 --> 00:10:06,320 and two thousand and seven, Jeffrey Epstein sexually abused more 141 00:10:06,360 --> 00:10:09,879 than thirty minor girls at his mansion in Palm Beach, Florida, 142 00:10:10,039 --> 00:10:13,799 and elsewhere in the United States and the overseas. The 143 00:10:13,879 --> 00:10:17,639 ruling goes on describing a child sex ring. In addition 144 00:10:17,879 --> 00:10:21,480 to his own sexual abuse of the victims, Epstein directed 145 00:10:21,519 --> 00:10:25,480 other persons to abuse the girls sexually. Epstein used paid 146 00:10:25,480 --> 00:10:29,080 employees to find and bring minor girls to him. Epstein 147 00:10:29,120 --> 00:10:32,440 worked in concert with others to obtain miners not only 148 00:10:32,600 --> 00:10:35,840 for his own sexual gratification, but also for the sexual 149 00:10:35,879 --> 00:10:40,000 gratification of others. See Doe versus United States, three point 150 00:10:40,000 --> 00:10:44,559 fifty nine f Dot supp Dot three D twelve oh 151 00:10:44,600 --> 00:10:48,600 one twelve oh four Southern District of Florida, twenty nineteen 152 00:10:49,559 --> 00:10:54,279 seventy two. On July eighth, twenty nineteen, Jeffrey Epstein was 153 00:10:54,360 --> 00:11:00,320 arrested pursuing to the aforementioned indictment seventy four indictments stated 154 00:11:00,360 --> 00:11:03,960 in part that plaintiff herein adopts is true that, at 155 00:11:04,000 --> 00:11:08,639 all times relative to this indictment, Jeffrey Epstein, the defendant, 156 00:11:08,679 --> 00:11:12,360 possessed and controlled the multi story private residence on the 157 00:11:12,440 --> 00:11:15,480 Upper East Side of Manhattan, New York. The New York 158 00:11:15,519 --> 00:11:18,799 Residence between in or at least about two thousand and 159 00:11:18,799 --> 00:11:22,120 two and in or about two thousand and five, Epstein 160 00:11:22,159 --> 00:11:26,039 abused numerous minor victims at the New York residences by 161 00:11:26,120 --> 00:11:29,840 causing these victims to be recruited to engage in paid 162 00:11:29,919 --> 00:11:34,759 sex acts with them. Number seventy five. The indictment further stated, 163 00:11:35,159 --> 00:11:38,360 and plaintiff adopts as true, that when a victim arrived 164 00:11:38,360 --> 00:11:41,480 at the New York residence, she typically would be escorted 165 00:11:41,639 --> 00:11:44,399 to a room with a massage table, where she would 166 00:11:44,399 --> 00:11:48,440 perform a massage on Jeffrey Epstein, the defendant. The victims, 167 00:11:48,480 --> 00:11:50,759 who were as young as fourteen years of age, were 168 00:11:50,759 --> 00:11:54,759 told by Epstein or other individuals to partially or fully 169 00:11:54,840 --> 00:11:59,519 undress before beginning the massage. During the encounter, Epstein would 170 00:11:59,600 --> 00:12:02,679 escalate the nature and the scope of physical contact with 171 00:12:02,799 --> 00:12:06,200 his victim to include, among other things, sex acts such 172 00:12:06,200 --> 00:12:10,679 as groping and direct and indirect contact with the victims genitals. 173 00:12:11,039 --> 00:12:16,159 Epstein typically would masturbate during these sexualized encounters, ask victims 174 00:12:16,240 --> 00:12:19,720 to touch them while he masturbated and touched victims genitals 175 00:12:19,840 --> 00:12:25,480 with his hands. Number seventy six. The indictment further stated, 176 00:12:26,080 --> 00:12:29,840 and plaintiff adopts is true that, in connection with each 177 00:12:29,879 --> 00:12:33,600 sexual encounter, Jeffrey Epstein, the defendant, or one of his 178 00:12:33,679 --> 00:12:38,360 employees or associates, paid the victims in cash. Victims typically 179 00:12:38,600 --> 00:12:41,519 were paid hundreds of dollars in cash for each encounter. 180 00:12:42,320 --> 00:12:46,600 Seventy seven. The indictment further stated, and plaintiff adopts is 181 00:12:46,639 --> 00:12:49,879 true that Jeffrey Epstein the defendant knew that many of 182 00:12:49,919 --> 00:12:54,080 his New York victims were underage, including because certain victims 183 00:12:54,120 --> 00:12:58,679 told them their age. Further, once these minor victims were recruited, 184 00:12:59,000 --> 00:13:02,840 many were abused by Epstein on multiple subsequent occasions at 185 00:13:02,840 --> 00:13:07,200 the New York residence. Epstein sometimes personally contacted victims to 186 00:13:07,240 --> 00:13:11,240 schedule appointments at the New York residence. In other instances, 187 00:13:11,240 --> 00:13:15,919 Epstein directed employees and associates to communicate with victims via 188 00:13:16,000 --> 00:13:19,159 phone to arrange for these victims to return to the 189 00:13:19,200 --> 00:13:23,720 New York residence for additional sexual encounters with Epstein see 190 00:13:23,759 --> 00:13:28,200 criminal indictment at four and five seventy eight. Plaintiff was 191 00:13:28,240 --> 00:13:32,679 initially recruited under false pretenses and not informed that she 192 00:13:32,759 --> 00:13:37,200 would be asked to perform massages sexual or otherwise. Defendants 193 00:13:37,279 --> 00:13:41,840 enabled Jeffrey Epstein to receive near daily massages from young females, 194 00:13:42,080 --> 00:13:46,759 often miners, who were not experienced in massage. Rather than 195 00:13:46,799 --> 00:13:51,600 receive regular body massages, Epstein was predictably sexually abusing the 196 00:13:51,639 --> 00:13:57,480 young females in violation of Article one thirty seventy nine. Additionally, 197 00:13:57,919 --> 00:14:03,120 employees of the various corporate, defense and institutional defendants performed 198 00:14:03,159 --> 00:14:07,559 actions or in actions that further place victims, including plaintiff, 199 00:14:07,919 --> 00:14:11,559 in danger of being sexually abused by Epstein and assisted 200 00:14:11,600 --> 00:14:14,960 in the concealment of his sexually abusive acts. Number eighty 201 00:14:15,559 --> 00:14:19,279 defendants employed many recruiters of young females. The nature of 202 00:14:19,360 --> 00:14:24,480 Jeffrey Epstein's sex trafficking venture and enterprise enabled victims themselves 203 00:14:24,600 --> 00:14:27,279 to elevate their status to that of a paid recruiter 204 00:14:27,559 --> 00:14:31,039 of other victims, an elevation only made possible through the 205 00:14:31,120 --> 00:14:36,559 negligence of defendants eighty one. Recruiters were taught by employees 206 00:14:36,600 --> 00:14:42,639 of defendant to inform targeted victims that Epstein possessed extraordinary wealth, power, resources, 207 00:14:42,679 --> 00:14:46,120 and influence, and that he was a philanthropist who would 208 00:14:46,120 --> 00:14:51,000 help female victims advance their careers and their lives. Eighty two. 209 00:14:51,279 --> 00:14:55,519 The collaboration from defendants and the many employees fulfilled Epstein's 210 00:14:55,519 --> 00:14:59,000 compulsive need for sex with young females by praying on 211 00:14:59,080 --> 00:15:05,000 their personal, se echological, financial, and related vulnerabilities. Defendants tactics 212 00:15:05,000 --> 00:15:10,919 included promising the victim's money, shelter, transportation, gifts, employment, admission 213 00:15:11,080 --> 00:15:16,080 into educational institutions, educational tuition, protection, and other things of 214 00:15:16,159 --> 00:15:20,600 value in exchange for sex and concealment of Jeffrey Epstein's actions. 