Speaker 1: What's up everyone, and welcome back to the Epstein Chronicles.
In this episode, we're picking back up where we left
off with Jennifer Aureos and her claims against Jeffrey Epstein
and his estate. Part seven. Cause of Action one Sexual
assault and battery against Darren Kayen Dyke and Richard D.
Con in their capacities as executors of the estate of
Jeffrey E. Epstein one ninety five. Plaintiff incorporates by reference
all preceding paragraphs and re alleges them as if set
forth fully Herein one ninety six, Jeffrey Epstein made violent
sexual demands on plaintiff while placing his hands on our body,
and committed repeated acts of harmful or offensive touching against
plaintiff one ninety seven. These demands were intended to intimidate
plaintiff and force her to submit to his sexual requests
one ninety eight. As a direct and proximate result of
Jeffrey Epstein's repeated sexual assaults and battery of the plaintiff,
she has in the past suffered, and in the future
will continue to suffer physical injury, pain, emotional distress, psychological trauma,
mental anguish, humiliation, embarrassment, loss of self esteem, loss of dignity,
invasion of her privacy, and the loss of her capacity
to enjoy life, as well as other damages, including but
not limited to dropping out of high school and giving
up on her career of being an actress, model, and
a singer. Plaintiff incurred medical and psychological expenses, and Plaintiff
will in the future suffer additional medical and psychological expenses.
These injuries are permanent in nature, and plaintiff will continue
to suffer these losses in the future. Cause of Action
number two intentional infliction of emotional distress against Darren kay
Endyke and Richard D. Conn in their capacities as executors
of the estate of Jeffrey E. Epstein. Plaintiff incorporates by
reference all preceding paragraphs and realleges them as if set
forth fully herein two hundred. Jeffrey Epstein's outrageous and unconscionable conduct,
which violated all norms of decent and civil society, was
an intentional infliction of emotional distress upon plaintiff two oh one.
As a direct and proximate result of Jeffrey Epstein's intentional
infliction of emotional distress. The plaintiff has in the past
suffered and in the future will continue to suffer physical injury, pain,
emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self esteem, loss of dignity, invasion of her privacy, and
a loss of her capacity to enjoy life, as well
as other damages, including but not limited to dropping out
of high school and giving up on her career of
being an actress, model, and singer. Plaintiff incurred medical and
psychological expenses, and plaintiff will in the future suffer additional
medical and psychological expenses. These injuries are permanent in nature,
and plaintiff will continue to suffer these losses in the future.
Cause of Action number three negligent infliction of emotional distress
against Darren kay Endyke and Richard D. Con in their
capacities as executors of the estate of Jeffrey E. Epstein.
Two two. Plaintiff incorporates by reference all preceding paragraphs and
realleges them as if set forth fully herein two three.
By reason thereof Jeffrey Epstein committed negligent infliction of emotional
distress upon plaintiff two O four as a direct and
proximate result of Jeffrey Epstein's negligent infliction of emotional distress.
The plaintiff has in the past suffered, and in the
future will continue to suffer physical injury, pain, emotional distress,
psychological trauma, mental anguish, humiliation, embarrassment, loss of self esteem,
loss of dignity, invasion of her privacy, and the loss
of her capacity to enjoy life, as well as other damages,
including but not limited to dropping out of high school
and giving up on her career of being an actress, model,
and singer. Plaintiff incurred medical and psychological expenses, and plaintiff
will in the future suffer additional medical and psychological expenses.
These injuries are permanent in nature, and plaintiff will continue
to suffer these losses in the future. Cause of Action
Number four conspiracy to commit sexual assault and battery against
Glenn Maxwell, Leslie Groff, Simberly Espinoza, the recruiter, the corporate defendants,
and or the institutional defendants. Two five. Plaintiff incorporates by
reference all preceding paragraphs and re alleges them as if
set forth fully Herein two six. Miss Maxwell, Miss Groff,
Miss Espinoza, the recruiter, the corporate defendants, end or institutional
defendants conspired with Jeffrey Epstein to commit repeated acts of
sexual assault and harmful or offensive touching against Plaintiff two
O seven as a t direct and proximate result of
Miss Maxwell, Miss Groff, Miss Espinoza, the recruiter, the corporate defendants,
and or the institutional defendants conspiring with Jeffrey Epstein to
commit repeated acts of sexual assault and battery against the plaintiff.
