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Mega Edition: The Amended Epstein Survivor Lawsuit Filed Against The USVI (Part 1-3) (11/1/26) · The Moscow Murders and More

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  Speaker 1: What's up everyone and welcome back to the Epstein Chronicles.
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  Speaker 1: In this episode we're getting right back to those court
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  Speaker 1: documents and we're going to take a look at the
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  Speaker 1: amended complaint filed by the Jane Doe's against the United
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  Speaker 1: States Virgin Islands. The amended complaint and the demand for
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  Speaker 1: a jury trial. 1. Plaintiffs Jane Doe 1, Jane Doe 2,
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  Speaker 1: Jane Doe 3, Jane Doe 4, Jane Doe 5, and
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  Speaker 1: Jane Doe 6 individually and on behalf of all others
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  Speaker 1: similarly situated, filed this amended complaint against the government of
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  Speaker 1: the United States Virgin Islands, hereafter USVI, First Lady Cecile
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  Speaker 1: de Jong, Governor Kenneth Mapp, Senator Celestino White, Attorney General
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  Speaker 1: Vincent Frazier, Governor John de Jong, Senator Carlton Dow, Delegate
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  Speaker 1: Stacey Plaskett, and John Doe's 1-100. For violations of the
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  Speaker 1: Trafficking Victims Protection Act, TVPA, U.S. Code 18, Section 1591-1595,
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  Speaker 1: and of negligence, and in support thereof, allege as follows. 1. Jurisdiction, venue,
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  Speaker 1: and timelines. 2. This action is brought pursuant to various
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  Speaker 1: federal and U.S. territorial statutes, including the Federal Trafficking Victims
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  Speaker 1: Protective Act, TVPA, U.S. Code 18, Section 1589-1595. This court
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  Speaker 1: has federal question subject matter jurisdiction pursuant to U.S. Code 28,
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  Speaker 1: Section 1331, because Jane Doe 1, Jane Doe 2, Jane
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  Speaker 1: Doe 3, Jane Doe 4, Jane Doe 5, and Jane
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  Speaker 1: Doe 6, each individually and on behalf of all others
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  Speaker 1: similarly situated, proceed under the federal TVPA statute. 3. This
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  Speaker 1: court has also supplemental jurisdiction of the state law claims
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  Speaker 1: recounted below pursuant to U.S. Code 28, Section 1367A. because
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  Speaker 1: all claims alleged herein are part of a uniform pattern
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  Speaker 1: and practice and form part of the same case or controversy. 4.
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  Speaker 1: Venue is proper in the United States District Court of
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  Speaker 1: the Southern District of New York, pursuant to U.S. Code 28,
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  Speaker 1: Section 1391, B and 2, because substantial activities occurred in
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  Speaker 1: this district, including, but not limited to, the following. 1.
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  Speaker 1: Epstein's sex trafficking operation was based, managed, and operated out
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  Speaker 1: of New York City, in this district. 2. Defendants, their officers, agencies, agents, servants,
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  Speaker 1: and or employees regularly communicated with Epstein about the formation, operation,
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  Speaker 1: maintenance of Epstein's sex trafficking ring by electronic means, including voice, telephone,
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  Speaker 1: text message, video, telephone, or meeting, while Epstein was in
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  Speaker 1: his New York office and or residence in this district. 3.
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  Speaker 1: Epstein and his co-conspirators, including defendants, knowingly aided and abetted, facilitated,
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  Speaker 1: and directly participated in Epstein's illegal venture through financial and
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  Speaker 1: non-financial transactions that originated in this district. 4. The commercial
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  Speaker 1: acts of sexual abuse committed by Epstein and certain select
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  Speaker 1: friends took place in Jeffrey Epstein's New York mansion located
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  Speaker 1: within this district at 9E 71st Street, New York City,
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  Speaker 1: among other locations including the USVI. Epstein used his New
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  Speaker 1: York mansion to harbor his victim's and as a base
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  Speaker 1: from which to transport them to other locations outside of
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  Speaker 1: New York. 5. Defendants received numerous substantial payments from Epstein's J.P.
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  Speaker 1: Morgan Chase New York accounts, as demonstrated below and as
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  Speaker 1: set forth in the various filings of both parties in
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  Speaker 1: the Government of the U.S. Virgin Islands v. J.P. Morgan Bank,
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  Speaker 1: North America, Case No. 122-CV-10904-JSR-SDNY-2023. 6. On at least one occasion,
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  Speaker 1: First Lady Cecile de Jong stayed in one of Epstein's
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  Speaker 1: apartments in New York for a month in 2017, nearly
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  Speaker 1: a decade after Epstein completed his prison sentence for soliciting
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  Speaker 1: minors for prostitution, in order to advise and assist him
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  Speaker 1: in securing the USVI's cooperation as a safe harbor for
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  Speaker 1: his sex trafficking ring. 8. Stacey Plaskett, delegate to the U.S.