215 00:15:21,159 --> 00:15:25,919 Number eighty three. Jeffrey Epstein's sexual attraction to young, often 216 00:15:26,000 --> 00:15:29,080 underage females dated back to at least the mid nineties, 217 00:15:29,360 --> 00:15:32,720 and the number of victims increased substantially with the necessary 218 00:15:32,759 --> 00:15:37,559 assistance from the defendants and the defendants employees number eighty four. 219 00:15:38,200 --> 00:15:41,240 Defendants at the direction of Epstein, or in furtherance of 220 00:15:41,240 --> 00:15:45,320 his demands, and with help from assistance associates and underlings 221 00:15:45,559 --> 00:15:49,799 and even other victims, recruited or procured dozens, if not 222 00:15:49,799 --> 00:15:53,480 one hundreds of young females, including miners, for the purpose 223 00:15:53,639 --> 00:16:01,039 of Epstein's sexual gratification eighty five. Jeffrey Epstein and consequently 224 00:16:01,080 --> 00:16:06,799 the defendants specifically targeted underprivileged, emotionally vulnerable, and or economically 225 00:16:06,840 --> 00:16:13,080 disadvantaged young females to sexually molest and abuse eighty six. Additionally, 226 00:16:13,320 --> 00:16:17,519 the institutional defendants, through its employees, informed young females that 227 00:16:17,679 --> 00:16:21,759 Jeffrey was wealthy, well connected, and could either advance the 228 00:16:21,840 --> 00:16:27,480 career or education of any young female eighty seven. Plaintiff 229 00:16:27,799 --> 00:16:31,720 was among individuals identified by the United States Attorney's Office 230 00:16:31,919 --> 00:16:34,639 for the Southern District of New York as victims of 231 00:16:34,720 --> 00:16:38,960 Jeffrey Epstein and as co conspirators upon information and belief 232 00:16:39,120 --> 00:16:42,320 whose testimony in part it intended to base its federal 233 00:16:42,360 --> 00:16:47,279 prosecution of Jeffrey Epstein for his illegal conduct. Part number four. 234 00:16:47,720 --> 00:16:54,240 Missarreos and the recruiter eighty eight child victim Plaintiff, Jennifer 235 00:16:54,320 --> 00:16:57,759 ARREOs was subjected to the types of illegal sexual acts 236 00:16:57,799 --> 00:17:01,919 detailed in the criminal indictment filed against Jeffrey Epstein by 237 00:17:01,960 --> 00:17:05,839 the Southern District of New York eighty nine. Jeffrey Epstein 238 00:17:06,039 --> 00:17:09,720 committed abhorrent acts of sexual abuse against plaintiff in two 239 00:17:09,720 --> 00:17:12,319 thousand and one and two thousand and two when she 240 00:17:12,440 --> 00:17:16,319 was only fourteen years old ninety Miss Areos was born 241 00:17:16,519 --> 00:17:20,039 in Saint John's Hospital in Queens on February fifth, nineteen 242 00:17:20,079 --> 00:17:23,680 eighty seven. Ninety one. She grew up poor and largely 243 00:17:23,799 --> 00:17:26,880 raised by her mother, a single parent in Middle Village, Queens. 244 00:17:27,319 --> 00:17:31,119 Ninety two. The loss of her father at twelve caused 245 00:17:31,119 --> 00:17:34,319 emotional vulnerability and issues surrounding the lack of having a 246 00:17:34,359 --> 00:17:38,920 father figure in her life. Ninety three. Miss Areos was 247 00:17:38,920 --> 00:17:42,440 a prime target for grooming by a pedophile like Jeffrey 248 00:17:42,480 --> 00:17:46,000 Epstein ninety four. In September of two thousand and one, 249 00:17:46,240 --> 00:17:50,079 at age fourteen, Miss Areos entered high school. She attended 250 00:17:50,079 --> 00:17:53,599 a special public high school for performing arts called Talent 251 00:17:53,839 --> 00:17:58,799 Unlimited High School, where she majored in musical theater, singing, dancing, 252 00:17:59,160 --> 00:18:04,720 acting ninety five. Its campus is within the Julia Richmond 253 00:18:04,880 --> 00:18:09,599 Education Complex, along with five other schools. Urban Academy, Vanguard 254 00:18:09,680 --> 00:18:13,599 High School P two two six M Junior High Annex, 255 00:18:13,880 --> 00:18:19,000 Ella Baker Elementary School, and Manhattan International High School ninety six. 256 00:18:19,680 --> 00:18:22,839 Because Talent Unlimited High School is a special high school 257 00:18:22,839 --> 00:18:26,480 for the performing arts, students' audition to be accepted. The 258 00:18:26,519 --> 00:18:31,359 school had approximately five hundred students ninety seven. During the 259 00:18:31,400 --> 00:18:34,440 first semester of miss Areo's freshman year of high school, 260 00:18:34,599 --> 00:18:37,599 while she was fourteen years old, after school one day, 261 00:18:37,640 --> 00:18:40,240 she was approached by a brunette woman who appeared to 262 00:18:40,240 --> 00:18:42,880 be in her early twenties on the sidewalk in front 263 00:18:42,880 --> 00:18:45,839 of her school. The woman, who we shall refer to 264 00:18:45,920 --> 00:18:50,480 as the recruiter, tried to befriend her. Ninety eight. Upon 265 00:18:50,559 --> 00:18:55,599 information and belief, defendants Maxwell Groff and Espinoza identified and 266 00:18:55,720 --> 00:18:59,000 hired the recruiter on behalf of Jeffrey Epstein to procure 267 00:18:59,119 --> 00:19:03,359 underage girls from Talented Unlimited High School and other schools, 268 00:19:03,640 --> 00:19:06,640 and oversaw the process that led to the recruitment and 269 00:19:06,720 --> 00:19:11,279 grooming of missus Aureos. Ninety nine. The recruiter asked Miss 270 00:19:11,319 --> 00:19:14,519 Oreos where she lived, where her parents were if they 271 00:19:14,559 --> 00:19:18,119 were together, where she was born, and where her parents worked. 