1 00:00:00,200 --> 00:00:02,879 Speaker 1: What's up, everyone, and welcome to another episode of The 2 00:00:03,120 --> 00:00:06,440 Diddy Diaries. In this episode, we're picking up where we 3 00:00:06,559 --> 00:00:12,720 left off with Ashley Parum's amended complaint against Ditty, Odell, Beckham, Drewski, 4 00:00:12,919 --> 00:00:17,480 Jaguar Wright and others. Fifteenth Cause of Action Trafficking and 5 00:00:17,600 --> 00:00:22,399 Victims Protection Act Plaintiff against all defendants. Plaintiffs incorporate by 6 00:00:22,440 --> 00:00:25,559 reference and re allege each of the preceding paragraphs and 7 00:00:25,600 --> 00:00:28,760 all paragraphs below, as though fully set forth and brought 8 00:00:29,000 --> 00:00:36,359 in this cause of action. Defendants knowingly and intentionally participated in, perpetrated, assisted, supported, 9 00:00:36,600 --> 00:00:39,799 and facilitated a sex trafficking venture that was in and 10 00:00:39,920 --> 00:00:44,439 affecting interstate and foreign commerce, together and with others, in 11 00:00:44,520 --> 00:00:48,719 violation of US Code Section fifteen ninety, among other things. 12 00:00:48,719 --> 00:00:53,920 Defendants knowingly and intentionally recruited, enticed, provided, obtained, advertised, and 13 00:00:54,000 --> 00:00:58,159 solicited by various means Plaintiffs knowing that defendants would use 14 00:00:58,159 --> 00:01:01,240 means of force, threats of force, ford coercion, and a 15 00:01:01,240 --> 00:01:04,680 combination of such means to cause plaintiffs to engage in 16 00:01:04,799 --> 00:01:09,159 non consensual sex acts. Defendants had actual knowledge that they 17 00:01:09,200 --> 00:01:13,480 were perpetrating and facilitating defendant Ditty's sexual abuse and sex 18 00:01:13,519 --> 00:01:19,079 trafficking conspiracy to recruit, solicit, entice, coerce, harbor, transport, obtain, 19 00:01:19,400 --> 00:01:22,920 and provide plaintiffs into non consensual sex acts through the 20 00:01:22,959 --> 00:01:26,079 means of force, threats of force, fraud, abuse of process, 21 00:01:26,560 --> 00:01:33,159 and coersion. Despite such knowledge, defendants intentionally paid for, facilitated, perpetrated, 22 00:01:33,239 --> 00:01:37,280 and participated in defending Ditty's violations of US Code Section 23 00:01:37,359 --> 00:01:41,799 fifteen ninety, which defendants knew and were in reckless disregard 24 00:01:41,840 --> 00:01:44,760 of the fact that Defendant Ditty would coerce the fraud 25 00:01:44,799 --> 00:01:49,680 and force plaintiffs to engage in nonconsensual sex acts. Defendants 26 00:01:49,719 --> 00:01:53,640 actions were in and affecting interstate and foreign commerce. By 27 00:01:53,640 --> 00:01:57,519 taking the concrete steps alleged in this complaint, defendants knowingly 28 00:01:57,599 --> 00:02:00,680 participated in sex trafficking and for a hither the Ditty 29 00:02:00,760 --> 00:02:05,239 Sexual Abuse and Cover Up enterprise. The concrete steps constituted 30 00:02:05,280 --> 00:02:08,400 taking part in the sex trafficking venture and were necessary 31 00:02:08,400 --> 00:02:13,080 for its success. The concrete steps constituted active engagement by 32 00:02:13,120 --> 00:02:16,319 defendants in the Ditty Sexual Abuse and cover up enterprise. 33 00:02:16,800 --> 00:02:19,719 Defendants knew that its active engagement would lead to the 34 00:02:19,759 --> 00:02:25,000 cause coercive sex trafficking defendants affirmative conduct was committed knowing 35 00:02:25,080 --> 00:02:28,319 and in reckless disregard of the facts that Defendant Ditty 36 00:02:28,360 --> 00:02:31,680 would use as means and influence to force an intimidate 37 00:02:31,719 --> 00:02:36,280 plaintiff into engaging in non consensual sex acts. Defendant's conduct 38 00:02:36,319 --> 00:02:41,479 was outrageous and intentional. Defendants knowing and intentional conduct has 39 00:02:41,479 --> 00:02:47,159 caused plaintiff's serious harm, including without limitation, physical, psychological, emotional, financial, 40 00:02:47,319 --> 00:02:51,800 and reputational harm. Defendants knowing and intentional conduct has caused 41 00:02:51,800 --> 00:02:55,680 plaintiff's harm that are sufficiently serious under all the surrounding 42 00:02:55,719 --> 00:02:59,800 circumstances to compel a reasonable person of the same background 43 00:03:00,120 --> 00:03:03,280 and in the same circumstances to perform or to continue 44 00:03:03,280 --> 00:03:07,680 performing non consensual sexual activity to avoid incurring further harm. 45 00:03:08,120 --> 00:03:12,560 Defendant's criminal conduct in perpetrating TVPA violations was outrageous and 46 00:03:12,680 --> 00:03:16,199 intentional because it was deliberate further into a widespread and 47 00:03:16,360 --> 00:03:21,759 dangerous criminal sex trafficking organization. Defendant's criminal conduct also evinced 48 00:03:21,800 --> 00:03:25,240 a high degree of moral perptitude and demonstrated such wanton 49 00:03:25,240 --> 00:03:29,159 dishonesty as to imply a criminal indifference to civil obligations. 