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Lisa Doe And Her Allegations Against Jeffrey Epstein And His Estate (Part 5) · The Vault: The Epstein Files

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  Speaker 1: What's up everyone, and welcome back to the Epstein Chronicles.
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  In this episode, we're diving right back in to the
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  lease A dough complaint against Jeffrey Epstein's estate. Count number
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  one Battery against Darren k Endyke and Richard D. Kahn
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  as joint personal representatives of the estate of Jeffrey E. Epstein,
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  one forty seven. The plaintiff adopts and realleges Paragraphs one
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  through one forty six Above one forty eight, Jeffrey Epstein
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  committed a harmful or offensive touching against plaintiff one forty nine.
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  As a direct and proximate result of Jeffrey Epstein's battery,
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  the plaintiff has in the past suffered and in the
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  future will continue to suffer physical injury, pain, emotional distress,
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  psychological trauma, mental anguish, humiliation, embarrassment, loss of self esteem,
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  loss of dignity, invasion of her privacy, and the loss
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  of capacity to enjoy life, as well as other damages.
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  Plaintiff incurred medical and psychological expenses, and plaintiff will in
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  the future suffer additional medical and psychological expenses. These injuries
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  are permanent in nature, and plaintiff will continue to suffer
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  these losses in the future. Wherefore, Plaintiff demands judgment against
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  the Estate of Jeffrey e. Epstein for compensatory and general damages,
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  attorney fees, punitive damages, and such other and further relief
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  as this Court deems just and proper. Plaintiff hereby demands
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  trial by jury on all issues triable as of right
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  by a jury. Count number two battery violation of Section
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  one thirty against Darren k Endyke and Richard D. Con
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  as joint personal representatives of the Estate of Jeffrey e Epstein.
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  The plaintiff adopts and re alleges Paragraphs one through one
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  forty six above one fifty one. The intentional acts of
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  Jeffrey Epstein against plaintiff constitute a sexual offense and define
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  the New York Penal Law Section one thirty, including but
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  not limited to the following a sexual misconduct as defined
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  in Section one thirty dot twenty inasmuch as Jeffrey Epstein
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  engaged in sexual intercourse with plaintiff without Plaintiff's consent b
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  rape in the first degree as defined in Section one
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  thirty dash thirty five. Inasmuch as Jeffrey Epstein engaged in
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  sexual intercourse with plaintiff by forcible compulsion C criminal sexual
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  act in the first degree as defined in Section one
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  thirty dot five zero, inasmuch as Jeffrey Epstein engaged in
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  oral sexual conduct with plaintiff by forcible compulsion D forcible
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  touching as defined in section one thirty dot five two,
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  inasmuch as Jeffrey Epstein intentionally and for no legitimate purposes,
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  engage the forcible sexual touching of plaintiff for the purpose
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  of degrading or abusing her, or for the purpose of
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  gratifying his own sexual desire, and e sexual abuse in
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  the third degree as defined in one thirty dot sixty six,
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  inasmuch as Jeffrey Epstein inserted a foreign object in the
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  vagina of plaintiff by forcible conpulsion one two. As a
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  direct and proximate result of Jeffrey Epstein's violations of New
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  York Penal Laws Section one thirty, plaintiff has in the
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  past suffered and in the future will continue to suffer
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  physical injury, pain, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment,
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  loss of self esteem, loss of dignity, invasion of her
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  privacy and the loss of her capacity to enjoy life,
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  as well as other damages. Plaintiff incurred medical and psychological expenses,
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  and plaintiff in the future will suffer additional medical and
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  psychological expenses. These injuries are permanent in nature, and plaintiff
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  will continue to suffer these losses in the future. Wherefore,
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  Plaintiff demands judgment against the Estate of Jeffrey Epstein for
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  the compensentory and general damages, attorney fees, punitive damages, and
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  others such further reliefs as the Court deems justin proper.
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  Plaintiff hereby demands trial by jury on all issues triable
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  as a right by a jury. Count three Cause of
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  action against Darren Kayendyke and Richard D. Con as joint
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  personal representatives of the Estate of Jeffrey Epstein, pursue it
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  to US Code eighteen, Section fifteen ninety five one fifty three.