272 00:19:18,519 --> 00:19:22,480 One hundred. The recruiter approached miss Oreos repeatedly over the 273 00:19:22,519 --> 00:19:24,759 course of a week or two, offering to take her 274 00:19:24,759 --> 00:19:27,599 for lunches close by the school, and during the meals 275 00:19:27,680 --> 00:19:30,519 would continue to ask her personal questions about her life. 276 00:19:30,799 --> 00:19:34,119 One oh one. At some point during this approximate two 277 00:19:34,160 --> 00:19:37,240 week period, the recruiter began to speak about Jeffrey Epstein, 278 00:19:37,480 --> 00:19:40,319 almost as if he was her uncle or a family friend. 279 00:19:40,960 --> 00:19:44,240 One O two. The recruiter said that Epstein was a 280 00:19:44,319 --> 00:19:46,319 nice guy and that he takes care of her and 281 00:19:46,359 --> 00:19:50,240 her family. The recruiter spoke glowingly of Epstein, stating he 282 00:19:50,319 --> 00:19:52,680 is very wealthy and you have to see his house. 283 00:19:53,200 --> 00:19:56,440 One O three. The recruiter eventually said that she told 284 00:19:56,480 --> 00:19:59,680 Epstein about Missus Aureos, about how pretty and smart she is, 285 00:20:00,039 --> 00:20:02,799 and about how she recently lost her father to AIDS. 286 00:20:03,640 --> 00:20:06,720 One oh four. The recruiter then told missus Areos that 287 00:20:06,759 --> 00:20:09,880 Epstein felt horrible about the loss of her father and 288 00:20:10,000 --> 00:20:12,920 said that he wanted to help her out. The recruiter 289 00:20:12,960 --> 00:20:15,920 said that Epstein is a caring guy, that he said 290 00:20:15,960 --> 00:20:18,319 she should not be struggling, and that he wanted to 291 00:20:18,359 --> 00:20:22,400 be there four one oh five, The recruiter then said 292 00:20:22,480 --> 00:20:25,519 that she wanted missus Areos to meet Epstein, that he 293 00:20:25,640 --> 00:20:28,279 knows a lot of people in the acting and modeling world, 294 00:20:28,480 --> 00:20:30,839 and that he could possibly help her and introduce her 295 00:20:30,880 --> 00:20:33,839 to the right people for her career. The recruiter said 296 00:20:33,839 --> 00:20:38,359 Epstein wanted to guide her. One o six, The recruiter 297 00:20:38,400 --> 00:20:41,559 said that he was very caring, very wealthy, very successful, 298 00:20:41,799 --> 00:20:45,200 and someone good to know. One oh seven. The recruiter 299 00:20:45,279 --> 00:20:47,960 said that if missus Aureos did not want to meet Epstein, 300 00:20:48,200 --> 00:20:51,000 she did not have to, but doing so could benefit her. 301 00:20:51,440 --> 00:20:55,400 The recruiter also enticed miss Areos by repeatedly saying how 302 00:20:55,400 --> 00:20:58,000 Epstein's home is so beautiful and that it was right 303 00:20:58,079 --> 00:21:02,359 here by missus Areo's school. One o eight. The recruiter 304 00:21:02,599 --> 00:21:05,640 said that they could go by Epstein's house together one 305 00:21:05,680 --> 00:21:08,920 oh nine. One day, the recruiter made plans with miss 306 00:21:08,960 --> 00:21:12,400 Aureos to meet after school, to visit Epstein's home and 307 00:21:12,440 --> 00:21:17,000 to meet them Part five. Epstein's sexual assault, battery and 308 00:21:17,079 --> 00:21:21,799 rape of missus Aureos. One ten. Upon arrival at Epstein's 309 00:21:21,960 --> 00:21:25,279 at ninety seventy one Street in New York, miss Areos 310 00:21:25,319 --> 00:21:27,799 and the recruiter were greeted at the front door by 311 00:21:27,799 --> 00:21:31,240 the maid, Miss Fontania, who brought them to the secretary, 312 00:21:31,400 --> 00:21:34,839 Miss Groff, to wait. When Epstein came to greet them, 313 00:21:34,960 --> 00:21:39,559 he appeared very welcoming, even humble. One eleven. Inside the 314 00:21:39,599 --> 00:21:42,599 front door, there were many security cameras pointing in all 315 00:21:42,599 --> 00:21:46,119 directions on the little TVs. Miss Areos could actually see 316 00:21:46,119 --> 00:21:50,839 herself on the camera walking inside. One twelve. Epstein gave 317 00:21:50,839 --> 00:21:53,319 Miss Aureos a tour of the first floor of the house, 318 00:21:53,519 --> 00:21:55,519 but he did not show her the massage room, not 319 00:21:55,599 --> 00:21:59,440 in the beginning. One thirteen. Instead, during the first time 320 00:21:59,519 --> 00:22:01,839 at epstein Mean's New York Residents, he showed her a 321 00:22:01,839 --> 00:22:05,599 trophy room as she entered, filled with taxidermied animals he'd 322 00:22:05,599 --> 00:22:10,079 allegedly hunted over the years. One fourteen. The room had 323 00:22:10,119 --> 00:22:14,440 marble floors with extremely high ceilings, mahogany wood with deep reds, 324 00:22:14,680 --> 00:22:18,160 and was filled with exotic, even endangered animals, including a 325 00:22:18,200 --> 00:22:22,440 giraffe and other rare specimens, including a stuffed tiger. Their 326 00:22:22,480 --> 00:22:25,400 skins were covering parts of the floor with more exotic 327 00:22:25,440 --> 00:22:30,640 animals one fifteen. As one might expect, Epstein's house was massive. 328 00:22:31,279 --> 00:22:33,720 When one walked in The huge entry door was in 329 00:22:33,759 --> 00:22:36,440 the middle of the city block, and upon entry there 330 00:22:36,480 --> 00:22:40,240 was a set of marble stairs in the entryway one sixteen. 331 00:22:40,799 --> 00:22:43,680 To the left there was Epstein's secretary office with a 332 00:22:43,680 --> 00:22:46,960 waiting room couches and chairs. To the right there was 333 00:22:47,000 --> 00:22:50,119 the trophy room filled with hunted animals. There was also 334 00:22:50,160 --> 00:22:53,519 a kitchen on the same floor as one cab. Walking forward, 335 00:22:53,680 --> 00:22:56,279 there was a spiral staircase with a self portrait of 336 00:22:56,279 --> 00:22:59,039 Epstein on the wall, with a young girl whom Epstein 337 00:22:59,079 --> 00:23:04,519 said he considered like a daughter one seventeen. On miss 338 00:23:04,559 --> 00:23:09,119 areos first visit, she recalls she and the recruiter waiting 339 00:23:09,119 --> 00:23:11,839 for Epstein in Miss Groff's office, where Miss Groff was 340 00:23:11,880 --> 00:23:15,839 sitting behind the desk. Subsequently, Miss Areos was offered cheese, 341 00:23:15,880 --> 00:23:19,599 crackers and wine in the kitchen by Miss Fontania. In 342 00:23:19,640 --> 00:23:23,559 Miss Groff's and Miss Fontania's presence, Miss Areos identified that 343 00:23:23,640 --> 00:23:27,039 she was a freshman at the local high school one eighteen. 