1 00:00:00,280 --> 00:00:03,879 Speaker 1: What's up everyone, and welcome back to the Epstein Chronicles. 2 00:00:04,480 --> 00:00:06,919 In this episode, we're picking back up where we left 3 00:00:06,960 --> 00:00:11,560 off with Jennifer Aureos and her claims against Jeffrey Epstein 4 00:00:11,919 --> 00:00:16,800 and his estate. Part seven. Cause of Action one Sexual 5 00:00:16,839 --> 00:00:20,480 assault and battery against Darren Kayen Dyke and Richard D. 6 00:00:20,640 --> 00:00:24,519 Con in their capacities as executors of the estate of 7 00:00:24,640 --> 00:00:29,679 Jeffrey E. Epstein one ninety five. Plaintiff incorporates by reference 8 00:00:29,800 --> 00:00:33,359 all preceding paragraphs and re alleges them as if set 9 00:00:33,439 --> 00:00:38,679 forth fully Herein one ninety six, Jeffrey Epstein made violent 10 00:00:38,759 --> 00:00:42,119 sexual demands on plaintiff while placing his hands on our body, 11 00:00:42,399 --> 00:00:46,439 and committed repeated acts of harmful or offensive touching against 12 00:00:46,479 --> 00:00:50,880 plaintiff one ninety seven. These demands were intended to intimidate 13 00:00:50,880 --> 00:00:54,159 plaintiff and force her to submit to his sexual requests 14 00:00:54,479 --> 00:00:57,439 one ninety eight. As a direct and proximate result of 15 00:00:57,520 --> 00:01:01,560 Jeffrey Epstein's repeated sexual assaults and battery of the plaintiff, 16 00:01:01,880 --> 00:01:04,480 she has in the past suffered, and in the future 17 00:01:04,560 --> 00:01:10,079 will continue to suffer physical injury, pain, emotional distress, psychological trauma, 18 00:01:10,239 --> 00:01:15,280 mental anguish, humiliation, embarrassment, loss of self esteem, loss of dignity, 19 00:01:15,519 --> 00:01:18,280 invasion of her privacy, and the loss of her capacity 20 00:01:18,480 --> 00:01:21,879 to enjoy life, as well as other damages, including but 21 00:01:21,959 --> 00:01:24,920 not limited to dropping out of high school and giving 22 00:01:25,040 --> 00:01:27,480 up on her career of being an actress, model, and 23 00:01:27,480 --> 00:01:32,640 a singer. Plaintiff incurred medical and psychological expenses, and Plaintiff 24 00:01:32,680 --> 00:01:36,560 will in the future suffer additional medical and psychological expenses. 25 00:01:37,040 --> 00:01:40,640 These injuries are permanent in nature, and plaintiff will continue 26 00:01:40,680 --> 00:01:44,159 to suffer these losses in the future. Cause of Action 27 00:01:44,239 --> 00:01:48,719 number two intentional infliction of emotional distress against Darren kay 28 00:01:48,840 --> 00:01:52,599 Endyke and Richard D. Conn in their capacities as executors 29 00:01:52,599 --> 00:01:58,120 of the estate of Jeffrey E. Epstein. Plaintiff incorporates by 30 00:01:58,159 --> 00:02:01,959 reference all preceding paragraphs and realleges them as if set 31 00:02:02,000 --> 00:02:08,680 forth fully herein two hundred. Jeffrey Epstein's outrageous and unconscionable conduct, 32 00:02:08,919 --> 00:02:12,680 which violated all norms of decent and civil society, was 33 00:02:12,719 --> 00:02:17,759 an intentional infliction of emotional distress upon plaintiff two oh one. 34 00:02:17,879 --> 00:02:21,159 As a direct and proximate result of Jeffrey Epstein's intentional 35 00:02:21,199 --> 00:02:25,199 infliction of emotional distress. The plaintiff has in the past 36 00:02:25,199 --> 00:02:29,280 suffered and in the future will continue to suffer physical injury, pain, 37 00:02:29,520 --> 00:02:35,319 emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of 38 00:02:35,319 --> 00:02:38,800 self esteem, loss of dignity, invasion of her privacy, and 39 00:02:38,840 --> 00:02:41,560 a loss of her capacity to enjoy life, as well 40 00:02:41,560 --> 00:02:45,199 as other damages, including but not limited to dropping out 41 00:02:45,199 --> 00:02:47,360 of high school and giving up on her career of 42 00:02:47,360 --> 00:02:50,879 being an actress, model, and singer. Plaintiff incurred medical and 43 00:02:50,919 --> 00:02:55,120 psychological expenses, and plaintiff will in the future suffer additional 44 00:02:55,159 --> 00:02:59,520 medical and psychological expenses. These injuries are permanent in nature, 45 00:02:59,759 --> 00:03:03,039 and plaintiff will continue to suffer these losses in the future. 46 00:03:04,560 --> 00:03:09,000 Cause of Action number three negligent infliction of emotional distress 47 00:03:09,039 --> 00:03:11,800 against Darren kay Endyke and Richard D. Con in their 48 00:03:11,840 --> 00:03:15,919 capacities as executors of the estate of Jeffrey E. Epstein. 49 00:03:16,199 --> 00:03:20,759 Two two. Plaintiff incorporates by reference all preceding paragraphs and 50 00:03:20,800 --> 00:03:25,199 realleges them as if set forth fully herein two three. 