She has in the past suffered and in the future
will continue to suffer physical injury, pain, emotional distress, psychological trauma,
mental anguish, humiliation, embarrassment, loss of self esteem, loss of dignity,
invasion of her privacy, and the loss of her capacity
to enjoy life, as well as other damages, including but
not limited to dropping out of high school and giving
up on her career of being an actress, model, and singer.
Plaintiff incurred medical and psychological expenses, and plaintiff will in
the future suffer additional medical and psychological expenses. These injuries
are permanent in nature, and plaintiff will continue to suffer
these losses in the future Cause of action Number five
Conspiracy to commit intentional infliction of emotional distress against Glen Maxwell,
Leslie Groff, simply Espinoza, the recruiter, the corporate defendants, and
or institutional defendants two eight. Plaintiff incorporates by reference all
preceding paragraphs and realleges them as if set forth fully
herein two oh nine, Miss Maxwell, miss Groff, Miss Espinoza,
the recruiter, the corporate defendants, and or the institutional defendants
conspired with Jeffrey Epstein to commit outrageous and unconscionable conduct
which violated all norms of decent and civil society, and
was an intentional infliction of emotional distress upon Plaintiff two ten.
As a direct and proximate result of Miss Maxwell, miss Groff,
Miss Espinoza, the recruiter, the corporate defendants, end or the
institutional defendants conspiring with Jeffrey Epstein to commit intentional infliction
of emotional distress, the plaintiff has in the past suffered,
and in the future will continue to suffer physical injury, pain,
emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self esteem, loss of dignity, invasion of her privacy, and
a loss for her capacity to enjoy life, as well
as other damages, including but not limited to dropping out
of high school and giving up on her career of
being an actress, model, and singer. Plaintiff incurred medical and
psychological expenses, and Plaintiff will in the future suffer additional
medical and psychological expenses. These injuries are permanent in nature,
and Plaintiff will continue to suffer these losses in the future.
Cause of Action Number six Conspiracy to commit negligent and
infliction of emotional distress against Glaine Maxwell, Simboly Espinoza, Leslie Groff,
the recruiter, the corporate defendants, and the institutional defendants two eleven.
Plaintiff incorporates by reference all preceding paragraphs and re alleges
them as if set forth fully herein twelve. By reason
thereof Miss Maxwell, Miss Groff, Miss Espinoza, the recruiter, the
corporate defendant, and or the institutional defendants conspired with Jeffrey
Epstein to commit negligent infliction of emotional distress upon Plaintiff
two thirteen. As a direct and proximate result of Miss Maxwell,
miss Groff, miss Espinoza, the recruiter, the corporate defendants, and
or the institutional defendants conspiring with Jeffrey Epstein to commit
negligent infliction of emotional distress. The plaintiff has in the
past suffered and in the future will continue to suffer
physical injury, pain, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment,
loss of self esteem, loss of dignity, invasion of her privacy,
and the loss of her capacity to enjoy life, as
well as other damages, including but not limited to dropping
out of high school and giving up on her career
of being an actress, model, and singer. Plaintiff incurred medical
and psychology logical expenses, and plaintiff will in the future
suffer additional medical and psychological expenses. These injuries are permanent
in nature, and plaintiff will continue to suffer these losses
in the future. Cause of Action Number seven Negligent Security
against ninety seventy first Street Corporation, two fourteen. Plaintiff incorporates
by reference all preceding paragraphs and re alleges them as
if set forth fully here in two fifteen, at all
times relevant Herein Defendant ninetist seventy first Street Corporation nine
East was the lawful owner of the property located at
ninety seventy first Street, New York, New York. To sixteen.
Defendant nine East was acquired titled to the property on
September sixth, nineteen eighty nine, and retained such until the
property was fraudulently transferred to Maple Incorporated on December eleventh,
twenty eleven, twenty seventeen. At all relevant herein Defendant ninetists
maintain legal control over the subject premises to eighteen. Epstein
was a regular inhabitant of Defendant nine East, and in
fact resided at the premises when he was present in
New York. To nineteen. Defendant ninetist knew or should have
known when Jeffrey Epstein was in the home owned by
Defendant nine East, and when Jeffrey Epstein had young females,
including minor females such as plaintiff at the premises to
twenty when plaintiff was sexually abused by Jeffrey Epstein in
two thousand and one and two thousand and two, Defendant
nine East, as the owner of the property where all
of the sexual abuse of plaintiff occurred had a duty
to maintain the premises in a reasonably safe condition. To
twenty one, Defendant nine East had a duty to take
care of precautions to protect guests, visitors, or invitees such
as plaintiff from foreseeable harm, including foreseeable conduct. To twenty two,
Defendant nine Easts had a duty to take reasonably precautionary
measures to minimize the risk of sexual assaults upon visit
visitors to the premises, such as plaintiff. Tow twenty three,
Jeffrey Epstein's sexual assault and battery of plaintiff was foreseeable
and no actions and or precautions were taken to prevent
it two twenty four to cite several examples before a
plaintiff was ever lured by Epstein's recruiter to visit the
premises owned by nine East. A Maria Farmer who was
responsible for manning the front door at his New York
mansion and keeping records of people who came to the home.