50 00:03:30,120 --> 00:03:34,599 Defendants criminal conduct was directed specifically at plaintiffs who was 51 00:03:34,599 --> 00:03:38,360 the victim of defendant ditty sexual abuse and sex trafficking. 52 00:03:39,240 --> 00:03:42,759 Defendant's outrageous and intentional conduct in this case is part 53 00:03:42,800 --> 00:03:46,159 of a pattern and practice of profiting by undertaking illegal, 54 00:03:46,240 --> 00:03:50,479 high risk, high reward actions by virtue of these knowing 55 00:03:50,520 --> 00:03:54,319 and intentional violations of US Code eighteen, section fifteen ninety 56 00:03:54,520 --> 00:03:58,039 and fifteen ninety five. Defendants reliable to plaintiffs for the 57 00:03:58,080 --> 00:04:02,560 damages they sustained and reasonable attorney fees by virtue of 58 00:04:02,599 --> 00:04:06,400 these intentional and outrageous violations of US Code eighteen, section 59 00:04:06,439 --> 00:04:11,439 fifteen ninety and fifteen ninety five. Defendants reliable to plaintiffs. 60 00:04:12,000 --> 00:04:15,520 Sixteenth Cause of action aiding a betting and inducing sex 61 00:04:15,520 --> 00:04:19,160 trafficking venture in violation of the Trafficking Victims Protection Act. 62 00:04:19,439 --> 00:04:23,959 US Code eighteen, section fifteen ninety and fifteen ninety five. 63 00:04:25,079 --> 00:04:29,240 Plaintiff against all defendants. Plaintiffs incorporate by reference and re 64 00:04:29,360 --> 00:04:33,000 allege each of the preceding paragraphs and all paragraphs below 65 00:04:33,199 --> 00:04:35,720 as though fully set fourth and brought in this cause 66 00:04:35,759 --> 00:04:40,199 of action. Defendants directly committed and perpetrated violations of Chapter 67 00:04:40,279 --> 00:04:44,439 seventy seven, Title eighteen US Code, including US Code eighteen, 68 00:04:44,519 --> 00:04:48,000 Section fifteen ninety. By aiding a betting and inducing the 69 00:04:48,040 --> 00:04:52,879 sex trafficking venture and sex trafficking of plaintiffs, defendants themselves 70 00:04:52,920 --> 00:04:57,600 directly violated Chapter seventy seven by committing and perpetrating these violations. 71 00:04:58,279 --> 00:05:02,240 Among other things, Defendants aided, abetted, and induced Defendants Ditty 72 00:05:02,319 --> 00:05:05,920 sex trafficking venture and sex trafficking of plaintiffs Parum and 73 00:05:06,000 --> 00:05:09,519 John Doe, knowing that Defendant Ditty would use means of force, 74 00:05:09,600 --> 00:05:12,800 threats of force, fraud, coercion, and a combination of such 75 00:05:12,839 --> 00:05:16,279 means to cause plaintiffs to engage in non consensual acts. 76 00:05:17,279 --> 00:05:20,839 By aiding and abetting and inducing Defendant Ditty sex trafficking 77 00:05:20,920 --> 00:05:24,000 venture and sex trafficking of plaintiff Parum and John Doe, 78 00:05:24,240 --> 00:05:28,160 defendants benefited both financially and by receiving things of value 79 00:05:28,319 --> 00:05:31,120 from participating in the Ditty sexual abuse and cover up 80 00:05:31,199 --> 00:05:36,560 enterprise sex trafficking venture. Defendants had actual knowledge that they 81 00:05:36,560 --> 00:05:39,600 were aiding a betting and inducing defendant Ditty and his 82 00:05:39,759 --> 00:05:43,759 co conspirators sexual abuse and sex trafficking conspiracy to recruit 83 00:05:43,839 --> 00:05:49,439 solicit entice, coerce, harbor, transport, obtain, and provide plaintiffs and 84 00:05:49,560 --> 00:05:52,560 the non consensual sex acts through the means of force, 85 00:05:52,800 --> 00:05:57,879 threats of force, fraud, abusive process, and coercion. Defendantsknew and 86 00:05:57,920 --> 00:06:00,279 should have known that Defendant Ditty had in gains aged 87 00:06:00,319 --> 00:06:05,040 and acts and violation of the TVPA. Defendants