344 00:23:27,599 --> 00:23:30,319 At this point Epstein showed up to greet the girls 345 00:23:30,480 --> 00:23:33,440 and showed Miss Areos the trophy room, of which appeared 346 00:23:33,799 --> 00:23:36,720 to be very proud of one nineteen. At the end 347 00:23:36,720 --> 00:23:39,759 of the first visit, Miss Areos recalls Epstein giving the 348 00:23:39,799 --> 00:23:43,039 recruiter a gift of a digital camera. The recruiter then 349 00:23:43,079 --> 00:23:45,640 said to Miss Areos, you see what I mean, He's 350 00:23:45,680 --> 00:23:49,519 such a nice guy. One twenty Epstein then gave Miss 351 00:23:49,559 --> 00:23:52,599 Areos three hundred dollars in cash on his first visit 352 00:23:52,839 --> 00:23:54,720 and said, here's a little something to help you out. 353 00:23:54,960 --> 00:23:57,480 I take care of the people I care about. One 354 00:23:57,559 --> 00:24:00,200 twenty one. He also told Miss Areos that he he 355 00:24:00,319 --> 00:24:03,079 was a big AIDS activist, which meant a lot to 356 00:24:03,079 --> 00:24:06,319 Miss Areos at the time because her father had recently 357 00:24:06,319 --> 00:24:10,039 passed away from the disease. One twenty two. After an 358 00:24:10,079 --> 00:24:12,839 hour or two, Miss Areos and the recruiter left together. 359 00:24:13,240 --> 00:24:16,480 One twenty three. Within a couple of days, the recruiter 360 00:24:16,519 --> 00:24:19,160 reached out to Miss Areos and said that she made 361 00:24:19,160 --> 00:24:22,000 a great impression on Epstein and that he wanted to 362 00:24:22,000 --> 00:24:26,000 see her again. One twenty four. At the time, Miss 363 00:24:26,039 --> 00:24:29,079 Areos figured there was no harm, as Epstein's house was 364 00:24:29,119 --> 00:24:31,319 only a couple of blocks from her high school and 365 00:24:31,480 --> 00:24:33,920 at this point he had done nothing to her to 366 00:24:33,960 --> 00:24:37,720 give her pause or cause for her concern. One twenty five, 367 00:24:38,160 --> 00:24:41,920 so again the recruiter brought Aarreos back to Epstein's New 368 00:24:41,960 --> 00:24:46,079 York residence after school one twenty six. The second time 369 00:24:46,119 --> 00:24:49,240 Miss Areos went to Epstein's New York residence, he gave 370 00:24:49,279 --> 00:24:52,079 Miss Areos the same camera that he had previously given 371 00:24:52,119 --> 00:24:55,079 the recruiter on miss areos first visit to the home. 372 00:24:55,559 --> 00:24:59,759 One twenty seven. Miss Aureos visited Epstein's New York residence 373 00:25:00,039 --> 00:25:02,559 with the recruiter about once or twice a week for 374 00:25:02,640 --> 00:25:06,359 the first month. Each time Miss Areos stayed between one 375 00:25:06,559 --> 00:25:08,720 and two hours, and at the end of the stay, 376 00:25:08,960 --> 00:25:12,440 Epstein would either personally or direct Miss Groff to give 377 00:25:12,480 --> 00:25:15,440 her three hundred in cash and just say that he 378 00:25:15,519 --> 00:25:18,119 wanted to help her out, while she and the recruiter 379 00:25:18,160 --> 00:25:22,039 would be served cheese, crackers and wine by Miss Fontania. 380 00:25:22,400 --> 00:25:25,799 One twenty eight, Miss Areos openly discussed with Epstein in 381 00:25:25,839 --> 00:25:28,599 front of the recruiter, Mis Groff, and Miss Fontania that 382 00:25:28,799 --> 00:25:31,400 she was a freshman at a performing arts high school 383 00:25:31,599 --> 00:25:33,839 right down the street and that her dream was to 384 00:25:33,839 --> 00:25:37,359 be an actress and the singer. One twenty nine, after 385 00:25:37,400 --> 00:25:39,799 about a month of making these visits to Epstein's New 386 00:25:39,880 --> 00:25:43,240 York residence with the recruiter, always waiting with the recruiter 387 00:25:43,440 --> 00:25:46,640 in the secretary's office, with miss Groff there at her desk. 388 00:25:46,960 --> 00:25:50,920 Miss Groff contacted miss ARREOs directly and scheduled arrangements for 389 00:25:50,960 --> 00:25:53,920 her visit to Epstein's home alone for the first time, 390 00:25:54,079 --> 00:25:57,400 and gave Miss ARREOs instructions for when she arrived. So 391 00:25:57,640 --> 00:26:00,400 just to interject here once again, oh is it that 392 00:26:00,519 --> 00:26:03,359 Leslie Groff got off scott free? How is it that 393 00:26:03,440 --> 00:26:06,240 Leslie Groff has never been brought in and put under oath? 394 00:26:06,359 --> 00:26:10,279 Can somebody please explain that to me? One thirty At 395 00:26:10,279 --> 00:26:13,680 this point, during miss areos first visit alone, Epstein took 396 00:26:13,680 --> 00:26:16,680 Aarreos on the elevator for the first time and showed 397 00:26:16,720 --> 00:26:19,400 her his massage room on one of the upper floors. 398 00:26:19,759 --> 00:26:22,319 One thirty one. The ceilings of most of the rooms 399 00:26:22,359 --> 00:26:25,640 of the house were painted with ornate murals, just like 400 00:26:25,759 --> 00:26:30,160 ancient Rome, Greece, and even the Sistine Chapel. One thirty two. 401 00:26:30,319 --> 00:26:33,200 Upon showing miss Areos his massage room for the first time, 402 00:26:33,359 --> 00:26:36,039 Epstein said, I want to show you something now. I 403 00:26:36,119 --> 00:26:38,920 love this room. It's my favorite room in the house. 404 00:26:39,920 --> 00:26:43,119 One thirty three. The massage room was on the smaller 405 00:26:43,160 --> 00:26:45,400 side compared to the other rooms in the house. The 406 00:26:45,440 --> 00:26:47,960 ceiling was painted to look like a blue sky with 407 00:26:48,000 --> 00:26:50,960 clouds and angels to give the appearance that you were 408 00:26:50,960 --> 00:26:55,079 in heaven. Now, think about how creepy that is. He 409 00:26:55,119 --> 00:26:58,559 has this whole room set up in this kind of passive, 410 00:26:58,640 --> 00:27:02,079 calm manner, but really, what's going on in this room 411 00:27:02,319 --> 00:27:05,440 is some of the most monstrous bullshit that we've ever seen. 412 00:27:06,400 --> 00:27:09,839 One thirty four. Epstein showed Miss Aureos the artwork in 413 00:27:09,880 --> 00:27:12,559 the room and the massage table, stating that not too 414 00:27:12,559 --> 00:27:15,559 many people know about this room. He then stated, you 415 00:27:15,599 --> 00:27:18,319 should really be a model. You're beautiful. I bet your 416 00:27:18,319 --> 00:27:20,799 body is incredible, and in order to help you with 417 00:27:20,839 --> 00:27:23,200 your modeling career, I will need to see your body. 418 00:27:23,920 --> 00:27:26,720 One thirty