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  Plaintiff adopts in realeges paragraphs one through one forty six
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  above one fifty four. Jeffrey Epstein within the special maritime
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  and territorial jurisdiction of the United States in interstate and
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  foreign commerce and or affecting interstate and foreign commerce knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized, solicited, threatened, forced,
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  and coerced plaintiff to engage in commercial sex acts one
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  fIF five. Such actions were undertaken knowing that his use
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  of force, threats of force, fraud, coercion, and or a
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  combinationation of such means would be used, and were in
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  fact used in order to cause plaintiff to engage in
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  commercial sex acts. In doing so, Jeffrey Epstein violated US
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  Code eighteen, section fifteen ninety one, one fifty six. Furthermore, at,
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  Jeffrey Epstein attempted to violate US Code eighteen, section fifteen
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  ninety one. In doing so, violated US Code eighteen section
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  fifteen ninety four A. One fifty seven. Jeffrey Epstein conspired
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  with each member of the enterprise and with other persons
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  known and unknown, to violate US Code eighteen section fifteen
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  ninety one. In doing so, violated US Code eighteen section
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  fifteen ninety four C. One fifty eight. By virtue of
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  Jeffrey Epstein's violations of US Code eighteen section fifteen ninety one,
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  fifteen ninety three A and fifteen ninety four defended Darren
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  k Endyke and Richard D. Con as joint personnel representatives
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  of the estate of Jeffrey E. Epstein is subject to
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  civil causes of action under US Code eighteen, section fifteen
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  ninety five by plaintiff who was a victim of the
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  violations one fifty nine. Certain property of Epstein's was essential
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  to the commission of the federal crimes and torts described
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  here in, including the use of multiple private aircraft, including
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  a Boeing Aircraft of making Model B seven twenty seven
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  thirty one H with tail number N nine zero eight JE,
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  and a gulf Stream Aircraft of making Model G eleven
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  fifty nine B with tel number N nine h nine JE.
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  Such aircraft, along with other of Jeffrey Epstein's property, were
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  used as means and instruments of Jeffrey Epstein's tortious and
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  criminal offenses, and as such are subject of forfeiture one
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  sixty one as direct and proximate result of Jeffrey Epstein's
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  commission of the aforementioned criminal offenses enumerated in US Code eighteen,
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  section fifteen ninety one, fifteen ninety three A, and fifteen
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  ninete and the associated civil remedies provided in Section fifteen
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  ninety five. Plaintiff has in the past suffered and will
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  continue to suffer injury and pain, emotional distress, psychological and
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  psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of self esteem,
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  loss of dignity, loss of enjoyment of life, invasion of privacy,
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  and other damages associated with actions. Plaintiff will incur further
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  medical and psychological expenses. These injuries are permanent in nature,
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  and Plaintiff will continue to suffer from them in the future.
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  In addition to these losses, Plaintiff has incurred attorney fees
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  and will be required to do so in the future. Wherefore,
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  Plaintiff demands judgment against the Estate of Jeffrey E. Epstein
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  for compensatory and general damages, attorney fees, punitive damages, and
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  such other and further relief as this Court deems just
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  and proper. Plaintiff hereby demands trial by jury on all
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  issues triable as a right by a jury. Count number four.
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  Cause of action against ninety seventy one Street Corporation, pursuant
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  to US Code eighteen, Section fifteen ninety five, one sixty two.
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  Plaintiff adopts and re alleges Paragraphs one through one forty
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  six above. One sixty three. Defendant buy And, through its
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  management and personnel within the special maritime and territorial jurisdiction
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  of the United States in interstate and foreign commerce and
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  or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
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  solicited by any means Plaintiff from two thousand and seven
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  through twenty ten one sixty four. Defendant buy And, through
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  its management and personnel, knew that means of fraud, core corrosion,
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  and or combinations of such means would be used and
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  were in fact used in order to cause Plaintiff to
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  engage in commercial sex acts. In doing so, Defendant Corporation
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  violated US Code eighteen, section fifteen ninety one one sixty five. Furthermore,
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  Defendant Corporation attempted to violate US Code eighteen, section fifteen
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  ninety one. In doing so, violated US Code eighteen fifteen
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  ninety four A. One sixty six. Defendant buy And, through
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  its management and personnel, conspired with other members of the
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  enterprise and with other persons and companies known and unknown
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  to violate US Code eighteen, section fifteen ninety one. In
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  doing so, Defendant violated US Code eighteen section fifteen ninety
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  four C. One sixty seven. By virtue of their violations
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  of US Code eighteen section fifteen ninety one, fifteen ninety
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  three A, and fifteen ninety four, Defendant is subject to
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  civil causes of action under US Code eighteen, section fifteen
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  ninety five by plaintiff who was a victim of their violations.
