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Epstein Survivors Amend Their Lawsuit Filed Against The U.S. Government (Part 2) (10/10/26) · The Vault: The Epstein Files

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  Speaker 1: What's up everyone and welcome to another episode of the
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  Speaker 1: Epstein Chronicles. In this episode we're picking up where we
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  Speaker 1: left off with the survivor lawsuit filed against the DOJ
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  Speaker 1: and the government of the United States. Jane Doe Wade
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  Speaker 1: is a citizen of the United States and was at
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  Speaker 1: all relevant times a resident and domiciled and sexually abused
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  Speaker 1: in the state of New York from 2004 to 2006.
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  Speaker 1: Jane Doe 9 is a U.S. citizen and and was
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  Speaker 1: at all relevant times a resident of and domiciled and
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  Speaker 1: sexually abused in the state of New York, United States,
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  Speaker 1: Virgin Islands, New Mexico, Palm Beach, and all over the
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  Speaker 1: world from 2002 through 2009, including being sexually abused in
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  Speaker 1: his Florida Science Foundation office while he was on work release.
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  Speaker 1: Jane Doe number 10 is a U.S. citizen and was
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  Speaker 1: at all relevant times a resident of and domiciled and
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  Speaker 1: sexually abused in the state of New York from 2001
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  Speaker 1: to 2002. Jane Doe number 11 is a U.S. citizen
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  Speaker 1: and was at all relevant times a resident of and
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  Speaker 1: domiciled and sexually abused in the state of New York
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  Speaker 1: from 2001 to 2002. Jane Doe 12 is a U.S.
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  Speaker 1: citizen and was at all relevant times a resident of
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  Speaker 1: and domiciled and sexually abused in the state of Florida
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  Speaker 1: from 1996 to 2001. Jane Doe 13 is a U.S.
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  Speaker 1: citizen and was at all relevant times a resident of
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  Speaker 1: and domiciled and sexually abused in the state of New
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  Speaker 1: York in 2006. Jane Doe 14 is a U.S. citizen
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  Speaker 1: and was at all relevant times a resident of and
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  Speaker 1: domiciled and sexually abused in the state of California in 2003.
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  Speaker 1: Jane Doe 15 is a U.S. citizen and was at
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  Speaker 1: all relevant times a resident of and domiciled and sexually
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  Speaker 1: abused in the state of New York in 2000 as
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  Speaker 1: a minor. Jane Doe 16 is a U.S. citizen and
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  Speaker 1: was at all relevant times a resident of and domiciled
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  Speaker 1: and sexually abused in the state of New York in 2003,
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  Speaker 1: and was 13 years old at the time of her abuse.
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  Speaker 1: Jane Doe, 17, is a U.S. citizen and was, at
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  Speaker 1: all relevant times, a resident of and domiciled and sexually
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  Speaker 1: abused in the state of New York in 2003. Jane Doe, 18,
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  Speaker 1: is a U.S. citizen and was, at all relevant times,
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  Speaker 1: a resident of and domiciled and sexually abused in the
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  Speaker 1: state of California in 1997. Jane Doe 19 is a U.S.
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  Speaker 1: citizen and was at all relevant times a resident of
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  Speaker 1: and domiciled and sexually abused in the state of New
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  Speaker 1: York from 2002 to 2010. Jane Doe 20 is a U.S.
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  Speaker 1: citizen and was at all relevant times a resident of
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  Speaker 1: and domiciled and sexually abused in the state of New
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  Speaker 1: York in 2002. Jane Doe 21 is a U.S. citizen
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  Speaker 1: and was at all relevant times a resident of and
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  Speaker 1: domiciled and sexually abused In the state of New York,
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  Speaker 1: Jane Doe, 22, is a U.S. citizen and was at
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  Speaker 1: all times a resident of and domiciled and sexually abused
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  Speaker 1: in the state of New York from 2015 to 2019.
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  Speaker 1: Jane Doe, 23, is a U.S. citizen and was at
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  Speaker 1: all relevant times a resident of and domiciled and sexually
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  Speaker 1: abused in the state of New York from 2002 to 2009.
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  Speaker 1: Jane Doe, 24, is a U.S. citizen and was at
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  Speaker 1: all relevant times a resident of and domiciled and sexually
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  Speaker 1: abused in the state of New York and Paris, France
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  Speaker 1: from 2006 to 2011. Jane Doe, 25, is a U.S.