five. Epstein had a lot of paintings of 419 00:27:26,799 --> 00:27:29,319 nude women on the walls. He even commented on one 420 00:27:29,359 --> 00:27:32,240 painting of a nude woman with small breasts and brunette hair, 421 00:27:32,519 --> 00:27:34,640 but you couldn't see her face clearly because she was 422 00:27:34,680 --> 00:27:38,759 partially turned. That painting was right behind the massage table, 423 00:27:39,119 --> 00:27:41,200 and he said how much the woman in the picture 424 00:27:41,279 --> 00:27:44,920 looked like Miss Areos, then fourteen years old. One thirty 425 00:27:44,960 --> 00:27:48,240 six He said he liked girls with small breasts because 426 00:27:48,279 --> 00:27:51,319 they were natural and real. He then complimented Miss Aureos 427 00:27:51,440 --> 00:27:56,319 repeatedly about her breast one thirty seven. He then told 428 00:27:56,359 --> 00:27:58,680 Miss Areos again that she would do great in the 429 00:27:58,680 --> 00:28:01,359 modeling industry and said that he had a lot of 430 00:28:01,400 --> 00:28:04,240 connections in the modeling industry and that he could help her. 431 00:28:05,079 --> 00:28:08,079 One thirty eight, Still in the massage room, Jeffrey Epstein 432 00:28:08,279 --> 00:28:11,480 quickly turned the encounter into a sexual encounter with a 433 00:28:11,519 --> 00:28:14,839 then fourteen year old plaintiff, asking Miss Areos to take 434 00:28:14,839 --> 00:28:17,640 off her top so he could see her body and frame, 435 00:28:17,960 --> 00:28:21,000 which he insinuated he needed to do if he was 436 00:28:21,039 --> 00:28:23,720 going to help her with her modeling career. He was 437 00:28:23,920 --> 00:28:28,680 very complimentary. One thirty nine. Feeling uncomfortable and confused and 438 00:28:28,720 --> 00:28:32,920 feeling trapped in Jeffrey Epstein's large mansion under the impression 439 00:28:33,000 --> 00:28:35,759 that there was no feasible or safe means of escape, 440 00:28:35,960 --> 00:28:41,480 miss Areos did as Epstein instructed. Epstein then immediately started harmful, 441 00:28:41,720 --> 00:28:46,160 forcibly physical touching and sexual exploitation of plaintiff, feeling Miss 442 00:28:46,200 --> 00:28:51,880 Areo's breasts and rubbing her new shoulders. He then asked 443 00:28:51,880 --> 00:28:54,559 her if she was good at giving massages, and considering 444 00:28:54,680 --> 00:28:57,000 all the financial help that he had given her family 445 00:28:57,039 --> 00:29:00,480 over the past month, insinuated that he would like one. 446 00:29:00,519 --> 00:29:03,720 Epstein then walked out of the room, returned in a bathrobe. 447 00:29:03,799 --> 00:29:07,400 He instructed Miss Areos to remove everything but her bottom 448 00:29:07,440 --> 00:29:10,440 underwear and laid down on the massage table with only 449 00:29:10,480 --> 00:29:14,240 a towel, instructing Miss Areos to proceed with a back massage. 450 00:29:14,640 --> 00:29:17,920 Miss Areos recalls Epstein having a lot of birthmarks and 451 00:29:18,160 --> 00:29:22,079 or freckles on his back. One forty one. After massaging 452 00:29:22,079 --> 00:29:25,640 Epstein's back for about twenty to twenty five minutes, Epstein 453 00:29:25,799 --> 00:29:30,319 suddenly turned over, removed his towel, and began masturbating one 454 00:29:30,400 --> 00:29:35,440 forty two. Miss Areos, feeling uncomfortable and intimidated, stood frozen 455 00:29:35,599 --> 00:29:38,720 to the side of the massage table as Epstein ejaculated 456 00:29:38,799 --> 00:29:43,720 onto himself. One forty three. Miss Aureos recalls Epstein having 457 00:29:43,759 --> 00:29:47,200 a lot of birthmarks and or freckles around his genitilia area. 458 00:29:48,319 --> 00:29:51,839 One forty four. Epstein exposing his penis made Miss Areos 459 00:29:51,839 --> 00:29:55,519 extremely nervous and uncomfortable, but she felt intimidated, so she 460 00:29:55,640 --> 00:30:00,000 did as she was told. One forty five also, epste 461 00:30:00,200 --> 00:30:02,359 insinuated that because of the money he gave her, she 462 00:30:02,400 --> 00:30:04,799 owed him. Epstein says, I take care of you, you 463 00:30:04,920 --> 00:30:07,960 take care of me. One forty six. He was giving 464 00:30:07,960 --> 00:30:10,880 Miss Areos instructions and telling her what to do the 465 00:30:11,039 --> 00:30:15,480 entire time. Epstein ultimately ejaculated on himself and then it 466 00:30:15,640 --> 00:30:19,960 ended one forty seven. He said, this was amazing. You're beautiful. 467 00:30:20,240 --> 00:30:22,240 I can't wait to see you again. I will give 468 00:30:22,240 --> 00:30:24,240 you a call during the week and we'll see each 469 00:30:24,279 --> 00:30:28,000 other again one forty eight. He also warned Miss Areos 470 00:30:28,079 --> 00:30:30,640 not to tell anyone what had occurred or about her 471 00:30:30,759 --> 00:30:34,160 visits to his home, something he would consistently repeat to 472 00:30:34,200 --> 00:30:37,279 her and insist upon throughout the more than one year 473 00:30:37,359 --> 00:30:42,799 of abusive sexual assaults and battery, and eventual forcible rape 474 00:30:42,920 --> 00:30:46,119 one forty nine. Miss Areos remembers after the first sexual 475 00:30:46,200 --> 00:30:48,759 encounter with Epstein, he showed her a room on the 476 00:30:48,799 --> 00:30:51,920 same floor as a massage room that he said was 477 00:30:51,960 --> 00:30:54,720 designed to look like his favorite room at the White House, 478 00:30:54,839 --> 00:30:57,359 which he called the Blue Room. It was blue and 479 00:30:57,400 --> 00:30:59,839 had a distinct oval shape, and then he showed her 480 00:31:00,119 --> 00:31:03,279 some more artwork his master bedroom with a large jacuzzi 481 00:31:03,640 --> 00:31:06,640 and prosthetic breasts on the wall in a bathroom that 482 00:31:06,759 --> 00:31:09,319 he could look at or play with while in the bathtub. 483 00:31:09,799 --> 00:31:13,519 One fifty Plaintiff observed the opulence of the mansion owned 484 00:31:13,519 --> 00:31:17,920 by defendant nine East and the organization of defendant NS Incorporated, 485 00:31:18,240 --> 00:31:23,720 which collectively facilitated her further cooperation with Jeffrey Epstein, culminating 486 00:31:23,759 --> 00:31:26,799 in New York penal law section one thirty crimes being 487 00:31:26,799 --> 00:31:32,759 committed against her by Jeffrey Epstein. One fifty one Plaintiff 488 00:31:32,880 --> 00:31:36,000 was paid three hundred cash before being escorted out of 489 00:31:36,000 --> 00:31:39,599 the mansion, all with assistant from defendants. This payment was 490 00:31:39,640 --> 00:31:43,200 made to induce plaintiff to conceal the activities of Epstein 491 00:31:43,519 --> 00:31:47,759 and to entice her to return one fifty two going forward. 