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  One sixty eight. Defendant buy And, through its man management
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  and personnel, participated in a venture with Jeffrey Epstein's enterprise
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  by knowingly recruiting, transporting, soliciting, obtaining, and maintaining plaintiff, knowing
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  that fraud or coercion would be used to cause plaintiff
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  to commit a commercial sex act one eight. As a
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  direct and proximate result of defendants corporations commission of the
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  aforementioned criminal offenses enumerated in US Code eighteen section fifteen
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  ninety one, fifteen ninety three A, and fifteen ninety four,
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  and the associated civil remedies provided in US Code fifteen
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  ninety five, Plaintiff has in the past suffered and will
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  continue to suffer injury and pain, emotional distress, psychological and
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  psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of self esteem,
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  loss of dignity, loss of enjoyment of life, invasion of privacy,
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  and other damages associated with actions. Plaintiff will incur further
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  medical and psychological expenses. These injuries are permanent in nature,
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  and Plaintiff will continue to suffer from them in the future.
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  In addition to these losses, Plaintiff has incurred attorney fees
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  and will be required to do so in the future. Wherefore,
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  Plaintiff demands judgment against Defendant Financial Trust Company Incorporated for
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  compensatory and general damages, attorney fees, punitive damages, and such
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  other and further relief as this Court deems just and proper.
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  Plaintiff hereby demands trial by jury on all issues triable
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  as of right by a jury. Count number six Cause
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  of Action against NESLLC one seventy nine. Plaintiff adopts and
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  re alleges Paragraphs one through one forty six above one.
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  Defendant buy and through its management and personnel within the
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  special Maritime and Territorial jurisdiction of the United States in
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  interstate and foreign commerce, and or affecting interstate and foreign commerce,
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  knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized, solicited
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  by any means Plaintiff one eighty one. Defendant buy And,
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  through its management and personnel, knew that means of fraud
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  or coercion and lore combinations of such means would be used,
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  and were in fact used in order to cause Plaintiff
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  to engage in commercial sex acts. In doing so, Defendant
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  Corporation violated US Code eighteen, section fifteen ninety one one
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  eighty two. Furthermore, Defendant Corporation attempted to violate US Code eighteen,
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  section fifteen ninety one. In doing so, violated US Code
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  eighteen section fifteen ninety four A. One eighty three. Defendant
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  buy And, through its management and personnel, conspired with other
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  members of the enterprise and with other persons and companies
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  known and unknown, to violate US Code eighteen, section fifteen
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  ninety one. In doing so, defendant violated US Code eighteen,
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  section fifteen ninety four C. One eighty four by virtue
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  of their violations of US Code eighteen section fifteen ninety one,
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  fifteen ninety three A, and fifteen ninety four. Defendant is
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  subject to civil causes of action under US Code eighteen,
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  Section fifteen ninety five by plaintiff who is a victim
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  of their violations. One eighty five. Defendant buy And, through
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  its management and personnel, participated in a venture with Jeffrey
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  Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and maintaining plaintiff,
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  knowing that fraud or coercion would be used to cause
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  plaintiff to commit a commercial sex act one eighty six.
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  As a direct and proximate result of defendant corporations commission
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  of the aforementioned criminal offenses enumerated in US Code eighteen,
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  section fifteen ninety one, fifteen ninety three, and fifteen ninety four,
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  and the associated civil remedies provided in section fifteen ninety five.