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  Speaker 1: citizen and was at all relevant times a resident of
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  Speaker 1: and domiciled and sexually abused in the state of New
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  Speaker 1: York from 2002 to 2009. Jane Doe, 26, is a U.S.
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  Speaker 1: citizen and was at all relevant times a resident of
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  Speaker 1: and domiciled and sexually abused in the state of New
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  Speaker 1: York from 2002 to 2005. Jane Doe, 27, is a U.S.
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  Speaker 1: citizen and was at all relevant times a resident of
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  Speaker 1: and domiciled and sexually abused in the state of New
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  Speaker 1: York in 2002. Jane Doe, 28, is a U.S. citizen
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  Speaker 1: and was at all relevant times a resident of and
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  Speaker 1: domiciled and sexually abused in the state of New York
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  Speaker 1: in 2002. Jane Doe, 29, is a U.S. citizen and
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  Speaker 1: was at all relevant times a resident of and domiciled
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  Speaker 1: and sexually abused in the state of New York from
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  Speaker 1: 2002 to 2008. Jane Doe, 30, is a U.S. citizen
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  Speaker 1: and was at all relevant times a resident of and
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  Speaker 1: domiciled and sexually abused in the state of New York
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  Speaker 1: from 2002 to 2009. Jane Doe, 31, is a U.S.
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  Speaker 1: citizen and was at all relevant times a resident of
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  Speaker 1: and domiciled and sexually abused in the state of New
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  Speaker 1: York from 2003 to to 2005. Jane Doe, 32, is
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  Speaker 1: a U.S. citizen and was at all relevant times a
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  Speaker 1: resident of and domiciled and sexually abused in the state
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  Speaker 1: of New York from 2000 to 2003. The Jane Doe
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  Speaker 1: plaintiffs are using pseudonyms to protect their identities because of
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  Speaker 1: the sensitive and highly personal nature of the matter, which
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  Speaker 1: involves sexual assault. Furthermore, some of the Jane Does were
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  Speaker 1: minors at the time of their abuse. Several of the
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  Speaker 1: Jane Does have been threatened by individuals associated with Epstein
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  Speaker 1: in not to pursue litigation. The Jane Doe plaintiffs are
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  Speaker 1: also at serious risk of retaliatory harm because the co-conspirators
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  Speaker 1: who participated in the Epstein sex trafficking venture had and
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  Speaker 1: continue to possess tremendous wealth and power and have demonstrated
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  Speaker 1: a clear ability to cause serious harm. The Jane Doe
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  Speaker 1: plaintiff's safety, right to privacy, and security outweighs the public
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  Speaker 1: by allowing them to proceed anonymously. Some of the Jane
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  Speaker 1: Doe plaintiffs were afforded similar protection in other lawsuits and
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  Speaker 1: anonymity had been ordered in other child sex trafficking cases
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  Speaker 1: involving Epstein. The United States of America is a defendant
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  Speaker 1: in this action pursuant to the Federal Tort Claims Act U.S.
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  Speaker 1: Code 28 Section 1346 and 2671-80. The liability of the
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  Speaker 1: United States arises from the acts and or omissions of
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  Speaker 1: employees or agents of the Federal Bureau of Investigation and DOJ,
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  Speaker 1: an agency of the defendant. At all times mentioned, Defendant
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  Speaker 1: United States of America controlled, funded, managed, operated, and or
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  Speaker 1: owned the FBI and Department of Justice. At all times mentioned,
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  Speaker 1: the FBI and Department of Justice were funded by Defendant
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  Speaker 1: United States of America and acted within its mandate and authority.
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  Speaker 1: It was the duty of the Defendant United States of America, FBI,
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  Speaker 1: and Department of Justice to timely and properly investigate reports
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  Speaker 1: of sex crimes. child sex trafficking claims, and child sexual
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  Speaker 1: abuse material to prevent the claims from repeatedly occurring and
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  Speaker 1: protect plaintiffs and many others from being repeatedly sexually abused
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  Speaker 1: in addition to enforcing anti-sex trafficking laws, rape, child pornography,
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  Speaker 1: and child sex trafficking laws. The FBI is a federal
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  Speaker 1: law enforcement agency empowered by the United States Congress to
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  Speaker 1: enforce and investigate certain alleged violations of U.S. criminal code.