51 00:03:25,400 --> 00:03:29,919 By reason thereof Jeffrey Epstein committed negligent infliction of emotional 52 00:03:29,960 --> 00:03:33,680 distress upon plaintiff two O four as a direct and 53 00:03:33,800 --> 00:03:38,240 proximate result of Jeffrey Epstein's negligent infliction of emotional distress. 54 00:03:38,599 --> 00:03:41,000 The plaintiff has in the past suffered, and in the 55 00:03:41,000 --> 00:03:45,439 future will continue to suffer physical injury, pain, emotional distress, 56 00:03:45,639 --> 00:03:51,120 psychological trauma, mental anguish, humiliation, embarrassment, loss of self esteem, 57 00:03:51,280 --> 00:03:54,560 loss of dignity, invasion of her privacy, and the loss 58 00:03:54,599 --> 00:03:58,199 of her capacity to enjoy life, as well as other damages, 59 00:03:58,240 --> 00:04:01,400 including but not limited to dropping out of high school 60 00:04:01,599 --> 00:04:04,199 and giving up on her career of being an actress, model, 61 00:04:04,240 --> 00:04:09,319 and singer. Plaintiff incurred medical and psychological expenses, and plaintiff 62 00:04:09,360 --> 00:04:13,240 will in the future suffer additional medical and psychological expenses. 63 00:04:13,719 --> 00:04:17,639 These injuries are permanent in nature, and plaintiff will continue 64 00:04:17,680 --> 00:04:21,560 to suffer these losses in the future. Cause of Action 65 00:04:21,879 --> 00:04:26,279 Number four conspiracy to commit sexual assault and battery against 66 00:04:26,319 --> 00:04:32,040 Glenn Maxwell, Leslie Groff, Simberly Espinoza, the recruiter, the corporate defendants, 67 00:04:32,120 --> 00:04:37,399 and or the institutional defendants. Two five. Plaintiff incorporates by 68 00:04:37,519 --> 00:04:41,040 reference all preceding paragraphs and re alleges them as if 69 00:04:41,079 --> 00:04:45,160 set forth fully Herein two six. Miss Maxwell, Miss Groff, 70 00:04:45,279 --> 00:04:49,959 Miss Espinoza, the recruiter, the corporate defendants, end or institutional 71 00:04:49,959 --> 00:04:54,240 defendants conspired with Jeffrey Epstein to commit repeated acts of 72 00:04:54,360 --> 00:04:58,879 sexual assault and harmful or offensive touching against Plaintiff two 73 00:04:58,680 --> 00:05:01,519 O seven as a t direct and proximate result of 74 00:05:01,560 --> 00:05:06,079 Miss Maxwell, Miss Groff, Miss Espinoza, the recruiter, the corporate defendants, 75 00:05:06,319 --> 00:05:10,439 and or the institutional defendants conspiring with Jeffrey Epstein to 76 00:05:10,439 --> 00:05:14,439 commit repeated acts of sexual assault and battery against the plaintiff. 77 00:05:14,759 --> 00:05:17,040 She has in the past suffered and in the future 78 00:05:17,079 --> 00:05:22,439 will continue to suffer physical injury, pain, emotional distress, psychological trauma, 79 00:05:22,720 --> 00:05:27,879 mental anguish, humiliation, embarrassment, loss of self esteem, loss of dignity, 80 00:05:28,040 --> 00:05:30,759 invasion of her privacy, and the loss of her capacity 81 00:05:30,800 --> 00:05:34,240 to enjoy life, as well as other damages, including but 82 00:05:34,360 --> 00:05:37,680 not limited to dropping out of high school and giving 83 00:05:37,759 --> 00:05:40,800 up on her career of being an actress, model, and singer. 84 00:05:41,199 --> 00:05:45,360 Plaintiff incurred medical and psychological expenses, and plaintiff will in 85 00:05:45,399 --> 00:05:50,439 the future suffer additional medical and psychological expenses. These injuries 86 00:05:50,480 --> 00:05:54,040 are permanent in nature, and plaintiff will continue to suffer 87 00:05:54,079 --> 00:05:57,639 these losses in the future Cause of action Number five 88 00:05:58,319 --> 00:06:03,319 Conspiracy to commit intentional infliction of emotional distress against Glen Maxwell, 89 00:06:03,560 --> 00:06:08,519 Leslie Groff, simply Espinoza, the recruiter, the corporate defendants, and 90 00:06:08,839 --> 00:06:13,800 or institutional defendants two eight. Plaintiff incorporates by reference all 91 00:06:13,839 --> 00:06:17,959 preceding paragraphs and realleges them as if set forth fully 92 00:06:18,040 --> 00:06:22,360 herein two oh nine, Miss Maxwell, miss Groff, Miss Espinoza, 93 00:06:22,439 --> 00:06:26,480 the recruiter, the corporate defendants, and or the institutional defendants 94 00:06:26,759 --> 00:06:31,199 conspired with Jeffrey Epstein to commit outrageous and unconscionable conduct 95 00:06:31,360 --> 00:06:35,199 which violated all norms of decent and civil society, and 96 00:06:35,480 --> 00:06:40,439 was an intentional infliction of emotional distress upon Plaintiff two ten. 97 00:06:41,439 --> 00:06:44,800 As a direct and proximate result of Miss Maxwell, miss Groff, 98 00:06:44,959 --> 00:06:48,959 Miss Espinoza, the recruiter, the corporate defendants, end or the 99 00:06:49,040 --> 00:06:54,000 institutional defendants conspiring with Jeffrey Epstein to commit intentional infliction 100 00:06:54,360 --> 00:06:58,040 of