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  Plaintiff has in the past suffered and will continue to suffer,
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  injury and pain, emotional distress, psychological and psychiatric trauma meant
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  the languish, humiliation, confusion, embarrassment, loss of self esteem, loss
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  of dignity, loss of enjoyment of life, invasion of privacy,
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  and other damages associated with actions, Plaintiff will incur further
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  medical and psychological expenses. These injuries are permanent in nature
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  and plaintiff will continue to suffer from them in the future.
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  In addition to these losses, Plaintiff has incurred attorney fees
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  and will be required to do so in the future. Wherefore,
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  Plaintiff demands judgment against Defendant NES Incorporated for compensatory in
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  general damages, attorney fees, punitive damages, and such other and
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  further relief as this coret deems just and proper. Plaintiff
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  hereby demands trial by jury on all issues triable as
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  of the right by a jury. Count number seven. Cause
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  of action against HBRK Associates Incorporated. One seven. Plaintiff adopts
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  and realeges Paragraph U one for six above. One eight eight.
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  Defendant BUY And, through its management and personnel within the
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  special maritime and territorial jurisdiction of the United States in
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  interstate and foreign commerce and or affecting interstate and foreign commerce,
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  knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized, solicited
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  by any means. Plaintiff one eight nine. Defendant Buy And,
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  through its management and personnel, knew that means of fraud
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  or coercion, and or combination of such means would be used,
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  and were in fact used, in order to cause plaintiff
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  to engage in commercial sex acts. In doing so, Defendant
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  Corporation violated US Code eighteen, section fifteen ninety one one ninety.
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  Defendant buy And, through its management and personnel, knowingly benefited
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  financially and by receiving things of value from participating in
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  the venture the Epstein sex Trafficking Venture Enterprise, which had
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  engaged in acts of violation of US Code eighteen, section
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  fifteen ninety two and fifteen ninety five A, knowing that
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  the venture had engaged in such violations. In doing so,
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  Defendant Corporation violated US Code eighteen, section fifteen ninety three
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  A one ninety one. Furthermore, Defendant Corporation attempted to violate
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  US Code eighteen, section fifteen ninety one. In doing so,
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  violated US Code eighteen section fifteen ninety four A one
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  ninety two. Defendant buy And, through its management and personnel,
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  conspired with other members of the enterprise and with other
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  persons and companies known and unknown, to violate US Code eighteen,
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  section fifteen ninety one. In doing so, defendant violated eighteen
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  US Code Section fifteen ninety four C. One ninety three
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  by virtue of their violations of US Code eighteen section
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  fifteen ninety one, fifteen ninety three A, and fifteen ninety
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  four defend in a subject to civil causes of action
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  under US Code eighteen, section fifteen ninety five by plaintiff
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  who was a victim of their violations. One ninety four.
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  Defendant buy And, through its management and personnel, participated in
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  a venture with Jeffrey Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining,
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  and maintaining plaintiff, knowing that fraud or coercion would be
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  used to cause plaintiff to commit a commercial sex act
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  one ninety five. As a direct and proximate result of
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  defendants corporation commission of the aforementioned criminal offenses enumerated in
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  US Code eighteen section fifteen ninety one, fifteen ninety three A,
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  and fifteen ninety four, and the associated civil remedies provided
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  in section fifteen ninety five, Plaintiff has in the past
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  suffered and will continue to suffer injury and pain, emotional distress,
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  psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss
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  of self esteem, loss of dignity, loss of enjoyment of life,
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  invasion of privacy, and other damages associated with actions Plaintiff
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  will incur further medical and psychological expenses. These injuries are
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  permanent in nature, and Plaintiff will continue to suffer from
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  them in the future. In addition to these losses, Plaintiff
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  has incurred attorney fees and will be required to do
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  so in the future. Wherefore, Plaintiff demands judgment against Defendant
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  HBRK Associates for compensatory and general damages, attorney fees, punitive damages,
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  and such other and further relief as this Court deems
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  just and proper. Plaintiff hereby demands trial by jury on
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  all issues triable as of right by a jury. This
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  document was signed by Stanley Pottinger and it was dated
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  August twentieth, twenty nineteen. All right, folks, that's going to
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  wrap up Lisade number one and her complaints against the
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  Jeffrey Epstein estate. All the information that goes with this
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  episode can be found in the description box.