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  Speaker 1: House of Representatives from the USVI's At-Large District, visited Epstein
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  Speaker 1: at his New York mansion to request that he contribute
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  Speaker 1: to her political campaigns, and Epstein and his colleagues paid
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  Speaker 1: her campaigns $ 30, 000. Plaskett also visited Epstein at his New
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  Speaker 1: York mansion to request a $ 30, 000 contribution to the Democratic
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  Speaker 1: National Committee, which was ultimately declined because, Plaskett knew, Epstein
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  Speaker 1: failed their vetting. 8. The transportation for the Epstein sex
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  Speaker 1: trafficking ring was owned, stored, and maintained in New York State,
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  Speaker 1: in particular Epstein's private jets and vehicles, which were used
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  Speaker 1: to transport victims and Epstein's clients or purchased, owned, stored,
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  Speaker 1: and maintained in New York. 9. Many of the trafficked women,
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  Speaker 1: including plaintiffs herein, were solicited by Epstein while he was
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  Speaker 1: in New York and then transported from New York to
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  Speaker 1: the USVI and held captive and abused in the USVI
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  Speaker 1: at Epstein's USVI estate. 10. At the time of the
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  Speaker 1: events at issue, plaintiffs resided in New York, New York,
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  Speaker 1: in this district. 11. Likewise, Epstein solicited many of his
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  Speaker 1: co-conspirators for the sex trafficking ring during meetings held in
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  Speaker 1: New York, seeking out their interest in engaging in sex
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  Speaker 1: crimes before extending invitations to the island, inclusive of his
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  Speaker 1: private transportation, to avoid publicity. 12. Epstein also facilitated entry
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  Speaker 1: into the United States Virgin Islands for the procurement of
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  Speaker 1: travel documents while he was in New York office and
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  Speaker 1: or residence. 5. All causes of action arose from 2001-2009.
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  Speaker 1: and continuing until 2019. 6. This action has been timely
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  Speaker 1: filed pursuant to U.S. Code 18, Section 1595-C1, which provides
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  Speaker 1: that a plaintiff shall have 10 years after the cause
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  Speaker 1: of action arose to file suit against any person who
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  Speaker 1: knowingly benefits financially or by receiving anything of value from
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  Speaker 1: participation in a venture which that person knew or should
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  Speaker 1: have known violated the laws against sex trafficking. As the
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  Speaker 1: conspiracy continued until 2019, This action is timely. This action
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  Speaker 1: is also timely under the New York Adult Survivors Act 7. Further,
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  Speaker 1: defendants actively and knowingly concealed their tortious actions from the
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  Speaker 1: plaintiffs and the public for many years. It was not
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  Speaker 1: until the recent case U.S. Virgin Islands v. J.P. Morgan
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  Speaker 1: Chase Bank, North America, U.S. District Court SDNY No. 22-10904
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  Speaker 1: where JPMorgan Chase deposed members of the USVI government that
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  Speaker 1: the plaintiffs and public learned of the many acts committed
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  Speaker 1: by defendants which contributed to and caused plaintiffs' injuries under
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  Speaker 1: the federal statute set forth below. 8. In addition, the
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  Speaker 1: New York Adult Survivors Act created a one-year window for
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  Speaker 1: adult sexual abuse victims to bring their negligence claims, making
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  Speaker 1: this action timely under CPLR 214-J. 2. The Introduction 9.
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  Speaker 1: Plaintiffs Jane Doe 1 Jane Doe 2, Jane Doe 3,
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  Speaker 1: Jane Doe 4, Jane Doe 5, and Jane Doe 6,
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  Speaker 1: on their behalf and on behalf of others similarly situated,
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  Speaker 1: file this complaint for damages and other relief, among other
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  Speaker 1: provisions of law, the United States Federal Anti-Sex Trafficking Statute, U.S.
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  Speaker 1: Code 18, Section 1591, the Trafficking Victim Protection Act, TVPA,
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  Speaker 1: and for aiding and abetting and negligence. 10. The suit
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  Speaker 1: arises from the USVI's participation in and involvement in Jeffrey
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  Speaker 1: Epstein's widespread and well-publicized sex trafficking operation, as well as
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  Speaker 1: the many individuals and representatives of the government who gave
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  Speaker 1: orders to provide preferential treatment to Epstein, which allowed, collaborated,
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  Speaker 1: and encouraged him to continue his sex trafficking enterprise in
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  Speaker 1: order to continue to receive the benefits it derived from
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  Speaker 1: its relationship with him. 11. The USVI's government actions actively
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  Speaker 1: facilitated Epstein's crimes and misconduct. 12. Government officials, including but
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  Speaker 1: not limited to defendants First Lady Cecile de Jong, Governor
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  Speaker 1: Kenneth Mapp, Senator Celestino White, Attorney General Vincent Frazier, Governor
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  Speaker 1: John de Jong, Stacey Plaskett, and Senator Carlton Dow, facilitated
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  Speaker 1: Epstein in his ongoing sex trafficking operation by ensuring that
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  Speaker 1: Epstein received preferential treatment and unfettered, unmonitored freedom while in
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  Speaker 1: the USVI, and by providing Epstein and or his company's instruments,
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  Speaker 1: which further enabled his sex trafficking ring, and related crimes. 13.
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  Speaker 1: Upon information and belief, government employees John Doe's 1-100 followed
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  Speaker 1: the orders of the aforementioned government officials, the USVI, and
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  Speaker 1: others further enabling Epstein in his crimes. 14. Defendant USVI
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  Speaker 1: knew or should have known that it was providing Epstein
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  Speaker 1: with a safe haven to create, operate, maintain, and expand
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  Speaker 1: his sex trafficking ring. The protection of the government to
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  Speaker 1: run said operation and the willful ignorance that such operations
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  Speaker 1: were occurring and continuing to occur at the behest of
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  Speaker 1: the USVI government. 15. Government officials and employees were given
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  Speaker 1: orders to carry out said government-sanctioned priorities, privileges, and benefits,
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  Speaker 1: negligently allowing Epstein to continue with his operations uninterrupted and
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  Speaker 1: without fear of police, airport, Coast Guard, or customs intervention.