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  Speaker 1: The FBI is part of the U.S. Department of Justice
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  Speaker 1: and formally subject to oversight and direction by the Attorney
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  Speaker 1: General and employee of the United States of America. Agents, servants,
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  Speaker 1: and employees of the FBI are agents, servants, and employees
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  Speaker 1: of the defendant United States of America. The FBI conducted
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  Speaker 1: investigations in Florida and New York and were legally obligated
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  Speaker 1: to do so in accord with defendant's policy and procedure.
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  Speaker 1: All negligent acts and omissions of individual employees and agents
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  Speaker 1: of the FBI and the Department of Justice were committed
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  Speaker 1: within the course and scope of their employment with the FBI,
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  Speaker 1: the Department of Justice, and the United States of America. Facts. A.
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  Speaker 1: Maria Farmer notified the FBI that Jeffrey Epstein possessed CSAM
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  Speaker 1: and sexually trafficked and abused women and children in 1996,
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  Speaker 1: and the FBI ignored those credible allegations. Since 1996, at
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  Speaker 1: the latest, the FBI and Department of Justice have known
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  Speaker 1: that Jeffrey Epstein and his co-conspirators, including Ghislaine Maxwell, currently
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  Speaker 1: serving a 20-year sentence for conspiring with Epstein to sexually
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  Speaker 1: abuse minors, sexually abuse children, ran a sex trafficking operation,
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  Speaker 1: and possessed CSAM. In the mid-90s, Maria Farmer was an
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  Speaker 1: artist in New York City. In 1995, Farmer met Epstein
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  Speaker 1: and Maxwell at an art show, where Farmer was displaying
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  Speaker 1: some of her work. Farmer sold Epstein a painting of
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  Speaker 1: that show for about six grand. In 96, Epstein contacted
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  Speaker 1: Farmer because he was looking for someone to help him
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  Speaker 1: acquire art. Epstein presented himself to Farmer and others as
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  Speaker 1: a philanthropist who was interested in helping young people achieve
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  Speaker 1: their educational and other dreams in the art world. Farmer
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  Speaker 1: took the job with Epstein, but the job eventually evolved
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  Speaker 1: into including additional responsibilities such as manning the front door
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  Speaker 1: at his New York City residence and recording who came
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  Speaker 1: to the home. During that time, Farmer worked for Epstein
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  Speaker 1: in New York City's residence. She witnessed a number of
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  Speaker 1: young girls coming to the home, some wearing school uniforms.
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  Speaker 1: The girls would then be escorted upstairs. Farmer also saw men,
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  Speaker 1: including many politicians and business leaders, go upstairs with those
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  Speaker 1: young girls. Farmer asked Maxwell why all the girls were
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  Speaker 1: coming to the home, and Maxwell said they were interviewing
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  Speaker 1: for modeling positions. While working at Epstein's mansion, Maxwell actively
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  Speaker 1: put together what she called the modeling book, containing photographs
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  Speaker 1: of young girls and boys in various stages of undress.
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  Speaker 1: Maxwell kept the modeling book in Epstein's safe. Maxwell said
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  Speaker 1: that the modeling book was used to recruit models. for
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  Speaker 1: Victoria's Secret. Farmer did not find Maxwell credible. From time
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  Speaker 1: to time, Farmer ran errands with Maxwell using Epstein's car,
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  Speaker 1: which time Maxwell would occasionally direct the driver to stop
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  Speaker 1: the car so she could go get girls for Epstein.
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  Speaker 1: Farmer also helped with interior design at the 66th Street
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  Speaker 1: apartment building where she saw many young girls, mostly appeared
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  Speaker 1: to be teenagers. For the summer of 1996, Epstein encouraged
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  Speaker 1: Farmer to leave New York City and work as an
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  Speaker 1: artist-in-residence at his residence in New Albany, Ohio, which was
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  Speaker 1: adjacent to property owned by Les Wexner. That summer, Epstein
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  Speaker 1: directed Farmer to obtain an Ohio driver's license using his
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  Speaker 1: Ohio address on the license so that she could pick
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  Speaker 1: up Epstein and Maxwell from the airport. During the summer
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  Speaker 1: of 96, while Farmer was working on an art project
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  Speaker 1: at Wexner's mansion, Maxwell and Epstein came to the mansion.