492 00:31:47,920 --> 00:31:51,920 Sometimes Epstein would call Miss ARREOs directly, but primarily Miss 493 00:31:52,000 --> 00:31:55,559 Groff would call email and or page Miss ARREOs, not 494 00:31:55,640 --> 00:31:58,200 necessarily in that order, but they would speak on the 495 00:31:58,240 --> 00:32:00,839 phone and she would give her instruction for her next 496 00:32:00,880 --> 00:32:05,359 sexual encounter with Epstein. There were also two assistants of 497 00:32:05,359 --> 00:32:09,039 Epstein's that would call Miss Areos from Epstein's office to 498 00:32:09,079 --> 00:32:12,640 schedule these encounters, who, like Miss Groff, would give Miss 499 00:32:12,680 --> 00:32:17,319 Areos explicit instructions to follow upon arrival. One of those 500 00:32:17,359 --> 00:32:20,799 assistants was Miss Espinoza, whom Miss Areos would see at 501 00:32:20,839 --> 00:32:25,759 the property after speaking to one fifty three. Upon information 502 00:32:25,839 --> 00:32:29,920 and belief, Maxwell and other staff of corporate Defendants and 503 00:32:30,039 --> 00:32:34,400 institutional Defendants would email or page Miss Areos directly and 504 00:32:34,599 --> 00:32:38,680 or coordinate Epstein's schedule with Miss Groff, Miss Espinoza, and 505 00:32:38,720 --> 00:32:43,680 Miss Fontania for these sexual encounters to occur one fifty four. 506 00:32:44,200 --> 00:32:47,960 These sexual encounters with Epstein, which of course were horribly 507 00:32:48,000 --> 00:32:52,319 abusive sexual assaults of a child, became more aggressive and escalated. 508 00:32:52,839 --> 00:32:55,960 For example, the second time it occurred, while Epstein started 509 00:32:55,960 --> 00:32:59,680 to masturbate, he grabbed Miss Areo's breast hard without asking, 510 00:33:00,039 --> 00:33:03,759 and this time insisted that Miss Areos rub his chest, arms, 511 00:33:03,759 --> 00:33:06,640 and legs, and pinch his nipples, which he said was 512 00:33:06,720 --> 00:33:09,480 one of the main things that turned him on sexually. 513 00:33:10,559 --> 00:33:14,480 One fifty five. These encounters would continue on a weekly basis, 514 00:33:14,519 --> 00:33:17,359 once or twice a week throughout the first and second 515 00:33:17,400 --> 00:33:20,839 semester of Miss areos freshman year of high school, and 516 00:33:20,920 --> 00:33:23,680 through the beginning of the first semester of her sophomore 517 00:33:23,759 --> 00:33:27,599 year of high school. One fifty six, three hundred dollars 518 00:33:27,640 --> 00:33:30,039 in cash would be left for Miss Areos in a 519 00:33:30,160 --> 00:33:33,519 drawer in the massage room, the same drawer each time, 520 00:33:33,920 --> 00:33:36,240 and as Epstein left the room, he would state that 521 00:33:36,279 --> 00:33:38,680 he had left something for her to help her family. 522 00:33:39,200 --> 00:33:41,240 At the time, this was a lot of money to 523 00:33:41,279 --> 00:33:45,680 Miss Areos. One fifty seven. Later on, this became routine 524 00:33:45,799 --> 00:33:49,000 where Epstein would have his maid, said Miss Areos upstairs 525 00:33:49,000 --> 00:33:51,640 to the massage room. The maid would put towels and 526 00:33:51,680 --> 00:33:55,480 lotion out and tell ARREOs to get changed in the bathroom. 527 00:33:56,000 --> 00:33:59,000 One fifty eight. When one walked into the massage room, 528 00:33:59,200 --> 00:34:02,400 there was the pain painting of a nude woman previously mentioned. 529 00:34:02,839 --> 00:34:05,400 To the right there was the massage table, and to 530 00:34:05,440 --> 00:34:07,799 the right of the massage table there was a bathroom, 531 00:34:08,119 --> 00:34:11,559 which is where ARREOs would be directed to get changed 532 00:34:11,880 --> 00:34:14,960 one fifty nine. Finally, one day, during the fall of 533 00:34:14,960 --> 00:34:17,840 her sophomore year of high school, while she was fifteen 534 00:34:17,960 --> 00:34:21,440 years old, she was giving Epstein a massage in her underwear, 535 00:34:21,679 --> 00:34:24,760 as she had routinely been instructed to do, but this time, 536 00:34:24,800 --> 00:34:27,880 instead of turning over to masturbate and fondle her breast 537 00:34:28,239 --> 00:34:30,840 while she stood off to the side of the massage table. 538 00:34:31,119 --> 00:34:34,360 Epstein became more aggressive with her and started touching her 539 00:34:34,440 --> 00:34:38,400 vaginal area. One sixty He said, why don't we do 540 00:34:38,480 --> 00:34:41,039 it where you're on top of me massaging me and 541 00:34:41,119 --> 00:34:44,639 take your underwear off? One sixty one. Miss Areos said 542 00:34:44,679 --> 00:34:47,679 to Epstein that this made her feel uncomfortable and she 543 00:34:47,800 --> 00:34:50,320 wanted to stick with what they were doing before, but 544 00:34:50,400 --> 00:34:53,960 Epstein ignored her and continued to engage in improper and 545 00:34:54,159 --> 00:34:58,679 illegal sexual conduct. One sixty two. Epstein responded that he 546 00:34:58,719 --> 00:35:00,880 loved her and cared for was going to look out 547 00:35:00,920 --> 00:35:03,639 for her, that it was okay, and that she should 548 00:35:03,679 --> 00:35:06,320 just climb on top of him and try something different. 549 00:35:06,800 --> 00:35:11,119 One sixty three. Miss Areos felt completely intimidated and, knowing 550 00:35:11,159 --> 00:35:13,679 that she had no way out of the premises, did 551 00:35:13,719 --> 00:35:16,119 not know what to do, so she just complied with 552 00:35:16,199 --> 00:35:19,280 Jeffrey Epstein's orders and got on top of him. One 553 00:35:19,400 --> 00:35:23,719 sixty four. Epstein masturbated as he instructed Miss Areos to 554 00:35:23,800 --> 00:35:28,480 rub his chest and pinch his nipples one sixty five. Then, suddenly, 555 00:35:28,679 --> 00:35:32,559 without giving Miss Aureos any notice, Epstein forced his penis, 556 00:35:32,800 --> 00:35:36,079 which already had massage oils on it, inside her vagina 557 00:35:36,320 --> 00:35:39,199 and proceeded to have sex with her while plaintiff resisted 558 00:35:39,960 --> 00:35:43,480 one sixty six. Throughout the duration of the sexual encounter, 559 00:35:43,880 --> 00:35:47,760 ARREOs was petrified and, finding herself trapped in Jeffrey Epstein's 560 00:35:47,800 --> 00:35:51,079 large