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  Speaker 1: In exchange, the USVI government leaders, staff, and officials were
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  Speaker 1: benefited by receiving generous financial donations, financial advice, support loans,
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  Speaker 1: access to lines of credit from Epstein and his entities,
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  Speaker 1: and that crucial financial support allowed Epstein to successfully rape,
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  Speaker 1: sexually assault, coercively sex-trafficked plaintiffs, and numerous other women freely
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  Speaker 1: and openly, access to underage and other women, and a
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  Speaker 1: haven to act without government scrutiny by customs, police, or
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  Speaker 1: airport personnel, or public knowledge. Sixteen. Other government staff and officials,
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  Speaker 1: including John Doe's 100, followed the orders of these officials
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  Speaker 1: and in turn maintained their government employment. Three. The parties. Seventeen.
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  Speaker 1: Jane Doe is a U.S. citizen and was at all
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  Speaker 1: relevant times a resident of and domiciled in the state
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  Speaker 1: of New York, New York. Eighteen. 19. Jane Doe 2
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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 in the state of New York. 20.
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  Speaker 1: Jane Doe 4 is a U.S. citizen and was at
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  Speaker 1: all times a resident of and domiciled in the state
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  Speaker 1: of New York. 21. Jane Doe 5 is a U.S.
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  Speaker 1: citizen and was at all times a resident of and
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  Speaker 1: domiciled in the state of New York. and was at
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  Speaker 1: all relevant times a resident of and domiciled in the
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  Speaker 1: state of New York. 22. Jane Doe Six 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 in the state of New York. 23. The Jane
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  Speaker 1: Doe plaintiffs are using a pseudonym to protect their identity
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  Speaker 1: because of the sensitive and highly personal nature of this matter,
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  Speaker 1: which involves sexual assault. 24. The Jane Doe plaintiffs are
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  Speaker 1: also at serious risk of retaliatory harm Twenty-five. Twenty-six. The
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  Speaker 1: Jane Doe's plaintiff's legitimate concerns outweigh any prejudice to defendants
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  Speaker 1: by allowing them to proceed anonymously. Accordingly, the Jane Doe
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  Speaker 1: plaintiffs filed a motion to proceed anonymously that was granted
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  Speaker 1: by this court. 27. As discussed below, many other women
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  Speaker 1: who are victims and survivors of sexual abuse and trafficking
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  Speaker 1: are similarly situated to the Jane Doe plaintiffs and also
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  Speaker 1: need to proceed anonymously for the same reasons. The identities
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  Speaker 1: of most of these women are are known to defendants
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  Speaker 1: and will be provided to them as required. 28. Plaintiffs
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  Speaker 1: bring this action against the Attorney General, pursuant to its
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  Speaker 1: authority to represent the government of the United States Virgin Islands. 29.
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  Speaker 1: Plaintiffs bring this action against the Attorney General as a
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  Speaker 1: representative of the USVI, which is vicariously liable for the
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  Speaker 1: negligent acts of its employees, including John Doe's 1-100, pursuant
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  Speaker 1: to the Virgin Island Code, 33. Section 3411 and 3414A. 30.
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  Speaker 1: Defendant First Lady Cecile de Jong was at all relevant
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  Speaker 1: times the First Lady of the USVI. 31. Defendant Governor
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  Speaker 1: Kenneth Mapp was at all relevant times the Governor of
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  Speaker 1: the USVI. 32. Defendant Celestino White was at all relevant
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  Speaker 1: times the Senator of the USVI. 33. Defendant Attorney General
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  Speaker 1: Vincent Frazier was at all relevant times the Attorney General
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  Speaker 1: of the USVI. Thirty-four. Defendant Governor John DeJong was, at
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  Speaker 1: all relevant times, the governor of the USVI. Thirty-five. Senator
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  Speaker 1: Carlton Dow was, at all relevant times, the senator of
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  Speaker 1: the USVI. Thirty-six. Defendant Stacey Plaskett was, at all relevant times,
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  Speaker 1: an attorney for the USVI's EDC when it approved over
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  Speaker 1: $ 300 million in tax breaks for Epstein's companies and a
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  Speaker 1: delegate to the U.S. House of Representatives from the U.S.
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  Speaker 1: Virgin Islands at-large district. Thirty-seven. Defendants John Does 1-10 and
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  Speaker 1: 51-100 were employees of the USVI working for and of
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  Speaker 1: the USVI as their agents, employees, and or officers acting
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  Speaker 1: in the scope of their employment as USVI customs agents
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  Speaker 1: and or officers. 38. Defendants John Does 11-20 were employees
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  Speaker 1: of the USVI working for and of the USVI as
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  Speaker 1: their agents, employees, and or officers acting in the scope
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  Speaker 1: of their employment for the USVI as air traffic controllers. 39.