knowing and 88 00:06:05,120 --> 00:06:09,319 intentional conduct of aiding, abetting, and inducing defendant Ditty's violations 89 00:06:09,680 --> 00:06:15,959 have caused plaintiff serious harm, including without limitation, physical, psychological, emotional, financial, 90 00:06:16,160 --> 00:06:21,240 and reputational harm. Through their unchecked support, defendants aided, abetted, 91 00:06:21,279 --> 00:06:25,040 and induced Defendant Ditty's violations and caused plaintiff harm that 92 00:06:25,160 --> 00:06:29,360 is sufficiently serious under all the surrounding circumstances to compel 93 00:06:29,399 --> 00:06:32,000 a reasonable person of the same background and in the 94 00:06:32,000 --> 00:06:36,759 same circumstances to perform or continue performing non consensual sexual 95 00:06:36,759 --> 00:06:42,000 activity in order to avoid incurring additional harm. Defendant's criminal 96 00:06:42,000 --> 00:06:45,600 conduct in aiding, abetting, and inducing Defendant Ditty's violations of 97 00:06:45,639 --> 00:06:49,000 the TVPA was outrageous and intentional because it was in 98 00:06:49,079 --> 00:06:52,959 deliberate further into a widespread and dangerous Ditty sexual abuse 99 00:06:52,959 --> 00:06:57,680 and cover up enterprise and criminal sex trafficking organization. Defendant's 100 00:06:57,680 --> 00:07:01,439 criminal conduct also evinced a high degree of moral tertitude 101 00:07:01,680 --> 00:07:05,240 and demonstrated such wanton dishonesty as to imply a criminal 102 00:07:05,279 --> 00:07:10,759 indifference to civil obligations. Defendant's criminal conduct was directed specifically 103 00:07:10,839 --> 00:07:14,160 at plaintiffs who are the victims of defendant ditty sexual 104 00:07:14,160 --> 00:07:19,680 abuse and cover up trafficking organization. Defendant's outrageous and intentional 105 00:07:19,720 --> 00:07:22,199 conduct in this case is part of a pattern of 106 00:07:22,240 --> 00:07:26,319 practice of defendant by profiting by undertaking illegal, high risk, 107 00:07:26,600 --> 00:07:30,759 high reward partnerships. By virtue of these knowing and intentional 108 00:07:30,839 --> 00:07:34,600 violations of US Code eighteen, section fifteen ninety and fifteen 109 00:07:34,680 --> 00:07:38,040 ninety five, defendants are liable to plaintiffs for the damages 110 00:07:38,079 --> 00:07:42,360 they sustained and reasonable attorney's fees. By virtue of these 111 00:07:42,399 --> 00:07:46,360 intentional and outrageous violations the US Code eighteen, section fifteen 112 00:07:46,439 --> 00:07:50,199 ninety and fifteen ninety five, defendants are liable to plaintiffs 113 00:07:50,199 --> 00:07:55,279 for punitive damages. Seventeenth Cause of action Knowing beneficiary in 114 00:07:55,319 --> 00:07:58,560 a sex trafficking venture in violation of the Trafficking Victims 115 00:07:58,600 --> 00:08:02,480 Protection Act us QX eighteen, section fifteen ninety and fifteen 116 00:08:02,560 --> 00:08:07,519 ninety five Plaintiff against all defendants plaintiffs in corporate by 117 00:08:07,560 --> 00:08:10,399 reference and re allege each of the preceding paragraphs and 118 00:08:10,439 --> 00:08:13,480 all paragraphs below, as though fully set forth and brought 119 00:08:13,720 --> 00:08:17,360 in this cause of action upon information and beliefs, defendants 120 00:08:17,360 --> 00:08:21,480 knowingly and intentionally benefited financially and by receiving things of 121 00:08:21,560 --> 00:08:26,160 value from participating, in, assisting, supporting, and facilitating an a 122 00:08:26,240 --> 00:08:29,600 legal course of sex trafficking venture that was in and 123 00:08:29,680 --> 00:08:33,519 affecting interstate and foreign commerce together and with others, in 124 00:08:33,600 --> 00:08:38,840 violation of US Code eighteen, Section fifteen ninety. Defendants took 125 00:08:38,879 --> 00:08:42,159 many concrete steps to aid and participate in Ditty sexual 126 00:08:42,200 --> 00:08:45,799 abuse and cover up enterprise sex trafficking venture. Among the 127 00:08:45,840 --> 00:08:49,399 concrete steps that defendants took to aid Defendant Ditty was 128 00:08:49,440 --> 00:08:52,879 providing victims to defendan Ditty like plaintiff, as well as 129 00:08:52,919 --> 00:08:57,679 security getaway driver, a private location to engage in his debaucheries, 130 00:08:57,720 --> 00:09:01,039 and drug used to a weaken plaintiff's defendse making the 131 