emotional distress, the plaintiff has in the past suffered, 101 00:06:58,160 --> 00:07:01,639 and in the future will continue to suffer physical injury, pain, 102 00:07:01,879 --> 00:07:07,920 emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of 103 00:07:07,959 --> 00:07:11,439 self esteem, loss of dignity, invasion of her privacy, and 104 00:07:11,480 --> 00:07:14,279 a loss for her capacity to enjoy life, as well 105 00:07:14,319 --> 00:07:17,759 as other damages, including but not limited to dropping out 106 00:07:17,759 --> 00:07:20,360 of high school and giving up on her career of 107 00:07:20,439 --> 00:07:24,360 being an actress, model, and singer. Plaintiff incurred medical and 108 00:07:24,439 --> 00:07:28,639 psychological expenses, and Plaintiff will in the future suffer additional 109 00:07:28,720 --> 00:07:33,519 medical and psychological expenses. These injuries are permanent in nature, 110 00:07:33,800 --> 00:07:37,000 and Plaintiff will continue to suffer these losses in the future. 111 00:07:37,720 --> 00:07:41,519 Cause of Action Number six Conspiracy to commit negligent and 112 00:07:41,600 --> 00:07:47,160 infliction of emotional distress against Glaine Maxwell, Simboly Espinoza, Leslie Groff, 113 00:07:47,360 --> 00:07:52,160 the recruiter, the corporate defendants, and the institutional defendants two eleven. 114 00:07:52,560 --> 00:07:56,680 Plaintiff incorporates by reference all preceding paragraphs and re alleges 115 00:07:56,759 --> 00:08:01,120 them as if set forth fully herein twelve. By reason 116 00:08:01,160 --> 00:08:05,040 thereof Miss Maxwell, Miss Groff, Miss Espinoza, the recruiter, the 117 00:08:05,120 --> 00:08:09,639 corporate defendant, and or the institutional defendants conspired with Jeffrey 118 00:08:09,639 --> 00:08:14,600 Epstein to commit negligent infliction of emotional distress upon Plaintiff 119 00:08:15,160 --> 00:08:19,120 two thirteen. As a direct and proximate result of Miss Maxwell, 120 00:08:19,279 --> 00:08:23,240 miss Groff, miss Espinoza, the recruiter, the corporate defendants, and 121 00:08:23,480 --> 00:08:27,399 or the institutional defendants conspiring with Jeffrey Epstein to commit 122 00:08:27,480 --> 00:08:31,199 negligent infliction of emotional distress. The plaintiff has in the 123 00:08:31,240 --> 00:08:34,159 past suffered and in the future will continue to suffer 124 00:08:34,399 --> 00:08:41,360 physical injury, pain, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, 125 00:08:41,600 --> 00:08:45,159 loss of self esteem, loss of dignity, invasion of her privacy, 126 00:08:45,320 --> 00:08:48,360 and the loss of her capacity to enjoy life, as 127 00:08:48,360 --> 00:08:52,080 well as other damages, including but not limited to dropping 128 00:08:52,080 --> 00:08:54,480 out of high school and giving up on her career 129 00:08:54,840 --> 00:08:59,440 of being an actress, model, and singer. Plaintiff incurred medical 130 00:08:59,480 --> 00:09:02,679 and psychology logical expenses, and plaintiff will in the future 131 00:09:02,919 --> 00:09:07,679 suffer additional medical and psychological expenses. These injuries are permanent 132 00:09:07,720 --> 00:09:11,159 in nature, and plaintiff will continue to suffer these losses 133 00:09:11,360 --> 00:09:16,279 in the future. Cause of Action Number seven Negligent Security 134 00:09:16,320 --> 00:09:21,519 against ninety seventy first Street Corporation, two fourteen. Plaintiff incorporates 135 00:09:21,519 --> 00:09:25,120 by reference all preceding paragraphs and re alleges them as 136 00:09:25,120 --> 00:09:29,200 if set forth fully here in two fifteen, at all 137 00:09:29,240 --> 00:09:33,639 times relevant Herein Defendant ninetist seventy first Street Corporation nine 138 00:09:33,679 --> 00:09:36,799 East was the lawful owner of the property located at 139 00:09:36,919 --> 00:09:40,720 ninety seventy first Street, New York, New York. To sixteen. 140 00:09:41,080 --> 00:09:44,720 Defendant nine East was acquired titled to the property on 141 00:09:44,759 --> 00:09:48,879 September sixth, nineteen eighty nine, and retained such until the 142 00:09:49,039 --> 00:09:53,000 property was fraudulently transferred to Maple Incorporated on December eleventh, 143 00:09:53,000 --> 00:09:58,720 twenty eleven, twenty seventeen. At all relevant herein Defendant ninetists 144 00:09:58,720 --> 00:10:03,840 maintain legal control over the subject premises to eighteen. Epstein 145 00:10:04,120 --> 00:10:07,240 was a regular inhabitant of Defendant nine East, and in 146 00:10:07,279 --> 00:10:10,159 fact resided at the premises when he was present in 147 00:10:10,279 --> 00:10:14,519 New York. To nineteen. Defendant ninetist knew or should have 148 00:10:14,600 --> 00:10:17,320 known when Jeffrey Epstein was in the home owned by 149 00:10:17,360 --> 00:10:21,039 Defendant nine East, and when Jeffrey Epstein had young