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  Speaker 1: Defendants John Does, 21-30, were employees of the USVI, working
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  Speaker 1: for and as the USVI as agents, employees, officers, acting
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  Speaker 1: in the scope of their employment as airport baggage check agents. 40.
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  Speaker 1: Defendants John Does, 31-40, were employees of the USVL, working
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  Speaker 1: for and of the USVI as their agents, employees, and
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  Speaker 1: or officers acting in the scope of their employment as
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  Speaker 1: USVI police officers. 41. Defendants John Doe's 41 through 50
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  Speaker 1: were employees of the USVI working for and of the
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  Speaker 1: USVI as their agents, employees, and or officers acting in
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  Speaker 1: the scope of their employment as USVI Coast Guard agents. 42.
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  Speaker 1: The USVI is responsible under United States law and otherwise
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  Speaker 1: for the acts of its officers, directors, employees, and agents
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  Speaker 1: including the acts described in this complaint. 43. The acts
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  Speaker 1: alleged were committed by USVI officers, directors, employees, and and
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  Speaker 1: agents were within the actual and apparent scope of their
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  Speaker 1: employment and with the intention, at least in part, to
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  Speaker 1: benefit the USVI. 44. USVI's governmental activities, including the events
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  Speaker 1: alleged herein, were in and affecting interstate and foreign commerce.
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  Speaker 1: In connection with the acts alleged in this complaint, defendants
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  Speaker 1: directly or indirectly used the means and instrumentalities of interstate commerce,
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  Speaker 1: including but not limited to the airports, ports, and territories.
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  Speaker 1: All right, we're going to wrap up the first episode here.
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  Speaker 1: And in the next episode, we're going to pick up
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  Speaker 1: with four facts of the case. All of the information
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  Speaker 1: that goes with this episode can be found in the
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  Speaker 1: description box. What's up, everyone? And welcome back to 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 amended complaint filed by the survivors
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  Speaker 1: against the USVI. Four facts of the case. A. Epstein
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  Speaker 1: sex trafficking ring and defendant's knowledge, assistance. and facilitation of
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  Speaker 1: the criminal enterprise. 45. The Epstein sex trafficking venture originated
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  Speaker 1: in the early 1990s. From its inception until Jeffrey Epstein's
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  Speaker 1: arrest by the FBI for sex trafficking in 2019 and
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  Speaker 1: his subsequent death on August 10, 2019 by apparent suicide,
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  Speaker 1: the venture operated primarily for the purpose of luring young
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  Speaker 1: women and girls, including plaintiffs, into a position where Jeffrey
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  Speaker 1: Epstein and his co-conspirators could coerce them to engage in
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  Speaker 1: commercial sex acts and commit sexual offenses against them. His
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  Speaker 1: venture provided financial and other benefits to those who assisted
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  Speaker 1: and enabled the venture. 46. The Epstein sex trafficking venture
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  Speaker 1: was well-structured and grew increasingly more complex and powerful as
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  Speaker 1: it victimized more young women and as its relationships with
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  Speaker 1: the USVI and many government officials grew. 47. The Epstein
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  Speaker 1: sex trafficking venture purpose included enticing, obtaining, harboring, and transporting
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  Speaker 1: the young women, including plaintiffs, to numerous places, including but
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  Speaker 1: not limited to the USVI, where they would be removed
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  Speaker 1: from their families, friends, and loved ones, and be completely isolated.
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  Speaker 1: The venture had everything a sex trafficking organization needed, funding, infrastructure,
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  Speaker 1: a place to operate said organization openly and without fear
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  Speaker 1: of interference or oversight, and complicit laws, employees, and government.
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  Speaker 1: It was by many accounts the most powerful and wealthiest
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  Speaker 1: sex trafficking venture ever created. Once in Epstein's clutches, each
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  Speaker 1: victim was taught and understood that she must completely be
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  Speaker 1: compliant with every demand Epstein or his clients made. Otherwise,
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  Speaker 1: she would certainly suffer serious reputational, financial, and psychological harm. 48.
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  Speaker 1: In creating and maintaining this network of victims worldwide whom
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  Speaker 1: they could force to engage in commercial sex acts, Epstein
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  Speaker 1: conspired with others, including defendants and others who facilitated his
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  Speaker 1: conduct by, among other things, recruiting victims, coercing victims, and
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  Speaker 1: scheduling their sexual abuse by Epstein at his New York mansion,
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  Speaker 1: his Palm Beach mansion, and his island in the USVI.
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  Speaker 1: Epstein's victims were young women and girls, like plaintiffs, who
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  Speaker 1: suffered severe abuse as Epstein's sex trafficking victims and who
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  Speaker 1: believed that they had to remain loyal to the venture
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  Speaker 1: at all costs to survive. Epstein victimized hundreds of young
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  Speaker 1: women and girls with the assistance of a wide network
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  Speaker 1: of co-conspirators, including the USVI and its many government officials
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  Speaker 1: and staff. 49. The sex trafficking venture knowingly used means
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  Speaker 1: of force, threats of force, fraud, coercion, including threats of
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  Speaker 1: serious harm or physical restraint, and abuse of law and
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  Speaker 1: the legal process to cause Jane Doe's 1-6 and many
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  Speaker 1: dozens of others similarly situated to engage in commercial sex acts.