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  Speaker 1: Epstein and Maxwell told Farmer to go into the bedroom
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  Speaker 1: where Epstein proceeded to sexually assault her. On August 29, 1996,
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  Speaker 1: Farmer called the New York Police Department's 6th Precinct to
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  Speaker 1: report that Epstein and Maxwell had sexually abused her and
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  Speaker 1: her sister Annie, and that Epstein and Maxwell were committing
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  Speaker 1: multiple other sex crimes against women and minor girls. Farmer
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  Speaker 1: also reported to the NYPD that Epstein had keys to
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  Speaker 1: her apartment and that he had recently called her to
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  Speaker 1: threaten her that he was going to burn the paintings
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  Speaker 1: in her apartment and take photos of the burnt paintings.
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  Speaker 1: The NYPD advised Farmer that they could only respond to
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  Speaker 1: the local fire threats and that there was only one
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  Speaker 1: law enforcement agency that could help her with the claims
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  Speaker 1: of sexual abuse trafficking and possession of child pornography, the FBI.
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  Speaker 1: In other words, local law enforcement agencies told Farmer that
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  Speaker 1: she must rely on the FBI, which was the only
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  Speaker 1: law enforcement agency that could help her. Here is a
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  Speaker 1: note from November 14th, 2006 interview, which is detailed below
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  Speaker 1: confirming that NYPD told Farmer, referred to as MF, to
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  Speaker 1: contact the FBI in 96. The NYPD further provided Farmer
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  Speaker 1: with a phone number to contact the FBI. At some
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  Speaker 1: point between August 29th, 1996 and September 3rd, 1996, Farmer
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  Speaker 1: followed the NYPD's instruction and and promptly called the FBI
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  Speaker 1: twice at two of its field offices, one of which
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  Speaker 1: was in New York to report Epstein's sexual abuse of her,
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  Speaker 1: one of her minor sister, and other women. During the
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  Speaker 1: first call, an FBI agent, working in the course and
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  Speaker 1: scope of his employment with the FBI, the Department of Justice,
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  Speaker 1: and U.S., abruptly hung up on her. Undeterred on September 3, 1996,
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  Speaker 1: Farmer called the FBI again. This time, an FBI agent
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  Speaker 1: took Farmer's call. During that call, Farmer reported to the
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  Speaker 1: FBI that Epstein possessed C-Sam, sexually abused and trafficked young girls,
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  Speaker 1: likely had recording devices and computer monitoring equipment in his
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  Speaker 1: New York City mansion that recorded illicit sexual activity, and
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  Speaker 1: that he had threatened to burn down her home. The
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  Speaker 1: FBI agent asked Farmer several questions, all of which indicated
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  Speaker 1: to Farmer that the FBI was going to help and
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  Speaker 1: do something in response to her report. The FBI completed
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  Speaker 1: the an investigatory intake form which is pictured above and
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  Speaker 1: attached here too as Exhibit A. The notation C-20 refers
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  Speaker 1: to a unit within the FBI's New York field office
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  Speaker 1: that handles sensitive investigations including those involving CSAM and other
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  Speaker 1: crimes against children. While the FBI intake form mentioned only
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  Speaker 1: CSAM material and Epstein's threats, Farmer also informed the FBI
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  Speaker 1: of Epstein's abuse and trafficking. Indeed, In her personal journal
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  Speaker 1: pictured below, Farmer explains she had to turn to them,
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  Speaker 1: to the FBI, because they molested all of us. At
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  Speaker 1: the end of the conversation, Farmer asks the FBI if
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  Speaker 1: Farmer should report Jeffrey Epstein to anyone else, including other
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  Speaker 1: law enforcement agencies. The FBI agent instructed Farmer not to
• 14:00
  Speaker 1: share her report with anyone else. Farmer relied on the
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  Speaker 1: FBI to investigate her claims and prevent Jeffrey Epstein from
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  Speaker 1: harming others. Farmer's reliance on the FBI is To investigate
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  Speaker 1: Jeffrey Epstein was reasonable for several reasons. First, the NYPD
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  Speaker 1: told Farmer that the FBI was the only law enforcement
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  Speaker 1: agency who could investigate her allegations. Second, during her second
• 14:23
  Speaker 1: conversation with the FBI on September 3, 1996, the agent
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  Speaker 1: was engaged, asked several questions, and took notes. Third, the
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  Speaker 1: FBI agent specifically instructed Farmer not to discuss her allegations
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  Speaker 1: against Epstein with anyone else. Based on NYPD's guidance, the
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  Speaker 1: FBI agents several follow-up questions and the FBI instruction not
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  Speaker 1: to inform anyone else, including any other law enforcement agency.