females, 150 00:10:21,080 --> 00:10:25,320 including minor females such as plaintiff at the premises to 151 00:10:25,480 --> 00:10:28,799 twenty when plaintiff was sexually abused by Jeffrey Epstein in 152 00:10:28,799 --> 00:10:31,679 two thousand and one and two thousand and two, Defendant 153 00:10:31,720 --> 00:10:34,200 nine East, as the owner of the property where all 154 00:10:34,240 --> 00:10:37,080 of the sexual abuse of plaintiff occurred had a duty 155 00:10:37,120 --> 00:10:40,559 to maintain the premises in a reasonably safe condition. To 156 00:10:40,720 --> 00:10:43,639 twenty one, Defendant nine East had a duty to take 157 00:10:43,679 --> 00:10:47,440 care of precautions to protect guests, visitors, or invitees such 158 00:10:47,440 --> 00:10:52,519 as plaintiff from foreseeable harm, including foreseeable conduct. To twenty two, 159 00:10:53,120 --> 00:10:56,679 Defendant nine Easts had a duty to take reasonably precautionary 160 00:10:56,759 --> 00:11:00,000 measures to minimize the risk of sexual assaults upon visit 161 00:11:00,039 --> 00:11:05,399 visitors to the premises, such as plaintiff. Tow twenty three, 162 00:11:05,960 --> 00:11:09,919 Jeffrey Epstein's sexual assault and battery of plaintiff was foreseeable 163 00:11:10,240 --> 00:11:13,759 and no actions and or precautions were taken to prevent 164 00:11:13,840 --> 00:11:17,600 it two twenty four to cite several examples before a 165 00:11:17,679 --> 00:11:20,679 plaintiff was ever lured by Epstein's recruiter to visit the 166 00:11:20,720 --> 00:11:25,159 premises owned by nine East. A Maria Farmer who was 167 00:11:25,240 --> 00:11:28,000 responsible for manning the front door at his New York 168 00:11:28,039 --> 00:11:30,840 mansion and keeping records of people who came to the home. 169 00:11:31,200 --> 00:11:34,600 Miss Farmer witnessed a number of school aged girls coming 170 00:11:34,600 --> 00:11:36,759 to the house. Some of the young girls would be 171 00:11:36,759 --> 00:11:40,759 wearing their school uniforms, who then would be escorted upstairs. 172 00:11:41,159 --> 00:11:44,639 See Maria Farmer's deposition. While miss Farmer was told these 173 00:11:44,679 --> 00:11:48,759 young girls were interviewing for modeling positions, she testified under 174 00:11:48,759 --> 00:11:51,519 oath that it did not seem credible to her that 175 00:11:51,559 --> 00:11:56,279 these young girls were interviewing for modeling positions. B. Another 176 00:11:56,320 --> 00:12:00,759 one of Epstein's household employees, mister Alfredo Rodriguez, testified to 177 00:12:00,759 --> 00:12:04,879 seeing numerous underage girls coming into Epstein's mansion for purported 178 00:12:04,919 --> 00:12:09,639 massages see Alfredo Rodriguez, July twenty ninth, two thousand and nine, 179 00:12:09,720 --> 00:12:14,559 deposition at two forty two through forty four. Rodriguez was 180 00:12:14,600 --> 00:12:17,639 aware that sex toys and vibrators were found in Epstein's 181 00:12:17,639 --> 00:12:21,679 bedroom after the purported massages id at two twenty three 182 00:12:21,960 --> 00:12:25,240 through twenty eight. Rodriguez thought that Epstein was doing was 183 00:12:25,279 --> 00:12:28,039 wrong given the extreme youth of the girls that he saw. 184 00:12:28,720 --> 00:12:33,360 See Juanna Lessi, Epstein's former house manager from nineteen ninety 185 00:12:33,360 --> 00:12:36,639 one to two thousand and two, testified he saw probably 186 00:12:37,039 --> 00:12:39,639 over one hundred girls Sir of Epstein at his mansion 187 00:12:39,840 --> 00:12:44,159 over ten years. See Juanaless's deposition dated September eighth, two 188 00:12:44,159 --> 00:12:47,759 thousand and nine. In Jane Doe number two versus Jeffrey 189 00:12:47,759 --> 00:12:51,480 Epstein Case number zero eight dash CB DASH nine zero 190 00:12:51,519 --> 00:12:55,360 one one nine. After each encounter, Alessi testified he would 191 00:12:55,360 --> 00:12:59,559 clean up the home upstairs massage room. On multiple occasions, 192 00:12:59,559 --> 00:13:02,360 he said he found vibrators or sex toys and put 193 00:13:02,399 --> 00:13:05,679 them in Defendant Maxwell's closet because he knew that's where 194 00:13:05,679 --> 00:13:09,279 they were kept. To twenty five, nearly every day that 195 00:13:09,360 --> 00:13:13,759 Jeffrey Epstein was honor in the property of Defendant ninetists, 196 00:13:13,799 --> 00:13:17,000 he was engaging in criminal sexual behavior in violation of 197 00:13:17,080 --> 00:13:21,879 Article one thirty, including every single encounter described herein with plaintiff. 198 00:13:22,440 --> 00:13:26,279 To twenty six, Defendant ninetiets breached its duty to plaintiff 199 00:13:26,519 --> 00:13:29,799 by failing to take even minimal safety precautions to protect 200 00:13:30,039 --> 00:13:33,840 against the predictable criminal acts of Jeffrey Epstein, which were 201 00:13:33,840 --> 00:13:38,120 reasonably predictable and foreseeable to occur on the property. To 202 00:13:38,279 --> 00:13:42,600 twenty seven, Defendant's ninetiest negligence was approximate cause of the 203 00:13:42,639 --> 00:13:47,240 sexual offenses committed against plaintiff and violation of Article one thirty. 