Miss Farmer witnessed a number of school aged girls coming
to the house. Some of the young girls would be
wearing their school uniforms, who then would be escorted upstairs.
See Maria Farmer's deposition. While miss Farmer was told these
young girls were interviewing for modeling positions, she testified under
oath that it did not seem credible to her that
these young girls were interviewing for modeling positions. B. Another
one of Epstein's household employees, mister Alfredo Rodriguez, testified to
seeing numerous underage girls coming into Epstein's mansion for purported
massages see Alfredo Rodriguez, July twenty ninth, two thousand and nine,
deposition at two forty two through forty four. Rodriguez was
aware that sex toys and vibrators were found in Epstein's
bedroom after the purported massages id at two twenty three
through twenty eight. Rodriguez thought that Epstein was doing was
wrong given the extreme youth of the girls that he saw.
See Juanna Lessi, Epstein's former house manager from nineteen ninety
one to two thousand and two, testified he saw probably
over one hundred girls Sir of Epstein at his mansion
over ten years. See Juanaless's deposition dated September eighth, two
thousand and nine. In Jane Doe number two versus Jeffrey
Epstein Case number zero eight dash CB DASH nine zero
one one nine. After each encounter, Alessi testified he would
clean up the home upstairs massage room. On multiple occasions,
he said he found vibrators or sex toys and put
them in Defendant Maxwell's closet because he knew that's where
they were kept. To twenty five, nearly every day that
Jeffrey Epstein was honor in the property of Defendant ninetists,
he was engaging in criminal sexual behavior in violation of
Article one thirty, including every single encounter described herein with plaintiff.
To twenty six, Defendant ninetiets breached its duty to plaintiff
by failing to take even minimal safety precautions to protect
against the predictable criminal acts of Jeffrey Epstein, which were
reasonably predictable and foreseeable to occur on the property. To
twenty seven, Defendant's ninetiest negligence was approximate cause of the
sexual offenses committed against plaintiff and violation of Article one thirty.
To twenty eight, as a direct and proximate result of
Defendant nine east breach, the plaintiff has in the past
suffered and in the future, will continue to suffer physical injury, pain,
emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self esteem, loss of dignity, invasion of her privacy, and
a loss of her capacity to enjoy life, as well
as other damages. Plaintiff incurred medical and psychological expenses, and
plaintiff will in the future suffer additional medical and psychological expenses.
These injuries are permanent in nature, and plaintiff will continue
to suffer these losses in the future. All right, folks,
We're going to wrap up right here and in the
next episode we'll pick up where we left off with
the Cause of Action number eight. All of the information
that goes with this episode can be found in the
description box. What's up, everyone, and welcome back to the
Epstein Chronicles. In this episode, we're going to pick back
up where we left off with Jennifer Aureos and her
claims against Jeffrey Epstein and Jeffrey Epstein's estate. So let's
get right back to it. Cause of Action number nine
against NESLLC nine East seventy first Street Corporation, Leslie Groff,
Simberly Espinoza and or Darren k Endyke and Richard D.