mansion under the impression that there was no feasible 561 00:35:51,239 --> 00:35:53,760 or safe means of escape, didn't know what to do, 562 00:35:54,039 --> 00:35:57,559 so she just did as she was told. Epstein held 563 00:35:57,559 --> 00:36:01,719 her tightly and forcibly raped her one sixty seven. On 564 00:36:01,800 --> 00:36:04,480 top of this brutal rape, Epstein did not use a condom, 565 00:36:04,679 --> 00:36:09,440 which substantially contributed to extreme emotional distress and the development 566 00:36:09,480 --> 00:36:12,679 of a panic disorder, which was exasperated by the fact 567 00:36:12,719 --> 00:36:15,519 that miss Areos had recently lost her father to AIDS 568 00:36:16,360 --> 00:36:20,519 one sixty eight. In addition to constituting illicit sex with 569 00:36:20,519 --> 00:36:24,039 a minor, this was also a brutal rape one sixty nine. 570 00:36:24,519 --> 00:36:29,679 Epstein's monstrous conduct cannot be understated. One seventy. Epstein, after 571 00:36:29,760 --> 00:36:33,079 raping Miss Areos, told her that she was amazing, that 572 00:36:33,199 --> 00:36:36,119 she felt amazing, and that she did nothing wrong. One 573 00:36:36,239 --> 00:36:40,320 seventy one. Miss Areos was disgusted with Jeffrey Epstein and 574 00:36:40,400 --> 00:36:43,559 herself at the time, and left his home soon afterwards, 575 00:36:43,599 --> 00:36:48,559 never to return one seventy two. Afterwards, Jeffrey Epstein tried 576 00:36:48,599 --> 00:36:51,679 to contact Miss Areos, but she ignored his calls one 577 00:36:51,800 --> 00:36:55,400 seventy three. Epstein also tried to reach out to Miss 578 00:36:55,440 --> 00:36:58,760 Areos in later years, but she did not take his calls. 579 00:36:59,079 --> 00:37:02,840 One seventy four, Following the rape, Miss Areos refused to 580 00:37:02,840 --> 00:37:05,440 go back to Talent Unlimited High School out of fear 581 00:37:05,480 --> 00:37:08,119 of seeing Epstein, who lived just blocks away from her 582 00:37:08,199 --> 00:37:12,039 high school, or seeing the recruiter again. One seventy five. 583 00:37:12,679 --> 00:37:15,320 At the time, Miss Areos told her mom the reason 584 00:37:15,760 --> 00:37:18,960 was that she was being bullied at school, concealing from 585 00:37:19,000 --> 00:37:22,880 her the truth involving Epstein, reflecting her extreme shame about 586 00:37:22,920 --> 00:37:26,639 what she experienced and the intimidation she felt from Epstein. 587 00:37:27,079 --> 00:37:30,679 One seventy six. Miss Areos, still fifteen years old at 588 00:37:30,719 --> 00:37:34,119 the time, transferred to Forest Hills School in Queens by 589 00:37:34,119 --> 00:37:37,480 her home to avoid any continued contact with Epstein and 590 00:37:37,519 --> 00:37:41,719 the recruiter. One seventy seven, Having left a special public 591 00:37:41,800 --> 00:37:44,719 high school for performing arts that she had to audition 592 00:37:44,840 --> 00:37:47,800 to get into to instead go to a regular high school, 593 00:37:48,039 --> 00:37:51,199 cause Miss Areos to lose interest in school, drop out, 594 00:37:51,440 --> 00:37:54,800 and give up on her career of being an actress, model, 595 00:37:54,800 --> 00:37:58,360 and a singer. One seventy eight. All sexual acts were 596 00:37:58,400 --> 00:38:02,679 performed by Jeffrey Epstein intentionally and for no legitimate purpose, 597 00:38:02,920 --> 00:38:05,599 and for his own gratification when plaintiff was a minor 598 00:38:05,679 --> 00:38:09,719 child less than seventeen years old. One seventy nine. The 599 00:38:09,760 --> 00:38:13,559 intentional acts of Jeffrey Epstein against plaintiff constitute of sexual 600 00:38:13,599 --> 00:38:18,880 offense has defined an article one thirty one. Pursuing to 601 00:38:19,000 --> 00:38:22,199 New York Penal Law one thirty dot five, a person 602 00:38:22,480 --> 00:38:25,559 is deemed incapable of consent when she is less than 603 00:38:25,599 --> 00:38:30,079 seventeen years old. One eighty one. Jeffrey Epstein committed sexual 604 00:38:30,119 --> 00:38:34,639 misconduct against plaintiff as defined in section one thirty dot 605 00:38:34,679 --> 00:38:39,039 twenty of NYPL inasmuch as Jeffrey Epstein engaged in sexual 606 00:38:39,079 --> 00:38:44,000 intercourse with plaintiff without plaintiff's consent. One eighty two. Jeffrey 607 00:38:44,000 --> 00:38:47,440 Epstein committed rape in the third degree as defined in 608 00:38:47,480 --> 00:38:51,119 section one thirty dot two five of NYPL inasmuch as 609 00:38:51,159 --> 00:38:54,679 Jeffrey Epstein, being twenty one years old or more, engaged 610 00:38:54,719 --> 00:38:57,800 in sexual intercourse with plaintiff who was less than seventeen 611 00:38:57,880 --> 00:39:01,760 years old. One eighty three, Jeffrey Epstein committed rape in 612 00:39:01,800 --> 00:39:05,440 the first degree, as defined in NYPL section one thirty 613 00:39:05,599 --> 00:39:09,360 dot three five, inasmuch as Jeffrey Epstein engaged in sexual 614 00:39:09,400 --> 00:39:14,800 intercourse with plaintiff by forcible compulsion. One four Jeffrey Epstein 615 00:39:14,840 --> 00:39:18,679 committed forcible touching against plaintiff, as defined in Penal Code 616 00:39:18,679 --> 00:39:23,119 one thirty fifty two, inasmuch as Jeffrey Epstein intentionally and 617 00:39:23,159 --> 00:39:26,880 for no legitimate purpose, engaged in forcible sexual touching of 618 00:39:26,920 --> 00:39:30,280 plaintiff for the purpose of degrading or abusing her for 619 00:39:30,320 --> 00:39:34,639 the purpose of gratifying his sexual desires. One eight five 620 00:39:35,159 --> 00:39:39,280 Jeffrey Epstein committed sexual abuse in the first degree against plaintiff, 621 00:39:39,360 --> 00:39:42,760 as defined in New York Penal Law one thirty dot 622 00:39:42,800 --> 00:39:47,400 sixty five, inasmuch as Jeffrey Epstein subjected plaintiff to sexual 623 00:39:47,440 --> 00:39:52,960 contact by forcible compulsion. One eighty six. Jeffrey Epstein committed 624 00:39:53,000 --> 00:39:56,719 an aggravated sexual abuse in the second degree against plaintiff, 625 00:39:56,960 --> 00:40:01,800 as defined in NYPL one thirty sixty seven, inasmuch as 626 00:40:01,840 --> 00:40:05,760 Jeffrey Epstein caused physical injury to plaintiff when he inserted 627 00:40:05,800 --> 00:40:09,920 a finger into the vagina of plaintiff by forcible compulsion 628 00:40:11,320 --> 00:40:14,719 one eight seven Defendants of legal conduct continues to have 629 00:40:14,760 --> 00:40:18,440 an impact in every aspect of