204 00:13:47,720 --> 00:13:50,919 To twenty eight, as a direct and proximate result of 205 00:13:50,960 --> 00:13:54,440 Defendant nine east breach, the plaintiff has in the past 206 00:13:54,480 --> 00:13:58,600 suffered and in the future, will continue to suffer physical injury, pain, 207 00:13:58,919 --> 00:14:04,840 emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of 208 00:14:04,840 --> 00:14:08,279 self esteem, loss of dignity, invasion of her privacy, and 209 00:14:08,320 --> 00:14:11,000 a loss of her capacity to enjoy life, as well 210 00:14:11,039 --> 00:14:15,919 as other damages. Plaintiff incurred medical and psychological expenses, and 211 00:14:16,000 --> 00:14:20,639 plaintiff will in the future suffer additional medical and psychological expenses. 212 00:14:21,039 --> 00:14:24,399 These injuries are permanent in nature, and plaintiff will continue 213 00:14:24,399 --> 00:14:28,159 to suffer these losses in the future. All right, folks, 214 00:14:28,200 --> 00:14:30,399 We're going to wrap up right here and in the 215 00:14:30,440 --> 00:14:33,200 next episode we'll pick up where we left off with 216 00:14:33,279 --> 00:14:36,759 the Cause of Action number eight. All of the information 217 00:14:36,799 --> 00:14:39,519 that goes with this episode can be found in the 218 00:14:39,600 --> 00:14:43,480 description box. What's up, everyone, and welcome back to the 219 00:14:43,519 --> 00:14:46,799 Epstein Chronicles. In this episode, we're going to pick back 220 00:14:46,879 --> 00:14:50,759 up where we left off with Jennifer Aureos and her 221 00:14:50,799 --> 00:14:55,440 claims against Jeffrey Epstein and Jeffrey Epstein's estate. So let's 222 00:14:55,480 --> 00:14:59,360 get right back to it. Cause of Action number nine 223 00:15:00,879 --> 00:15:06,360 against NESLLC nine East seventy first Street Corporation, Leslie Groff, 224 00:15:06,559 --> 00:15:10,720 Simberly Espinoza and or Darren k Endyke and Richard D. 225 00:15:10,840 --> 00:15:14,879 Con in their capacities as executors of the estate of 226 00:15:15,039 --> 00:15:20,159 Jeffrey Epstein two fifty two. The plaintiff incorporates by reference 227 00:15:20,480 --> 00:15:24,039 all preceding paragraphs and realleges them as set fourth here 228 00:15:24,080 --> 00:15:27,799 in two fifty three. It is believed that each employee 229 00:15:27,799 --> 00:15:32,240 of Defendant NES LLC NES operated at the direction of 230 00:15:32,279 --> 00:15:36,440 Jeffrey Epstein nine East New York Strategy Group, Miss Maxwell, 231 00:15:36,679 --> 00:15:41,440 Miss Espinoza, and Miss Groff two fifty four. Upon information 232 00:15:41,519 --> 00:15:46,240 and belief, the primary responsibility of each employee of Defendant 233 00:15:46,320 --> 00:15:50,440 NES was to fulfill the needs or requests of Jeffrey Epstein, 234 00:15:50,799 --> 00:15:55,679 more particularly his daily massage schedule two fifty five. Upon 235 00:15:55,759 --> 00:16:00,840 information and belief, the employees of Defendant NES were compensated primarily, 236 00:16:01,159 --> 00:16:05,720 if not exclusively, to procure or maintain each young female massuse, 237 00:16:06,000 --> 00:16:09,799 or to assist, knowingly or unknowingly, in the concealment of 238 00:16:09,879 --> 00:16:14,960 any misconduct committed against each massuse two fifty six. Upon 239 00:16:15,039 --> 00:16:19,559 information and belief, the employment responsibilities of the various employees 240 00:16:19,559 --> 00:16:23,600 of Defendant NES included, but were not limited to, one 241 00:16:23,799 --> 00:16:27,720 recruiting young females, including minor children, such as plaintiff to 242 00:16:27,759 --> 00:16:33,159 provide massages. Two creating Jeffrey Epstein's massage schedule. Three maintaining 243 00:16:33,240 --> 00:16:38,320 Jeffrey Epstein's massage schedule. Four escorting various young females into 244 00:16:38,360 --> 00:16:40,919 the massage room at the New York mansion owned by 245 00:16:41,000 --> 00:16:45,840 Defendant nine East. Five maintaining contact with various young females 246 00:16:46,000 --> 00:16:48,480 who were recruited to the New York mansion for the 247 00:16:48,519 --> 00:16:53,600 purposes of providing Jeffrey Epstein with massage. Six Providing compensation 248 00:16:53,919 --> 00:16:56,919 to each young massuse upon the completion of her engagement 249 00:16:57,120 --> 00:17:02,279 with Jeffrey Epstein. Seven Meals and food and other services 250 00:17:02,320 --> 00:17:04,920 to the young females in order to provide in air 251 00:17:04,960 --> 00:17:09,200 of legitimacy to the functions of the corporation. Eight Providing 252 00:17:09,200 --> 00:17:13,000 hospitality services to the young females in order to provide 253 00:17:13,039 --> 00:17:17,000 an air of legitimacy to the functions of the corporation. 