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  Speaker 1: Epstein fraudulently represented to the victims, including plaintiffs, that he
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  Speaker 1: would take care of them in various ways, which ultimately
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  Speaker 1: allowed Epstein to cause them to engage in commercial sex
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  Speaker 1: acts with himself and on occasion select others, as well
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  Speaker 1: as to create the opportunity for Epstein to sexually abuse them. 50.
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  Speaker 1: Among other things, Epstein causes victims to engage in commercial
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  Speaker 1: sex acts. 51. As one means of causing victims to
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  Speaker 1: engage in commercial sex acts, Epstein... and his co-conspirators threatened
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  Speaker 1: that harm would come to victims if they did not
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  Speaker 1: comply with their demands that they perform commercial sex acts. 52.
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  Speaker 1: As another means of causing victims to engage in commercial
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  Speaker 1: sex acts, Epstein and his co-conspirators fraudulently promised to further
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  Speaker 1: victims' educational or career aspirations if they would comply with
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  Speaker 1: his sexual demands. 53. Epstein and his co-conspirators also caused
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  Speaker 1: victims to engage in commercial sex acts, Epstein and his
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  Speaker 1: co-conspirators would gift his victims money and provide them with
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  Speaker 1: living accommodations, clothing, education, or other necessities. Epstein and his
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  Speaker 1: co-conspirators would then force them to pay off the debt
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  Speaker 1: by complying with Epstein's sexual demands. 54. Epstein recruited, solicited, enticed, harbored, obtained, provided,
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  Speaker 1: and transported his victims to cause them to engage in
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  Speaker 1: commercial sex acts in ways that were in and affecting
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  Speaker 1: interstate and foreign commerce. including using means of interstate communications,
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  Speaker 1: such as cellular telephones, and means of interstate and foreign travel,
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  Speaker 1: such as aircraft that he owned and controlled. 55. Epstein
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  Speaker 1: transported his victims in interstate and foreign commerce, including transportation
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  Speaker 1: to and from his mansion in this district. 56. The
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  Speaker 1: Epstein sex trafficking venture transported victims across state boundaries between
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  Speaker 1: New York, Florida, and the USVI and elsewhere. 57. Epstein
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  Speaker 1: did not act alone. He created and maintained his sex
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  Speaker 1: trafficking venture with the assistance of other influential individuals and
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  Speaker 1: entities who knew or should have known that he was
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  Speaker 1: sexually abusing and sexually trafficking young women and girls, but
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  Speaker 1: nevertheless supported the sex trafficking enterprise. Epstein's sex trafficking venture
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  Speaker 1: was not possible without the assistance and complicity of defendants
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  Speaker 1: who provided his operation with an appearance of legitimacy and
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  Speaker 1: and special treatment to the sex trafficking venture, thereby ensuring
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  Speaker 1: its continued operation and sexual abuse and sex trafficking of
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  Speaker 1: young women and girls. Without defendants' participation, Epstein's sex trafficking
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  Speaker 1: scheme could not have existed nor flourished. 58. The USVI
• 21:18
  Speaker 1: negligently and or intentionally provided special treatment to Epstein and
• 21:23
  Speaker 1: the sex trafficking venture through their territories, laws, employees, staff, airports, ports,
• 21:28
  Speaker 1: and government staff and officials. 59. thereby ensuring Epstein's sex
• 21:31
  Speaker 1: trafficking ventures continued operation and sexual abuse and sex trafficking
• 21:35
  Speaker 1: of young women and girls. Without the USVI's government inclusive
• 21:39
  Speaker 1: of defendants, Epstein's sex trafficking scheme could not have existed
• 21:43
  Speaker 1: and flourished undisturbed in the USVI. 59. Defendants USVI negligently hired, supervised,
• 21:51
  Speaker 1: and retained defendants John Doe's 1-100, 60. The victims, including plaintiff,
• 21:56
  Speaker 1: could not escape from Epstein's enterprise because the Epstein sex
• 21:59
  Speaker 1: trafficking venture used the USVI laws and agencies, defendants and
• 22:04
  Speaker 1: others to cause plaintiffs and many others of similarly situated
• 22:08
  Speaker 1: women to engage in commercial sex acts and remain in
• 22:11
  Speaker 1: the USVI until Epstein permitted them to leave, as explained herein. 61.
• 22:15
  Speaker 1: The Epstein sex trafficking venture operated in and affected interstate
• 22:20
  Speaker 1: and foreign commerce. Epstein recruited, solicited, coerced, harbored, transported, and
• 22:25
  Speaker 1: enticed some of his victims, including plaintiffs and others similarly situated,
• 22:30
  Speaker 1: to engage in commercial sex acts in, among other places,
• 22:33
  Speaker 1: New York, including the Southern District of New York, Florida,
• 22:37
  Speaker 1: and the USVI. 62. Plaintiffs were injured as a result
• 22:41
  Speaker 1: of the existence and success of the sex trafficking ring.