00:09:01,039 --> 00:09:05,879 sex trafficking venture possible. Upon information and belief, defendants roles 132 00:09:05,919 --> 00:09:09,639 and actions provided were necessary for Defendant Ditty to force 133 00:09:09,679 --> 00:09:14,480 plaintiffs to engage in non consensual acts. The financing to 134 00:09:14,559 --> 00:09:17,679 the defendants in the Ditty sexual abuse cover up enterprise 135 00:09:17,759 --> 00:09:21,159 directly form part of the commercial nature of the sex acts. 136 00:09:21,720 --> 00:09:25,679 Defendants thusly actively participated in the recruitment of victims of 137 00:09:25,720 --> 00:09:29,039 the venture. Defendants knew or should have known that they 138 00:09:29,039 --> 00:09:33,399 were feeding defendant Ditty sexual deviancy. Upon information and belief, 139 00:09:33,440 --> 00:09:37,480 defendants received financial benefits from Defendant Ditty and to sex 140 00:09:37,519 --> 00:09:40,879 trafficking venture, most notably a new car for defendant Chain 141 00:09:41,279 --> 00:09:46,720 and cash payments to defendants KK, Brandy Pelletier, Gonzales, Valdez, Odell, 142 00:09:46,879 --> 00:09:51,559 Drewskian Doze. Defendants knew that it would gain from routine 143 00:09:51,600 --> 00:09:54,799 financial benefits by participating in the Ditty sexual abuse and 144 00:09:54,840 --> 00:09:58,600 cover up enterprise sex trafficking venture. By virtue of these 145 00:09:58,679 --> 00:10:02,759 knowing and intentional violations of US Code eighteen, Section fifteen 146 00:10:02,840 --> 00:10:06,799 ninety and fifteen ninety five, defenders are reliable to plaintiffs 147 00:10:06,799 --> 00:10:11,679 for the damages they sustained and reasonable attorney fees. All right, folks, 148 00:10:11,679 --> 00:10:13,799 we're gonna wrap this one up right here, and in 149 00:10:13,879 --> 00:10:16,320 the next episode, we're gonna finish this bad boy off. 150 00:10:17,080 --> 00:10:18,840 If you'd like to contact me, you can do that 151 00:10:18,879 --> 00:10:23,840 at Bobby Kopuci at Protonmeil dot com. That's Bobby capu 152 00:10:24,279 --> 00:10:27,279 Cci at Protonmeil dot com, or if you prefer, you 153 00:10:27,279 --> 00:10:32,440 can find me on x at Bobby Underscore cap Ucci. 154 00:10:33,279 --> 00:10:35,120 All of the links that go with this episode can 155 00:10:35,159 --> 00:10:38,200 be found in the description box. What's up, everyone, and 156 00:10:38,320 --> 00:10:42,080 welcome to another episode of The Diddy Diaries. In this episode, 157 00:10:42,080 --> 00:10:44,600 we're picking up where we left off with the Ashley 158 00:10:44,679 --> 00:10:50,320 parhum amended complaint against Diddy, Odell Beckham, Jaguar Wright, Drewski 159 00:10:50,360 --> 00:10:54,960 and others. Eighteenth Cause of Action Obstruction of the enforcement 160 00:10:55,000 --> 00:10:58,440 of the Trafficking Victim Protection Act US Code eighteen, section 161 00:10:58,559 --> 00:11:03,759 fifteen ninety B Plaintiffs against all defendants. Plaintiffs incorporate by 162 00:11:03,799 --> 00:11:07,039 reference and reallege each of the preceding paragraphs and all 163 00:11:07,080 --> 00:11:10,440 paragraphs below is though fully set forth and brought in 164 00:11:10,480 --> 00:11:15,600 this cause of action. Defendants knowingly and intentionally obstructed, attempted 165 00:11:15,639 --> 00:11:19,159 to obstruct, interfered with, and prevented the enforcement of US 166 00:11:19,200 --> 00:11:22,840 Code eighteen, section fifteen ninety all in violation of US 167 00:11:22,879 --> 00:11:27,879 Code eighteen, section fifteen ninety B. This activity is hereinafter 168 00:11:28,000 --> 00:11:32,639 referred to collectively simply as obstruction upon information and belief. 169 00:11:32,679 --> 00:11:36,559 Defendants obstruction of the enforcement of the US Code eighteen, 170 00:11:36,639 --> 00:11:40,159 Section fifteen ninety was forbidden by US Code eighteen, Section 171 00:11:40,440 --> 00:11:44,679 fifteen ninety B, thereby violating Chapter seventy seven, Title eighteen. 