254 00:17:17,119 --> 00:17:23,359 Nine Providing educational services, ten providing medical services, eleven providing 255 00:17:23,400 --> 00:17:29,319 transportation services, twelve providing housing services. Thirteen providing various other 256 00:17:29,480 --> 00:17:33,440 enticements to ensure the continued operation of the various young 257 00:17:33,480 --> 00:17:40,519 female messuses with defendant nes corporate objective four encouraging individuals, 258 00:17:40,559 --> 00:17:43,319 including the females who were recruited to the house to 259 00:17:43,400 --> 00:17:47,119 provide a massage, to recruit other young females to engage 260 00:17:47,119 --> 00:17:51,240 in the same activity for Jeffrey Epstein, and fifteen coordinating 261 00:17:51,240 --> 00:17:54,799 together and with Jeffrey Epstein to convey a powerful and 262 00:17:54,880 --> 00:17:59,599 legitimate enterprise system capable of gaining cooperation from young females 263 00:17:59,680 --> 00:18:04,200 recruit uited for massages, often minors, such as plaintiff to 264 00:18:04,319 --> 00:18:09,759 fifty seven. In fulfilling their employment responsibilities, each employee voluntarily 265 00:18:09,799 --> 00:18:13,200 assumed the duty with respect to each young female recruited 266 00:18:13,480 --> 00:18:18,319 to massage Jeffrey Epstein, including Plaintiff to fifty eight. To 267 00:18:18,319 --> 00:18:21,880 fulfill said duty, each employee was required to perform their 268 00:18:21,880 --> 00:18:26,279 assumed duty carefully, without omitting to do what an ordinarily 269 00:18:26,319 --> 00:18:30,000 prudent person would do. In accomplishing the task to fifty nine, 270 00:18:30,720 --> 00:18:33,799 the young females being recruited to engage in massages for 271 00:18:33,880 --> 00:18:37,359 Jeffrey Epstein were inexperienced in the art of massage, a 272 00:18:37,359 --> 00:18:39,640 fact that was known or should have been known to 273 00:18:39,799 --> 00:18:44,039 Defendant NES and its employees and management in the exercise 274 00:18:44,119 --> 00:18:49,039 of reasonable care. To sixty. Plaintiff relied on defendants NES 275 00:18:49,079 --> 00:18:52,519 voluntary assumption of a duty, as well as the voluntary 276 00:18:52,519 --> 00:18:57,160 assumption of each individual employee and manager toag with reasonable 277 00:18:57,160 --> 00:19:01,480 care towards her to sixty one. The exercise of reasonable care, 278 00:19:01,799 --> 00:19:05,599 Defendant NES and its employees and managers further new or 279 00:19:05,640 --> 00:19:09,400 should have known of the dangerous propensities of Jeffrey Epstein 280 00:19:09,640 --> 00:19:12,279 and the proximate harm that would be caused by his 281 00:19:12,559 --> 00:19:16,559 likely sexual misconduct and various violations of Article one thirty 282 00:19:16,920 --> 00:19:20,920 to sixty two. The failure of Defendant NES and each 283 00:19:20,960 --> 00:19:23,920 of its respective employees and managers to act in the 284 00:19:23,960 --> 00:19:27,559 same manner as an ordinarily prudent person places plaintiff in 285 00:19:27,599 --> 00:19:31,000 a more vulnerable position than if Defendant NES and its 286 00:19:31,039 --> 00:19:34,799 employees and management had not assumed the obligation to treat 287 00:19:34,799 --> 00:19:38,720 her with reasonable care to sixty three. In breaching its duty, 288 00:19:38,920 --> 00:19:43,319 Defendant NES, its employees, and management launched a force or 289 00:19:43,400 --> 00:19:48,000 instrument of harm directed toward plaintiff. In doing so, Defendant NES, 290 00:19:48,240 --> 00:19:52,319 its employees, and management enhance the risk plaintiff faced and 291 00:19:52,480 --> 00:19:55,960 caused her to forego any opportunity she may otherwise have 292 00:19:56,039 --> 00:19:58,359 had to avoid the risk inherent with being in a 293 00:19:58,440 --> 00:20:02,279 room alone with Jeffreys Epstein to perform a massage as 294 00:20:02,319 --> 00:20:05,720 an untrained minor child and, in the case of Miss Areos, 295 00:20:05,720 --> 00:20:09,799 someone who was not invited there to give massages to 296 00:20:10,000 --> 00:20:14,119 sixty four defendants NES Jeffrey Epstein, nine Niece New York 297 00:20:14,200 --> 00:20:18,880 Strategy Group, Miss Maxwell, Miss Espinoza, and Miss groff negligence 298 00:20:18,960 --> 00:20:23,319 was approximate cause of sexual offenses committed against plaintiff and 299 00:20:23,400 --> 00:20:27,240 violation of Article one thirty to sixty five As a 300 00:20:27,279 --> 00:20:31,799 direct and proximate result of defendant NES Jeffrey Epstein's nine 301 00:20:31,799 --> 00:20:35,720 East New York Strategy Group, Miss Maxwell, Miss Espinoza, and 302 00:20:35,759 --> 00:20:39,640 Miss Groff's negligence, the plaintiff has in the past suffered 303 00:20:39,799 --> 00:20:43,319 and in the future will continue to suffer physical injury, pain, 304 00:20:43,559 --> 00:20:49,480 emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of 305 00:20:49,519 --> 00:20:53,200 self esteem, loss of dignity, invasion of her privacy, and 306 00:20:53,279 --> 00:20:56,160 the loss of her capacity to enjoy life, as well 307 00:20:56,200 --> 00:21:01,079 as other damages. Plaintiff incurred medical and psychological expenses, and 308 00:21:01,160 --> 00:21:05,599 plaintiff will in the future suffer additional medical and psychological expenses. 