Con in their capacities as executors of the estate of
Jeffrey Epstein two fifty two. The plaintiff incorporates by reference
all preceding paragraphs and realleges them as set fourth here
in two fifty three. It is believed that each employee
of Defendant NES LLC NES operated at the direction of
Jeffrey Epstein nine East New York Strategy Group, Miss Maxwell,
Miss Espinoza, and Miss Groff two fifty four. Upon information
and belief, the primary responsibility of each employee of Defendant
NES was to fulfill the needs or requests of Jeffrey Epstein,
more particularly his daily massage schedule two fifty five. Upon
information and belief, the employees of Defendant NES were compensated primarily,
if not exclusively, to procure or maintain each young female massuse,
or to assist, knowingly or unknowingly, in the concealment of
any misconduct committed against each massuse two fifty six. Upon
information and belief, the employment responsibilities of the various employees
of Defendant NES included, but were not limited to, one
recruiting young females, including minor children, such as plaintiff to
provide massages. Two creating Jeffrey Epstein's massage schedule. Three maintaining
Jeffrey Epstein's massage schedule. Four escorting various young females into
the massage room at the New York mansion owned by
Defendant nine East. Five maintaining contact with various young females
who were recruited to the New York mansion for the
purposes of providing Jeffrey Epstein with massage. Six Providing compensation
to each young massuse upon the completion of her engagement
with Jeffrey Epstein. Seven Meals and food and other services
to the young females in order to provide in air
of legitimacy to the functions of the corporation. Eight Providing
hospitality services to the young females in order to provide
an air of legitimacy to the functions of the corporation.
Nine Providing educational services, ten providing medical services, eleven providing
transportation services, twelve providing housing services. Thirteen providing various other
enticements to ensure the continued operation of the various young
female messuses with defendant nes corporate objective four encouraging individuals,
including the females who were recruited to the house to
provide a massage, to recruit other young females to engage
in the same activity for Jeffrey Epstein, and fifteen coordinating
together and with Jeffrey Epstein to convey a powerful and
legitimate enterprise system capable of gaining cooperation from young females
recruit uited for massages, often minors, such as plaintiff to
fifty seven. In fulfilling their employment responsibilities, each employee voluntarily
assumed the duty with respect to each young female recruited
to massage Jeffrey Epstein, including Plaintiff to fifty eight. To
fulfill said duty, each employee was required to perform their
assumed duty carefully, without omitting to do what an ordinarily
prudent person would do. In accomplishing the task to fifty nine,
the young females being recruited to engage in massages for
Jeffrey Epstein were inexperienced in the art of massage, a
fact that was known or should have been known to
Defendant NES and its employees and management in the exercise
of reasonable care. To sixty. Plaintiff relied on defendants NES
voluntary assumption of a duty, as well as the voluntary
assumption of each individual employee and manager toag with reasonable
care towards her to sixty one. The exercise of reasonable care,
Defendant NES and its employees and managers further new or
should have known of the dangerous propensities of Jeffrey Epstein
and the proximate harm that would be caused by his
likely sexual misconduct and various violations of Article one thirty
to sixty two. The failure of Defendant NES and each
of its respective employees and managers to act in the
same manner as an ordinarily prudent person places plaintiff in
a more vulnerable position than if Defendant NES and its
employees and management had not assumed the obligation to treat
her with reasonable care to sixty three. In breaching its duty,
Defendant NES, its employees, and management launched a force or
instrument of harm directed toward plaintiff. In doing so, Defendant NES,
its employees, and management enhance the risk plaintiff faced and
caused her to forego any opportunity she may otherwise have
had to avoid the risk inherent with being in a
room alone with Jeffreys Epstein to perform a massage as
an untrained minor child and, in the case of Miss Areos,
someone who was not invited there to give massages to
sixty four defendants NES Jeffrey Epstein, nine Niece New York
Strategy Group, Miss Maxwell, Miss Espinoza, and Miss groff negligence
was approximate cause of sexual offenses committed against plaintiff and
violation of Article one thirty to sixty five As a
direct and proximate result of defendant NES Jeffrey Epstein's nine
East New York Strategy Group, Miss Maxwell, Miss Espinoza, and
Miss Groff's negligence, the plaintiff has in the past suffered
and in the future will continue to suffer physical injury, pain,
emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self esteem, loss of dignity, invasion of her privacy, and
the loss of her capacity to enjoy life, as well
as other damages. Plaintiff incurred medical and psychological expenses, and
plaintiff will in the future suffer additional medical and psychological expenses.
These injuries are permanent, and plaintiff will continue to suffer
these losses in the future causes of action ten through thirteen.
Fraudulent conveyance against ninety seventy First Street Corporation and Maple Incorporated.