• 22:44
  Speaker 1: For instance, Epstein arranged with defendants and or their agents, servants,
• 22:48
  Speaker 1: and or employees to allow Jane Doe 2 and Jane
• 22:51
  Speaker 1: Doe 3 into the USVI for the purpose of sexually
• 22:54
  Speaker 1: abusing them, even though their visas were expired, which caused
• 22:58
  Speaker 1: them to be sexually trafficked, abused, assaulted, and battered by
• 23:01
  Speaker 1: Epstein in the USVI. Epstein could not and would not
• 23:04
  Speaker 1: have sexually trafficked, abused, assaulted, and battered Jane Doe 2
• 23:08
  Speaker 1: and Jane Doe 3 in the USVI unless without the
• 23:10
  Speaker 1: unlawful conduct of defendants and or their agents, servants, and
• 23:14
  Speaker 1: or employees. 63. In approximately 2003 or 2004, Epstein brought
• 23:20
  Speaker 1: Jane Doe Ford to his office in Red Hook on St.
• 23:23
  Speaker 1: Thomas for the purpose of sexually abusing her. Epstein's office
• 23:26
  Speaker 1: had two doors, one that led out to an open
• 23:28
  Speaker 1: courtyard and the other to an area where defendant Cecile
• 23:31
  Speaker 1: Dijon sat with her desk positioned adjacent against the exterior
• 23:35
  Speaker 1: wall of Epstein's office. There, Epstein grabbed Jane Doe 4
• 23:40
  Speaker 1: into his office from the courtyard entrance and raped her
• 23:43
  Speaker 1: over his desk. The brutal assault lasted about 10 minutes.
• 23:46
  Speaker 1: When Epstein was finished, they exited through the other door
• 23:49
  Speaker 1: where defendant Cecile Dijon was sitting. Given her proximity, Dijon
• 23:54
  Speaker 1: heard the sexual assault, yet she looked at Jane Doe
• 23:57
  Speaker 1: 4 straight into the eyes from her desk and did
• 23:59
  Speaker 1: nothing at that time or at any time afterwards. Given
• 24:02
  Speaker 1: her proximity, it would be impossible for her to have
• 24:05
  Speaker 1: not heard the sexual assault and yet she did nothing
• 24:08
  Speaker 1: with that information at the time. 64. In 2002, Epstein
• 24:13
  Speaker 1: took Jane Doe One to his office in Red Hook
• 24:15
  Speaker 1: on St. Thomas. When they entered the office, defendant DeJong
• 24:18
  Speaker 1: was sitting behind the desk. Epstein said hello to her
• 24:21
  Speaker 1: and immediately took Jane Doe One down the short hallway
• 24:24
  Speaker 1: into his office and immediately thrust her against the wall,
• 24:27
  Speaker 1: trapping her. Epstein aggressively pulled down Jane Doe One's pants,
• 24:31
  Speaker 1: ripped her panties to the side, and orally copulated her.
• 24:35
  Speaker 1: In that moment, Jane Doe One was petrified, shocked, and
• 24:38
  Speaker 1: didn't know what to do. The only word that was
• 24:41
  Speaker 1: spoken was a soft no, but that did not even
• 24:43
  Speaker 1: faze him, as he proceeded to rape her. Knowing there
• 24:46
  Speaker 1: were others in the office nearby made Jane Doe One
• 24:49
  Speaker 1: even more petrified, and in shock knowing others could hear
• 24:52
  Speaker 1: what was happening. Defendant DeJong was in very close proximity
• 24:56
  Speaker 1: during this sexual attack, and heard the vicious assault, yet
• 24:59
  Speaker 1: did nothing to stop it. Epstein was not fazed in
• 25:02
  Speaker 1: the slightest by DeJong's close proximity. Jane Doe One came
• 25:05
  Speaker 1: out disheveled and was seen by Dijon. Given that Dijon
• 25:09
  Speaker 1: was in close physical proximity to the attack, could hear
• 25:11
  Speaker 1: the attack, and did nothing to help Jane Doe One,
• 25:14
  Speaker 1: Jane Doe One felt she had nowhere to go. After
• 25:17
  Speaker 1: that experience, Jane Doe One knew she could not tell
• 25:20
  Speaker 1: anyone as she began to fear this network behind this enterprise.
• 25:24
  Speaker 1: Epstein continued to sexually assault her for years after On
• 25:28
  Speaker 1: the Island. 65. In approximately 2004... Even though Epstein knew
• 25:33
  Speaker 1: that Jane Doe Six did not have a passport, Epstein
• 25:37
  Speaker 1: arranged with defendants, their agents, servants, and or employees for
• 25:40
  Speaker 1: Jane Doe Six to be brought into the USVI and
• 25:43
  Speaker 1: in the USVI Island residence for the purpose of sexually
• 25:47
  Speaker 1: abusing her without question or hindrance, an arrangement that was
• 25:51
  Speaker 1: executed successfully solely because of the help provided to Epstein
• 25:54
  Speaker 1: by the defendants. Soon after Jane Doe Six arrived on
• 25:57
  Speaker 1: Epstein's private USVI Island, he sexually assaulted and raped her
• 26:02
  Speaker 1: In his bed, the next day he ordered Jane Doe
• 26:04
  Speaker 1: 6 to go with his staff to secure temporary travel
• 26:07
  Speaker 1: documents from USVI officials. 66. On one occasion, after already
• 26:13
  Speaker 1: in the USVI, Jane Doe 3's travel documents had expired.