309 00:21:05,960 --> 00:21:09,559 These injuries are permanent, and plaintiff will continue to suffer 310 00:21:09,599 --> 00:21:16,240 these losses in the future causes of action ten through thirteen. 311 00:21:17,200 --> 00:21:22,400 Fraudulent conveyance against ninety seventy First Street Corporation and Maple Incorporated. 312 00:21:22,759 --> 00:21:27,480 To sixty six. Plaintiff incorporates by reference all preceding paragraphs 313 00:21:27,680 --> 00:21:30,680 and re alleges them as if set forth fully herein 314 00:21:31,559 --> 00:21:34,799 to sixty seven. Defendants were engaged in a business or 315 00:21:34,960 --> 00:21:39,079 transaction to sixty eight. At the time of the fraudulent conveyance, 316 00:21:39,119 --> 00:21:42,400 Plaintiff was a future creditor as defined under the New 317 00:21:42,519 --> 00:21:46,720 York Debtor and Creditor Law to sixty nine. Despite efforts 318 00:21:46,720 --> 00:21:50,079 by Jeffrey Epstein, his attorneys, and the New York prosecutor 319 00:21:50,160 --> 00:21:52,839 to lower his sexual offender status to be filed in 320 00:21:52,960 --> 00:21:56,720 New York, on November seventeenth, twenty eleven, a New York 321 00:21:56,759 --> 00:22:00,599 Appeals Court upheld a lower court's ruling that Epstein register 322 00:22:01,000 --> 00:22:04,359 as New York's highest level sex offender. A Level three 323 00:22:04,440 --> 00:22:07,440 status means high risk of repeat offense and a threat 324 00:22:07,480 --> 00:22:12,279 to public safety exists, according to the state's guidelines two seventy, 325 00:22:12,759 --> 00:22:15,559 just four business days after being ordered to register as 326 00:22:15,640 --> 00:22:18,680 New York's highest level sex offender and have regular ninety 327 00:22:18,759 --> 00:22:22,279 eight check ins as required by law on November twenty three, 328 00:22:22,359 --> 00:22:25,440 twenty eleven, in an order to shield himself and his 329 00:22:25,519 --> 00:22:29,519 property owned by nine East located at ninety seventy first Street, 330 00:22:30,400 --> 00:22:32,640 where all of the crimes in the state occurred against 331 00:22:32,640 --> 00:22:36,240 missus Areos and so many other victims from claims of 332 00:22:36,279 --> 00:22:40,279 current and future creditors whose claims had not matured, Epstein 333 00:22:40,640 --> 00:22:44,759 fraudently transferred title the property for nine East of the 334 00:22:44,839 --> 00:22:49,559 Virgin Islands based company Maple Incorporated, another company controlled by them, 335 00:22:49,839 --> 00:22:53,920 to seventy one. The transferred documents list Epstein as president 336 00:22:53,960 --> 00:22:56,920 of both nine East and Maple, and show a mortgage 337 00:22:56,960 --> 00:23:00,880 of zero dollars and consideration paid of ten dollars for 338 00:23:00,920 --> 00:23:05,279 the transaction, despite the property being conservatively valued by Jeffrey 339 00:23:05,279 --> 00:23:08,559 Epstein's own admission at fifty five million, nine hundred and 340 00:23:08,599 --> 00:23:12,440 thirty one thousand dollars two seventy two. At the time 341 00:23:12,480 --> 00:23:16,599 of the fraudulent transfers, defendants were aware of current legal 342 00:23:16,640 --> 00:23:19,920 claims against Epstein and new or reasonably should have known 343 00:23:20,079 --> 00:23:24,680 about plaintiff's potential exposure to Missoreos for future legal claims 344 00:23:25,039 --> 00:23:28,960 to seventy three at the time of fraudulent conveyance plaintiff's 345 00:23:29,000 --> 00:23:32,920 claims against Epstein had not matured two seventy four. The 346 00:23:32,960 --> 00:23:37,279 fraudulent transfers were effectuated for the express purpose of evading 347 00:23:37,319 --> 00:23:42,279 financial liability to current and future creditors, including plaintiff two 348 00:23:42,319 --> 00:23:47,039 seventy five. Defendants by these fraudulent transfers intended to hinder, delay, 349 00:23:47,119 --> 00:23:51,440 or defraud both present and future creditors, including plaintiff, from 350 00:23:51,519 --> 00:23:54,559 satisfying any judgment they may have had against the property 351 00:23:54,799 --> 00:23:57,480 where all of the sexual crimes