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  Speaker 1: Farmer believed the FBI would help her and investigate her allegations.
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  Speaker 1: Farmer's reliance is reflected in her personal journal. In 1997, Ms.
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  Speaker 1: Farmer wrote that she had to turn them, Epstein and Maxwell,
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  Speaker 1: into the FBI. Based on that reliance, Farmer did not
• 15:05
  Speaker 1: contact any other law enforcement agency about Epstein and his associates.
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  Speaker 1: As explained further below, mandatory FBI policy and procedure required
• 15:16
  Speaker 1: FBI to investigate Maria's allegations. Tragically, however, the FBI violated
• 15:22
  Speaker 1: those mandatory protocols and never followed up on the tips Ms.
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  Speaker 1: Farmer reported to them. On August 29, 2023, the FBI's
• 15:30
  Speaker 1: Assistant General Counsel emailed colleagues about an alleged victim of
• 15:34
  Speaker 1: Epstein who submitted a report in 1996. That victim was
• 15:39
  Speaker 1: Maria Farmer. After a colleague forwarded the report, the Assistant
• 15:43
  Speaker 1: General Counsel asked if any action took place after receiving
• 15:46
  Speaker 1: the complaint. An agent of the Child Exploitation and Human
• 15:50
  Speaker 1: Trafficking Task Force replies, based on the fact that it
• 15:53
  Speaker 1: ended up in a zero file, I'd assume no actions
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  Speaker 1: were taken on it. By failing to investigate Ms. Farmer's allegation,
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  Speaker 1: the FBI failed to exercise reasonable care. That failure to
• 16:05
  Speaker 1: exercise reasonable care increased the risk of the harm that
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  Speaker 1: plaintiff ultimately suffered. The FBI knew or should have known
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  Speaker 1: that its failure to follow Farmer's tips or investigator allegations
• 16:17
  Speaker 1: created an unreasonable risk of harm for other victims, including plaintiffs. Thus,
• 16:22
  Speaker 1: by failing to investigate credible tips such as Ms. Farmer's allegations,
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  Speaker 1: the FBI created a foreseeable zone of risk to future
• 16:30
  Speaker 1: victims of Epstein's sex trafficking enterprise, including plaintiffs. the FBI knew,
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  Speaker 1: should have known, or foresaw that its failure to act
• 16:39
  Speaker 1: endangered Farmer and other potential victims of child sexual abuse
• 16:43
  Speaker 1: and sex trafficking for several reasons. First, as of Farmer's
• 16:46
  Speaker 1: report 96, the FBI knew that Epstein and his co-conspirators
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  Speaker 1: were sexually abusing minors, running a sex trafficking operation, and
• 16:55
  Speaker 1: in possession of CSAM. Second, the FBI knew that these
• 16:59
  Speaker 1: acts were ongoing and not likely to stop without its intervention. Third,
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  Speaker 1: the FBI knew that no other law enforcement organization could
• 17:07
  Speaker 1: investigate such a sprawling, multi-state criminal enterprise, nor support a
• 17:11
  Speaker 1: prosecution based on obvious violations of federal law. Fourth, the
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  Speaker 1: FBI knew that Farmer and other victims had nowhere else
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  Speaker 1: to turn for help. Plaintiff's injuries occurred within the zone
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  Speaker 1: of risk created by the FBI's repeated failure to intervene
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  Speaker 1: and prevent Epstein from continuing to sexually abuse plaintiffs, including
• 17:31
  Speaker 1: other women and minor girls. The FBI's failure to exercise
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  Speaker 1: reasonable care increased the risk of harm and in fact
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  Speaker 1: resulted in harm to plaintiffs. Plaintiffs have suffered harm because
• 17:42
  Speaker 1: Maria Farmer relied on the FBI to investigate her allegations
• 17:46
  Speaker 1: against Epstein. Alright folks, we're going to wrap up this
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  Speaker 1: episode right here and in the next episode dealing with
• 17:52
  Speaker 1: the topic we're going to pick up where we left off.
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  Speaker 1: All the information that goes with this episode can be
• 17:58
  Speaker 1: found in the description box.