172 00:11:45,159 --> 00:11:49,200 Defendants obstruction described here and in the preceding paragraph directly 173 00:11:49,360 --> 00:11:53,799 proximately and foreseeably harmed plaintiffs, directly resulting in plaintiffs being 174 00:11:53,840 --> 00:11:58,200 forced against their will to engage in non consensual sex acts. 175 00:11:58,639 --> 00:12:01,720 Upon information and belief TOD defendant Ditty was a well 176 00:12:01,759 --> 00:12:06,279 documented history of criminal investigations. Defendants were on notice of 177 00:12:06,360 --> 00:12:10,039 Defendant Ditty's proclivity to criminal activity. They knew or should 178 00:12:10,080 --> 00:12:13,120 have known that Defendant Ditty's sexual abuse and cover of 179 00:12:13,279 --> 00:12:17,000 enterprise sex trafficking operation would or could result in a 180 00:12:17,039 --> 00:12:21,879 criminal investigation by state and federal prosecutors for violating, among 181 00:12:21,960 --> 00:12:25,799 other laws, the TVPA. Defendants should have taken a queue 182 00:12:26,000 --> 00:12:29,919 from the federal prosecutor's arrest and prosecution of Jeffrey Epstein. 183 00:12:30,480 --> 00:12:32,799 The U S. Attorney's Office for the Southern District of 184 00:12:32,840 --> 00:12:38,879 New York indicted Epstein and unnamed associates for violating the TVPA. Later, 185 00:12:39,000 --> 00:12:43,080 the same office indicted Epstein's co conspirator, Glenn Maxwell, for 186 00:12:43,200 --> 00:12:46,519 conspiracy to entice minor victims to travel to be abused 187 00:12:46,519 --> 00:12:50,039 by Epstein. All named defendants in this matter engaged in 188 00:12:50,080 --> 00:12:53,840 the same activities as mister Epstein and Miss Maxwell. In fact, 189 00:12:53,879 --> 00:12:58,000 defendants may have done worse upon information and belief by 190 00:12:58,000 --> 00:13:02,039 concealing their actions Thereafter. Defended, then substructed, interfered with, and 191 00:13:02,080 --> 00:13:05,799 prevented the state and federal government's enforcement of the TVPA 192 00:13:05,879 --> 00:13:09,039 against defendant Ditty. To the extent that the federal government 193 00:13:09,120 --> 00:13:13,279 was able, the ultimately charged Defendant Ditty with TVPA violations. 194 00:13:13,879 --> 00:13:17,399 The filing of those charges was delayed by defendant's actions. 195 00:13:18,080 --> 00:13:21,159 Because of that delay, plaintiffs were forced to engage in 196 00:13:21,279 --> 00:13:26,120 non consensual sex acts. One example of how defendants obstructed, 197 00:13:26,159 --> 00:13:29,440 attempted to obstruct, interfered with, and prevented state and federal 198 00:13:29,480 --> 00:13:34,519 government's enforcement of the TVPA. Defendants provided resources to Defendant Ditty, 199 00:13:34,919 --> 00:13:39,919 like security victims, drugs, getaway driver, and false alibis, so 200 00:13:39,960 --> 00:13:42,759 that the forced sex acts would escape the detection of 201 00:13:42,799 --> 00:13:47,919 the state and federal law enforcement and prosecuting agencies. Defendants 202 00:13:47,960 --> 00:13:51,399 provided these resources to further the Ditty sexual abuse and 203 00:13:51,480 --> 00:13:54,639 cover up enterprise sex trafficking venture with the purpose of 204 00:13:54,679 --> 00:13:58,320 helping defendant Ditty and the other defendants in evading criminal 205 00:13:58,360 --> 00:14:02,679 liability for violating the TVPA. By providing this type of 206 00:14:02,679 --> 00:14:06,960 support to Defendant Ditty, defendants intended and knew that Defendant 207 00:14:06,960 --> 00:14:10,679 Ditty is depraved and egregiously for sex acts would escape 208 00:14:10,720 --> 00:14:14,159 the detection of law enforcement and prosecuting agencies for some 209 00:14:14,200 --> 00:14:18,279 period of time. Defendant support furthered the Ditty sexual abuse 210 00:14:18,320 --> 00:14:21,480 and cover up enterprise sex trafficking venture, and the purpose 211 00:14:21,519 --> 00:14:25,840 of helping defendant Ditty evade criminal liability for violating the TVPA. 212 00:14:26,559 --> 00:14:31,519 Upon information and belief, defendants obstruction, attempt at obstruction, interference with, 213 00:14:31,919 --> 00:14:35,519 and prevention of the enforcement of the TVPA were all 214 00:14:35,559 --> 00:14:39,399 done intentionally and knowingly. For example, defendants knew that Defendant 215 00:14:39,399 --> 00:14:42,639 Ditty was high risk, specifically high risks to violate the 216 00:14:42,639 --> 00:14:47,240 TVPA through continuing criminal sex trafficking activities due to its 217 00:14:47,279 --> 00:14:50,759 proximity to criminal activity as far back as nineteen ninety one. 218 00:14:51,919 --> 00:14:55,600 Upon information and belief, defendants were aware and participated and 219 00:14:55,720 --> 00:14:59,679 engaged in