To sixty six. Plaintiff incorporates by reference all preceding paragraphs
and re alleges them as if set forth fully herein
to sixty seven. Defendants were engaged in a business or
transaction to sixty eight. At the time of the fraudulent conveyance,
Plaintiff was a future creditor as defined under the New
York Debtor and Creditor Law to sixty nine. Despite efforts
by Jeffrey Epstein, his attorneys, and the New York prosecutor
to lower his sexual offender status to be filed in
New York, on November seventeenth, twenty eleven, a New York
Appeals Court upheld a lower court's ruling that Epstein register
as New York's highest level sex offender. A Level three
status means high risk of repeat offense and a threat
to public safety exists, according to the state's guidelines two seventy,
just four business days after being ordered to register as
New York's highest level sex offender and have regular ninety
eight check ins as required by law on November twenty three,
twenty eleven, in an order to shield himself and his
property owned by nine East located at ninety seventy first Street,
where all of the crimes in the state occurred against
missus Areos and so many other victims from claims of
current and future creditors whose claims had not matured, Epstein
fraudently transferred title the property for nine East of the
Virgin Islands based company Maple Incorporated, another company controlled by them,
to seventy one. The transferred documents list Epstein as president
of both nine East and Maple, and show a mortgage
of zero dollars and consideration paid of ten dollars for
the transaction, despite the property being conservatively valued by Jeffrey
Epstein's own admission at fifty five million, nine hundred and
thirty one thousand dollars two seventy two. At the time
of the fraudulent transfers, defendants were aware of current legal
claims against Epstein and new or reasonably should have known
about plaintiff's potential exposure to Missoreos for future legal claims
to seventy three at the time of fraudulent conveyance plaintiff's
claims against Epstein had not matured two seventy four. The
fraudulent transfers were effectuated for the express purpose of evading
financial liability to current and future creditors, including plaintiff two
seventy five. Defendants by these fraudulent transfers intended to hinder, delay,
or defraud both present and future creditors, including plaintiff, from
satisfying any judgment they may have had against the property
where all of the sexual crimes and violation of Article
one thirty of Miners occurred. To seventy six defendants, fraudulent
conveyances were made without fair consideration, despite the person making it,
Jeffrey Epstein, being a defendant in actions for money judgments
to seventy seven. The conveyances were fraudulent as to the
plaintiff as a future creditor as defined under New York
debtor creditor law to seventy eight. Plaintiff is therefore entitled
to avoid the fraudulent transfers. To seventy nine. Plaintiff is
thereby entitled to attach or levy execution upon any property
or assets that were fraudulently conveyed to eighty In addition,
plaintiff is entitled to recover interest, costs and disbursements of
this action, including reasonable attorney fees pursu into New York
Debtor and Creditor Law. To eighty one, Defendants have violated
each of the following sections of New York Debtor Creditor
Law seventy three A to seventy six to seventy six
A and two seventy nine. Wherefore, Plaintiff demands judgment against
defendants as follows. One on the first cause of action
assessing compensentory damages and punitive damages in an amount to
be determined at trial. Two on the second cause of action,
assessing compensentory damages and punitive damages in an amount to
be determined at trial. On the third cause of action,
assessing compensentory damages in an amount to be determined at trial.
Four on the fourth cause of action, compensentory and punitive
damages in an amount to be determined at trial. Five
on the fifth cause of action, compensentory and punitive damages
in an amount to be determined at trial. Number six
on the sixth cause of action, competentory and punitive damages
in an amount to be determined at trial seven on
the seventh cause of action. Compensentory and punitive damages in
an amount to be determined at trial eight on the
eighth cause of action. Compensentory and punitive damages in an
amount to be determined at trial number nine on the
ninth cause of action, Compensentory and punitive damages in an
amount to be determined at trial on the tenth cause
of action. Compensentory damages to be determined at trial on
the eleventh cause of action, Competentory damages to be determined
at trial on the twelfth cause of action. Compensentory damages
to be determined at trial on the thirteenth cause of action.
Competentory damages to be determined at trial on the fourteenth
cause of action, Compensantory damages to be determined at trial
on the fifteenth cause of action. Compensentory damages to be
determined at trial on the sixteenth cause of action, Competentory
damages to be determined a trial on seventeen cause of action.
Compensentory damages to be determined at trial number eighteen for
a Court order voiding any and all fraudulent conveyances number
nineteen attorney fees and interest and disbursements, and number twenty
for such other relief as the Court deems just and proper.
This document was signed by Daniel Kaiser and it was
dated October tenth, twenty nineteen. And this is going to
wrap up Jennifer Areos and Hurr complaints against Jeffrey Epstein's estate.
All of the information that goes with this episode can
be found in the description box.