• 26:17
  Speaker 1: Epstein ordered Jane Doe 3 to take one of his
• 26:20
  Speaker 1: boats to go to the main USVI island to a
• 26:22
  Speaker 1: specific USVI customs agent who would extend her stay in
• 26:26
  Speaker 1: the USVI. After Jane Doe 3 attempted to obtain travel
• 26:30
  Speaker 1: documents from USVI officials without Epstein present, Jane Doe 3
• 26:34
  Speaker 1: returned to his estate unsuccessful. Epstein appeared annoyed and angry
• 26:38
  Speaker 1: and escorted her down to the USVI office himself to
• 26:41
  Speaker 1: the same designated USVI official who did not provide the
• 26:44
  Speaker 1: documents requested on her earlier attempt. With Epstein present and
• 26:48
  Speaker 1: without Jane Doe saying a word to the USVI customs agent,
• 26:51
  Speaker 1: quickly provided Jane Doe 3 with the travel documents required.
• 26:54
  Speaker 1: 67 The responses and reactions by the USVI customs agents
• 26:59
  Speaker 1: indicated that USVI regularly and routinely provided Epstein with visas, passports,
• 27:05
  Speaker 1: and other travel documents to enable him to traffic his
• 27:08
  Speaker 1: victims internationally, including to the USVI. Jane Doe Six was
• 27:13
  Speaker 1: escorted by Epstein's co-conspirators to a government building on the
• 27:18
  Speaker 1: main USVI island where two USVI customs agents and or
• 27:22
  Speaker 1: government officials chatted and laughed with the two Epstein associates.
• 27:25
  Speaker 1: while Jane Doe 6 stood silent. Without once asking Jane
• 27:29
  Speaker 1: Doe 6 any questions, without Jane Doe 6 providing any
• 27:33
  Speaker 1: documentation supporting her identity or citizenship, without Jane Doe signing anything,
• 27:38
  Speaker 1: and without Jane Doe saying one word, the USVI officials
• 27:41
  Speaker 1: gave Jane Doe 6 documents authorizing her travel back into
• 27:46
  Speaker 1: the US from the USVI. 68. Epstein could not and
• 27:50
  Speaker 1: would not have sexually trafficked, abused, assaulted, and battered Jane
• 27:53
  Speaker 1: Doe 6 in the USVI without the unlawful conduct of
• 27:57
  Speaker 1: defendants and or their agents, servants, and or employees. Sixty-nine.
• 28:02
  Speaker 1: Epstein could not have sexually trafficked, abused, assaulted, and battered
• 28:05
  Speaker 1: plaintiffs and other class members in the USVI without the
• 28:08
  Speaker 1: unlawful conduct of defendants and or their agents, servants, and
• 28:12
  Speaker 1: or employees. Seventy. In this complaint, Jane Doe's 1-6 and
• 28:17
  Speaker 1: other members of the class allege defendants acted outrageously and intentionally,
• 28:22
  Speaker 1: but in addition, wherever Jane Doe's 1-6 and other members
• 28:25
  Speaker 1: of the class allege that defendants acted with actual knowledge
• 28:29
  Speaker 1: or in reckless disregard of the fact that the Epstein
• 28:32
  Speaker 1: sex trafficking venture used means of force, threats of force, fraud, coercion,
• 28:37
  Speaker 1: abuse of process, or some combination thereof to cause a
• 28:40
  Speaker 1: person to engage in commercial sex acts. Jane Doe's 1-6
• 28:44
  Speaker 1: and other members of the class also alleged that, at
• 28:47
  Speaker 1: a bare minimum, the defendant should have known that Epstein's
• 28:50
  Speaker 1: sex trafficking venture had used such means to engage in
• 28:53
  Speaker 1: illegal sex trafficking in violation of U.S. Code Section 1591-94,
• 28:59
  Speaker 1: that they had constructive knowledge of Epstein's sex trafficking. All right,
• 29:03
  Speaker 1: we're going to wrap up this episode right here, and
• 29:05
  Speaker 1: in the next episode, we're going to pick up with B,
• 29:07
  Speaker 1: the payoffs. All of the information that goes with this
• 29:10
  Speaker 1: episode can be found... in the description box. What's up
• 29:14
  Speaker 1: everyone and welcome back to the Epstein Chronicles. In this episode,
• 29:19
  Speaker 1: we're picking up where we left off with the amended
• 29:21
  Speaker 1: complaint filed by Epstein's survivors against the USVI. B. The Payoffs. 71.
• 29:30
  Speaker 1: To support and expand his sex trafficking empire, Epstein gave
• 29:33
  Speaker 1: payments and other benefits to the highest USVI government officials. 72.
• 29:38
  Speaker 1: Epstein paid hundreds of thousands of dollars to USVI government
• 29:43
  Speaker 1: entities and officials for over two decades, including paying school
• 29:47
  Speaker 1: tuition for Governor DeJong's children. Many of Epstein's payments to
• 29:50
  Speaker 1: politicians were advised and directed by the USVI's First Lady DeJong.
• 29:55
  Speaker 1: A USVI government official, and bought Epstein's loyalty and access
• 30:00
  Speaker 1: among USVI politicians. 73. Governor Kenneth Mapp, USVI's governor from
• 30:06
  Speaker 1: 2015 to 2018, asked Epstein to advise him on how
• 30:11
  Speaker 1: to increase the USVI's business investments and deal with the
• 30:14
  Speaker 1: USVI's structural fiscal imbalance. He specifically asked Epstein to spread
• 30:19
  Speaker 1: word that USVI was pushing for business investments and requested
• 30:24
  Speaker 1: Epstein's input on issuing critically needed bonds to finance USVI's operations. 74.