Plaintiff's life today. Part 630 00:40:18,519 --> 00:40:22,960 six Plaintiff's Petition for pre Action Discovery and Epstein's death 631 00:40:23,039 --> 00:40:28,239 and Will eight. On July twenty second, twenty nineteen, at 632 00:40:28,280 --> 00:40:32,760 ten fifteen am, New York Deputy Sheriff Quinnsang personally served 633 00:40:32,800 --> 00:40:36,280 Jeffrey Epstein at the Metropolitan Correctional Center, where he was 634 00:40:36,320 --> 00:40:39,880 being held without bail awaiting trial on sex trafficking and 635 00:40:39,960 --> 00:40:43,679 conspiracy charges, with an order to show cause to compel 636 00:40:43,760 --> 00:40:48,440 preaction disclosure from Epstein signed by Judge Melissa A. Crane, 637 00:40:48,679 --> 00:40:51,519 notifying Epstein of the charges to be filed against him 638 00:40:51,800 --> 00:40:54,880 by Miss Areos and the court date of August twenty seventh, 639 00:40:55,039 --> 00:41:00,679 twenty nineteen, along with a verified petition, exhibits and supporting documents. 640 00:41:00,840 --> 00:41:05,159 Plaintiff's petition for preaction Discovery, which included a copy of 641 00:41:05,159 --> 00:41:09,239 Plaintiff's complaint to be filed on August fourteenth, twenty nineteen, 642 00:41:09,559 --> 00:41:13,440 the first day permitted under the CVA, attached as Exhibit A, 643 00:41:13,880 --> 00:41:18,039 and the subpoena for Epstein's deposition testimony attached as Exhibit B. 644 00:41:18,480 --> 00:41:22,519 See Sheriff's Certificate of Service Document number six, Order to 645 00:41:22,599 --> 00:41:27,599 show cause, n y SCEF Document number five, Petition for 646 00:41:27,639 --> 00:41:32,400 pre action discovery with exhibits A nb n ysc EF 647 00:41:32,559 --> 00:41:38,679 Docket number one and Affirmation in support nys CEF Docket 648 00:41:38,760 --> 00:41:42,000 number two in the matter of the application of Jennifer 649 00:41:42,079 --> 00:41:46,119 Danielle Aureos versus Jeffrey Edward Epstein and Jane Does one 650 00:41:46,159 --> 00:41:50,039 through three, Index number one, five, six, seven, two eight, 651 00:41:50,320 --> 00:41:55,840 twenty nineteen, Supreme Court, New York County, July sixteenth, twenty nineteen, 652 00:41:56,400 --> 00:42:00,400 one eighty nine. According to CBS News and The Miami Herald, 653 00:42:00,599 --> 00:42:04,840 law enforcement sources confirmed on July twenty second, twenty nineteen, 654 00:42:05,239 --> 00:42:07,760 the very same day that Epstein learned of the charges 655 00:42:07,800 --> 00:42:11,280 against him by miss Areos, he was found semi unconscious 656 00:42:11,280 --> 00:42:14,920 in his cell of an apparent but unconfirmed suicide attempt, 657 00:42:15,119 --> 00:42:18,079 which led to him being put on suicide watch. Now, 658 00:42:18,159 --> 00:42:20,079 that was the time he had in the cell with 659 00:42:20,159 --> 00:42:24,280 Nicholas Tartaglioni, and as you all know, I don't buy it. 660 00:42:24,639 --> 00:42:27,719 I think that Tartaglioni attacked him, and until I see 661 00:42:27,760 --> 00:42:30,519 evidence proving otherwise, that's a hill that I'm willing to 662 00:42:30,559 --> 00:42:34,599 die on. The Department of Justice is only confirmed that 663 00:42:34,639 --> 00:42:37,800 Epstein was put on suicide watch in July following an 664 00:42:37,800 --> 00:42:43,239 incident one. If Epstein attempted to commit suicide upon learning 665 00:42:43,239 --> 00:42:45,760 of accusations of rape of a fifteen year old child, 666 00:42:46,039 --> 00:42:49,480 it would certainly indicate a consciousness of guilt, as why 667 00:42:49,519 --> 00:42:52,960 would Epstein want to take his own life unless accusations 668 00:42:53,000 --> 00:42:55,320 were true and he realized that he faced up to 669 00:42:55,360 --> 00:42:59,000 twenty five years in prison if charged see New York 670 00:42:59,079 --> 00:43:04,079 Penal Law one thirty thirty five one ninety one. On 671 00:43:04,119 --> 00:43:08,320 August eighth, twenty nineteen, Jeffrey Epstein responded to plaintiff's petition 672 00:43:08,440 --> 00:43:12,440 for pre action discovery incorporated herein by reference, and on 673 00:43:12,480 --> 00:43:16,800 that very same day, Epstein also created a revocable trust, 674 00:43:17,079 --> 00:43:20,280 the nineteen fifty three Trust, executing a new will that 675 00:43:20,360 --> 00:43:23,519 fraudently conveyed all of his assets to the nineteen fifty 676 00:43:23,519 --> 00:43:26,800 three trust in order to prevent the lay or hinder 677 00:43:26,840 --> 00:43:31,719 plaintiff from recovering for her legal injuries one ninety two. 678 00:43:32,079 --> 00:43:35,800 On August tenth, twenty nineteen, according to the Bureau of Prisons, 679 00:43:35,960 --> 00:43:39,679 Jeffrey Epstein died of an apparent suicide one ninety three. 680 00:43:39,760 --> 00:43:43,920 On August twenty six, twenty nineteen, defendant Darren K Endyke 681 00:43:44,199 --> 00:43:47,480 filed a certificate of trust with the Superior Court for 682 00:43:47,639 --> 00:43:50,920 the Virgin Islands, confirming that he and defendant Richard D. 683 00:43:51,039 --> 00:43:54,639 Con are the two trustees of the nineteen fifty three trust. 684 00:43:55,079 --> 00:43:57,719 Seize Certificate of Trust in the Matter of the Estate 685 00:43:57,960 --> 00:44:02,039 of Jeffrey e Epstein pro eight number st Dash nineteen 686 00:44:02,280 --> 00:44:06,760 pb DASH eighty, Superior Court, Virgin Islands, August twenty six, 687 00:44:06,840 --> 00:44:12,039 twenty nineteen, one ninety four. On September six, twenty nineteen, 688 00:44:12,440 --> 00:44:16,639 Magistrate Judge Carolyn p Herman Purcell of the Superior Court 689 00:44:16,639 --> 00:44:20,199 of the Virgin Islands order that Epstein's will be admitted 690 00:44:20,199 --> 00:44:23,480 to probate and authorize mister Endyke and mister Kahan to 691 00:44:23,559 --> 00:44:28,000 administer the estate. See Order for Probate and Letters Testamentary 692 00:44:28,360 --> 00:44:31,119 in the Matter of the Estate of Jeffrey e Epstein 693 00:44:31,400 --> 00:44:36,280 Probate Number st Dash nineteen pb DASH eighty, Superior Court, 694 00:44:36,360 --> 00:44:40,639 Virgin Islands, September six, twenty nineteen. All Right, folks, we're 695 00:44:40,639 --> 00:44:42,880 gonna wrap up there, and in the next episode we'll 696 00:44:42,880 --> 00:44:45,920 pick up with the cause of action. All of the 697 00:44:45,920 --> 00:44:49,000 information that goes with this episode can be found in 698 00:44:49,079 --> 00:44:50,079 the description box.