witness intimidation and bribery to escape criminal liability, 220 00:15:00,120 --> 00:15:03,320 including offering plaintiff money to say that the sexual abuse 221 00:15:03,360 --> 00:15:06,639 and rape she suffered was consensual and for plaintiff to 222 00:15:06,679 --> 00:15:11,120 say she was a sex worker. Defendants were fully aware 223 00:15:11,200 --> 00:15:14,879 that there were public allegations that Defendant Ditty's illegal conduct 224 00:15:14,879 --> 00:15:20,240 made through complaints in previous lawsuits. Defendants concealed information from 225 00:15:20,279 --> 00:15:23,519 the federal government in an intentional attempt to obstruct in 226 00:15:23,600 --> 00:15:27,120 many ways, interfere with and prevented the enforcement of the 227 00:15:27,159 --> 00:15:33,159 TVPA by investigators and prosecuting agencies upon information and belief. 228 00:15:33,159 --> 00:15:36,799 Defendant's relationship with defendant Ditty when far beyond the normal 229 00:15:37,120 --> 00:15:41,720 lawful partnership, relationship, and friendship. Defendants knew and intended that 230 00:15:41,759 --> 00:15:45,679 its relationship with Defendant Ditty would go far beyond normal relationships. 231 00:15:46,159 --> 00:15:49,000 Defendants knew that its decision to go beyond the normal 232 00:15:49,039 --> 00:15:53,320 employment and personal relationship with Defendant Ditty obstructed the ability 233 00:15:53,360 --> 00:15:57,559 of law enforcement and prosecuting agencies to enforce the TVPA 234 00:15:58,519 --> 00:16:01,879 upon information and belief. Defend and substruction of the government's 235 00:16:01,919 --> 00:16:06,200 TVPA and other law enforcement efforts was intentional and willful, 236 00:16:06,480 --> 00:16:10,799 and therefore defendants intentionally and wilfully cause defendant Ditty's commission 237 00:16:11,039 --> 00:16:14,399 of the forcible sex acts with plaintiffs through its obstruction 238 00:16:14,919 --> 00:16:18,279 supporting the concealment of the Ditty sexual abuse and cover 239 00:16:18,360 --> 00:16:22,639 up enterprise sex trafficking venture. Defendants knew that Defendant Ditty 240 00:16:22,799 --> 00:16:26,039 would use means of force, threats of force, fraud, coercion, 241 00:16:26,279 --> 00:16:29,000 and a combination of such means to cause Plaintiff to 242 00:16:29,120 --> 00:16:33,399 engage in non consensual sex acts. Upon information and belief, 243 00:16:33,440 --> 00:16:37,279 defendants knew acted in reckless disregard of the fact and 244 00:16:37,360 --> 00:16:40,639 should have known that its obstruction and violation of US 245 00:16:40,679 --> 00:16:44,799 Code eighteen, Section fifteen ninety B would directly and approximately 246 00:16:44,919 --> 00:16:48,320 lead to unlawful and forceful sex acts by Defendant Ditty 247 00:16:48,559 --> 00:16:53,360 with individuals like plaintiff. Upon information and belief, defendant substruction 248 00:16:53,720 --> 00:16:59,399 has caused Plaintiff's serious harm, including without limitation, physical, psychological, financial, 249 00:16:59,679 --> 00:17:03,720 and retational harm. That harm was directly and proximately caused 250 00:17:03,720 --> 00:17:06,920 by the obstruction, and the harm resulting from obstruction was 251 00:17:06,960 --> 00:17:11,880 foreseeable upon information and belief, Defended substruction has caused plaintiff 252 00:17:11,880 --> 00:17:16,039 harm that is sufficiently serious under all the surrounding circumstances 253 00:17:16,079 --> 00:17:19,680 to compel a reasonable person of the same background and 254 00:17:19,759 --> 00:17:23,160 in the same circumstances to perform or continue to perform 255 00:17:23,240 --> 00:17:28,640 sexual activity to avoid incurring further harm upon information and belief. 