and violation of Article 352 00:23:57,519 --> 00:24:02,160 one thirty of Miners occurred. To seventy six defendants, fraudulent 353 00:24:02,200 --> 00:24:06,240 conveyances were made without fair consideration, despite the person making it, 354 00:24:06,440 --> 00:24:10,000 Jeffrey Epstein, being a defendant in actions for money judgments 355 00:24:10,359 --> 00:24:14,319 to seventy seven. The conveyances were fraudulent as to the 356 00:24:14,359 --> 00:24:18,119 plaintiff as a future creditor as defined under New York 357 00:24:18,160 --> 00:24:22,599 debtor creditor law to seventy eight. Plaintiff is therefore entitled 358 00:24:22,680 --> 00:24:26,680 to avoid the fraudulent transfers. To seventy nine. Plaintiff is 359 00:24:26,680 --> 00:24:31,000 thereby entitled to attach or levy execution upon any property 360 00:24:31,119 --> 00:24:34,799 or assets that were fraudulently conveyed to eighty In addition, 361 00:24:35,039 --> 00:24:39,480 plaintiff is entitled to recover interest, costs and disbursements of 362 00:24:39,519 --> 00:24:43,559 this action, including reasonable attorney fees pursu into New York 363 00:24:43,599 --> 00:24:48,160 Debtor and Creditor Law. To eighty one, Defendants have violated 364 00:24:48,400 --> 00:24:51,799 each of the following sections of New York Debtor Creditor 365 00:24:51,920 --> 00:24:56,480 Law seventy three A to seventy six to seventy six 366 00:24:56,839 --> 00:25:01,839 A and two seventy nine. Wherefore, Plaintiff demands judgment against 367 00:25:01,839 --> 00:25:05,400 defendants as follows. One on the first cause of action 368 00:25:05,480 --> 00:25:09,480 assessing compensentory damages and punitive damages in an amount to 369 00:25:09,519 --> 00:25:12,799 be determined at trial. Two on the second cause of action, 370 00:25:13,160 --> 00:25:17,240 assessing compensentory damages and punitive damages in an amount to 371 00:25:17,240 --> 00:25:20,279 be determined at trial. On the third cause of action, 372 00:25:20,640 --> 00:25:24,359 assessing compensentory damages in an amount to be determined at trial. 373 00:25:25,000 --> 00:25:28,599 Four on the fourth cause of action, compensentory and punitive 374 00:25:28,680 --> 00:25:32,000 damages in an amount to be determined at trial. Five 375 00:25:32,359 --> 00:25:36,039 on the fifth cause of action, compensentory and punitive damages 376 00:25:36,079 --> 00:25:39,160 in an amount to be determined at trial. Number six 377 00:25:39,559 --> 00:25:42,960 on the sixth cause of action, competentory and punitive damages 378 00:25:43,079 --> 00:25:46,359 in an amount to be determined at trial seven on 379 00:25:46,400 --> 00:25:49,880 the seventh cause of action. Compensentory and punitive damages in 380 00:25:49,920 --> 00:25:53,400 an amount to be determined at trial eight on the 381 00:25:53,400 --> 00:25:57,079 eighth cause of action. Compensentory and punitive damages in an 382 00:25:57,079 --> 00:26:00,160 amount to be determined at trial number nine on the 383 00:26:00,240 --> 00:26:04,000 ninth cause of action, Compensentory and punitive damages in an 384 00:26:04,000 --> 00:26:07,880 amount to be determined at trial on the tenth cause 385 00:26:07,920 --> 00:26:11,599 of action. Compensentory damages to be determined at trial on 386 00:26:11,680 --> 00:26:15,319 the eleventh cause of action, Competentory damages to be determined 387 00:26:15,480 --> 00:26:20,039 at trial on the twelfth cause of action. Compensentory damages 388 00:26:20,079 --> 00:26:23,240 to be determined at trial on the thirteenth cause of action. 389 00:26:23,480 --> 00:26:27,440 Competentory damages to be determined at trial on the fourteenth 390 00:26:27,440 --> 00:26:31,279 cause of action, Compensantory damages to be determined at trial 391 00:26:31,720 --> 00:26:35,039 on the fifteenth cause of action. Compensentory damages to be 392 00:26:35,079 --> 00:26:39,000 determined at trial on the sixteenth cause of action, Competentory 393 00:26:39,079 --> 00:26:43,359 damages to be determined a trial on seventeen cause of action. 394 00:26:43,559 --> 00:26:47,559 Compensentory damages to be determined at trial number eighteen for 395 00:26:47,599 --> 00:26:51,440 a Court order voiding any and all fraudulent conveyances number 396 00:26:51,519 --> 00:26:55,599 nineteen attorney fees and interest and disbursements, and number twenty 397 00:26:55,759 --> 00:26:58,920 for such other relief as the Court deems just and proper. 398 00:27:00,200 --> 00:27:04,880 This document was signed by Daniel Kaiser and it was 399 00:27:05,039 --> 00:27:09,960 dated October tenth, twenty nineteen. And this is going to 400 00:27:09,960 --> 00:27:14,400 wrap up Jennifer Areos and Hurr complaints against Jeffrey Epstein's estate. 401 00:27:15,559 --> 00:27:18,200 All of the information that goes with this episode can 402 00:27:18,240 --> 00:27:20,200 be found in the description box.