256 00:17:28,839 --> 00:17:32,680 Defendants criminal conduct and obstructing enforcement of the TVPA was 257 00:17:32,720 --> 00:17:36,240 outrageous and intentional because it was in deliberate further into 258 00:17:36,319 --> 00:17:41,720 a widespread and dangerous criminal sex trafficking organization. Defendant substruction 259 00:17:42,240 --> 00:17:46,000 also evinced a high degree of moral certitude and demonstrated 260 00:17:46,039 --> 00:17:49,279 such wanton dishonesty as to imply a criminal indifference to 261 00:17:49,319 --> 00:17:55,079 civil obligations. Defendant's actions were directed specifically at plaintiffs who 262 00:17:55,079 --> 00:17:57,839 were the victims of the Ditty sexual abuse and cover 263 00:17:57,960 --> 00:18:02,359 up enterprise sex trafficking organization. By virtue of these violations, 264 00:18:02,359 --> 00:18:06,279 the US Code eighteen, section fifteen ninety B, defendants reliable 265 00:18:06,319 --> 00:18:09,960 to plaintiffs for the damage they sustained and reasonable attorney fees. 266 00:18:10,200 --> 00:18:13,799 By operation of US Code eighteen, Section fifteen ninety five, 267 00:18:14,279 --> 00:18:19,200 defendants perpetrated an obstruction of the TVPA, and therefore perpetrated 268 00:18:19,200 --> 00:18:24,079 a violation of Chapter seventy seven, Title eighteen nineteenth. Cause 269 00:18:24,119 --> 00:18:30,240 of action false imprisonment Plaintiff against all defendants. Plaintiffs incorporate 270 00:18:30,279 --> 00:18:33,039 by reference and re allege each of the preceding paragraphs 271 00:18:33,160 --> 00:18:36,119 and all paragraphs below as though fully set forth and 272 00:18:36,200 --> 00:18:40,640 brought in this cause of action, Defendants intentionally detained and 273 00:18:40,759 --> 00:18:45,440 or prevented plaintiffs from leaving the premises, therefore imprisoning plaintiffs, 274 00:18:45,480 --> 00:18:48,759 acting in deliberate malice and for the purpose of trafficking 275 00:18:48,960 --> 00:18:52,559 and or sexually assaulting and raping plaintiffs. Defendants in prison 276 00:18:52,599 --> 00:18:56,440 plaintiffs without just a reasonable cause, without lawful privilege, without 277 00:18:56,440 --> 00:18:59,920 plaintiff's consent, and without probable cause, for an appreciable amount 278 00:18:59,920 --> 00:19:04,400 of time, and therefore deprived plaintiffs of their personal civil liberties. 279 00:19:05,440 --> 00:19:09,240 Defendants on lawful conduct resulted in the false imprisonment of plaintiffs. 280 00:19:09,319 --> 00:19:13,279 On March twenty third, twenty eighteen, Plaintiff Parum was invited 281 00:19:13,319 --> 00:19:16,079 to defend in Shane's home as a guest. Plaintiff was 282 00:19:16,119 --> 00:19:18,720 under the impression she was in a safe environment where 283 00:19:18,759 --> 00:19:23,079 only she and defended Shane would be present honor. About 284 00:19:23,119 --> 00:19:27,880 the same enumerated date above, Plaintiff Parum's clothes, phone, purse, keys, 285 00:19:27,920 --> 00:19:31,079 and cell phone were hid and confiscated in an effort 286 00:19:31,079 --> 00:19:34,359 to prevent her from leaving the premises. After Defendant Ditty 287 00:19:34,400 --> 00:19:39,519 and other defendants arrived at defending Shane's residence, Defendant forced 288 00:19:39,599 --> 00:19:43,079 plaintiff parum against her will and over her protest with 289 00:19:43,160 --> 00:19:46,400 threats of physical violence, forced plaintiff to engage in non 290 00:19:46,440 --> 00:19:50,920 consensual sexual activities with defendants Ditty, Shane O'Dell, Drewskian do. 291 00:19:52,319 --> 00:19:55,880 Defendants forced plaintiff Dough against her will and over their 292 00:19:55,920 --> 00:19:59,640 protests with threats of physical violence, trafficked, battered, assaulted, and 293 00:19:59,640 --> 00:20:03,759 abuse plaintiffs. Plaintiffs were not released from their imprisonment until 294 00:20:03,799 --> 00:20:07,920 they made their harrowing escape as enumerated above. In this complaint, 295 00:20:08,759 --> 00:20:12,720 plaintiffs believe that procuring their false imprisonment was made intentionally 296 00:20:12,960 --> 00:20:16,160 with actual malice and was intended to harm plaintiffs solely 297 00:20:16,319 --> 00:20:19,680 for purposes of the sexual gratification of defendant Ditty and 298 00:20:19,759 --> 00:20:23,039 then furtherance of the Ditty sexual abuse and cover up enterprise. 299 00:20:24,079 --> 00:20:27,599 Malice is attributable to defending Ditty's actions as a joint 300 00:20:27,640 --> 00:20:32,319 tortfeezer in that he joined and facilitated the false imprisonment 301 00:20:32,400 --> 00:20:36,720 and maliciously instigated it. Malice is further attributable to defendant 302 00:20:36,720 --> 00:20:42,119 Gonzales Valdez, Jaguar and Elina as security personnel for defendant Ditty, 303 00:20:42,279 --> 00:20:46,000 whose actions independently based on the fact that defendant ditty 304 00:20:46,319 --> 00:20:50,640 wanted to prevent plaintiffs from being able to escape. As 305 00:20:50,680 --> 00:20:54,279 a legal result of defendant's actions, plaintiffs were physically, mentally, 306 00:20:54,319 --> 00:20:57,200 and or emotionally injured, all to the extent in an 307 00:20:57,240 --> 00:21:01,720 amount subject of proof at trial. Defendants acted with malice 308 00:21:01,759 --> 00:21:04,200 and with the intent to cause injury to plaintiffs, or 309 00:21:04,240 --> 00:21:07,720 acted with a willful and conscious disregard of the rights 310 00:21:07,759 --> 00:21:12,119 of plaintiffs in a despicable manner. An addition, defendants engaged 311 00:21:12,119 --> 00:21:15,960 in despicable conduct that subjected plaintiffs to cruel and unjust 312 00:21:16,000 --> 00:21:20,319 hardship and conscious disregard of their rights. Therefore, plaintiffs are 313 00:21:20,440 --> 00:21:23,480 entitled to an award of punitive damages for the purpose 314 00:21:23,519 --> 00:21:27,359 of punishing those individual defendants to deter them and others 315 00:21:27,440 --> 00:21:31,079 from such conduct in the future. As approximate result of 316 00:21:31,119 --> 00:21:34,519 the acts of the defendants, plaintiffs have suffered great damage 317 00:21:34,559 --> 00:21:39,839 to their person, reputation, and embarrassment. As an approximate result 318 00:21:39,839 --> 00:21:42,720 of the acts of defendants, each of them herein alleged 319 00:21:42,880 --> 00:21:45,799 plaintiff have been and will continue to be prevented from 320 00:21:45,880 --> 00:21:48,720 having a normal life. The amount of damage done to 321 00:21:48,759 --> 00:21:52,000 plaintiffs are still ongoing and not fully known at this time. 322 00:21:53,359 --> 00:21:56,480 As an additional approximate result of the acts of defendant, 323 00:21:56,680 --> 00:22:00,640 Plaintiffs were injured in their health, strength, and activity, shocking 324 00:22:00,720 --> 00:22:04,119 injury to their person and injury to their body, requiring 325 00:22:04,119 --> 00:22:09,319 several hospitalizations treatments from therapists and other medical professionals. All 326 00:22:09,400 --> 00:22:12,400 of these injuries have caused plaintiffs to suffer extreme and 327 00:22:12,480 --> 00:22:17,319 physical severe physical pain and mental anguish. These injuries will 328 00:22:17,319 --> 00:22:20,400 result in some level of permanent disability to the plaintiffs. 329 00:22:21,559 --> 00:22:24,400 As a further approximate result of the acts of defendants, 330 00:22:24,400 --> 00:22:28,599 Plaintiffs were required to and did not employ physicians, therapists, 331 00:22:28,640 --> 00:22:33,559 and other medical professionals, including hospitalizations for medical examinations, treatment, 332 00:22:33,880 --> 00:22:38,200 and care for injuries resulting from this experience. Plaintiff did 333 00:22:38,200 --> 00:22:42,000 and will incur medical and incidental expenses for the services 334 00:22:42,799 --> 00:22:47,160 the acts of defendants, each of them herein alleged were wilful, wanton, malicious, 335 00:22:47,200 --> 00:22:53,079 and oppressive, justifying the award of punitive damages requests for relief. Wherefore, 336 00:22:53,160 --> 00:22:59,400 Plaintiff respectfully requests judgment against defendants, awarding compensatory, consequential, exemplary 337 00:22:59,480 --> 00:23:04,359 punitive restitution on Justin Richmond, equitable and treble damages in 338 00:23:04,400 --> 00:23:07,240 an amount to be determined at trial, cost of suit, 339 00:23:07,519 --> 00:23:10,319 attorney fees, and such other and further relief as the 340 00:23:10,359 --> 00:23:14,119 Court may deem justin proper demand for a jury trial 341 00:23:14,480 --> 00:23:17,240 pursuing the Federal Rule of Civil Procedure thirty A b 342 00:23:17,720 --> 00:23:21,599 Plaintiff demands a trial by jury on all issues so triable, 343 00:23:22,519 --> 00:23:26,400 respectfully submitted by the law offices of Sean R. Perez 344 00:23:26,839 --> 00:23:30,440 and Area Mitchell, and it was dated March seventh, twenty 345 00:23:30,519 --> 00:23:34,119 twenty five. If you'd like to contact me, you can 346 00:23:34,160 --> 00:23:37,200 do that at Bobby Kobuchi at protonmeil dot com. That's 347 00:23:37,240 --> 00:23:42,720 Bobby caapu Cci at protonmeil dot com, or if you prefer, 348 00:23:42,839 --> 00:23:48,359 you can find me on x at Bobby underscore cap Ucci. 349 00:23:49,079 --> 00:23:51,160 All of the links that we discussed can be found 350 00:23:51,519 --> 00:23:52,599 in the description box