• 30:30
  Speaker 1: Governor Mapp also asked Epstein to assist him in developing
• 30:34
  Speaker 1: a means for Economic Development Commission, hereafter as EDC, beneficiaries
• 30:39
  Speaker 1: to repatriate their income to make USVI's EDC program more attractive.
• 30:44
  Speaker 1: And one of Epstein's lawyers drafted a proposed legislation for
• 30:47
  Speaker 1: the governor. As per the USVI's own legislation, the EDC
• 30:52
  Speaker 1: board is under the general supervision and direction of the governor.
• 30:56
  Speaker 1: Virgin Island Code 29, Section 1101B. As such, actions of
• 31:01
  Speaker 1: the EDC are done of and by the USVI government. 75.
• 31:07
  Speaker 1: On one occasion when USVI government was desperate for money,
• 31:10
  Speaker 1: USVI officials affirmatively and directly solicited Epstein's assistance. Epstein worked
• 31:15
  Speaker 1: with both a sitting and former USVI governor, on a
• 31:19
  Speaker 1: plan to secure cash by extending it a $ 50 million
• 31:22
  Speaker 1: loan collateralized by the USVI Islands. 76. First Lady de
• 31:29
  Speaker 1: Jong suggested that Epstein put Senator Celestino White on a
• 31:32
  Speaker 1: monthly retainer to obtain government loyalty and access. First Lady
• 31:36
  Speaker 1: de Jong also directed payments from Epstein's companies to political
• 31:40
  Speaker 1: action committees for the Virgin Island candidates. 77. Epstein also
• 31:45
  Speaker 1: freely loaned the DeJong family money. In 2015, former Governor
• 31:49
  Speaker 1: DeJong was arrested on charges of using $ 500, 000 of public
• 31:53
  Speaker 1: money to improve his private home. Former Governor DeJong resolved
• 31:56
  Speaker 1: the criminal case by paying a settlement of $ 380, 000 without
• 31:59
  Speaker 1: admitting wrongdoing by successfully borrowing $ 215, 000 from Epstein to pay
• 32:01
  Speaker 1: the settlement. Seventy-eight. Epstein and his colleagues loaned Stacey Plaskett $ 30, 000
• 32:11
  Speaker 1: to support her political campaign. Plaskett was the attorney for
• 32:16
  Speaker 1: the EDC when it approved the $ 300 million in tax
• 32:19
  Speaker 1: breaks to Epstein's companies and had worked for Epstein's attorney. 79.
• 32:24
  Speaker 1: By way of example only, Epstein compensated a USVI customs
• 32:29
  Speaker 1: agent and or border control worker under the guise of
• 32:32
  Speaker 1: playing Caribbean drums for him on his island. See the
• 32:36
  Speaker 1: quid pro quo. Defendants assisted Epstein in operating and expanding
• 32:40
  Speaker 1: his criminal enterprise. 80. In exchange for Epstein's payments to
• 32:44
  Speaker 1: defendants and various officials and agents within the USVI government,
• 32:49
  Speaker 1: they provided him with special treatment in order to facilitate
• 32:52
  Speaker 1: his crimes. 81. In exchange for his payoffs, Epstein received 1.
• 32:57
  Speaker 1: Influence over the very laws that were supposed to constrain him. 2.
• 33:01
  Speaker 1: Waivers of sex offender monitoring requirements. 3. $ 300 million in subsidies.
• 33:06
  Speaker 1: to the allegedly sham companies he used for sex trafficking. 4.
• 33:10
  Speaker 1: Facilitation of visas, licenses, and or ignoring requirements for same
• 33:15
  Speaker 1: and other forms of government assistance that enabled criminal conduct. 5.
• 33:20
  Speaker 1: Immunity from investigation and scrutiny. I. Epstein provides input to
• 33:25
  Speaker 1: USVI's proposed sex offender monitoring legislation and is given a
• 33:29
  Speaker 1: waiver of compliance from it. 82. In 2002, the USVI
• 33:34
  Speaker 1: First Lady solicited Epstein's input on USVI's pending sex offender
• 33:39
  Speaker 1: monitoring legislation and shared draft language from the DOJ with Epstein, writing,
• 33:44
  Speaker 1: This is the suggested language. Will it work for you?
• 33:47
  Speaker 1: Epstein responded with directions on how to loosen the restrictions. 83.
• 33:52
  Speaker 1: In particular, Epstein was concerned that the proposed bill included
• 33:56
  Speaker 1: a 21-day notice requirement which would prevent him and others
• 33:59
  Speaker 1: from coming and going as freely as he wanted. 84.
• 34:02
  Speaker 1: The First Lady responded that, as Attorney General Vincent Frazier
• 34:06
  Speaker 1: had a deadline to submit the legislation, they had to
• 34:09
  Speaker 1: develop the language that would address Epstein's concerns by Thursday
• 34:12
  Speaker 1: because the governor would be traveling for a week and
• 34:14
  Speaker 1: the Attorney General had to submit the proposed legislation during
• 34:18
  Speaker 1: that time frame. Eighty-five. Epstein and his lawyers continue to
• 34:22
  Speaker 1: stay in touch with the USVI Justice Department attorneys and
• 34:26
  Speaker 1: various senators in order to influence the text of the
• 34:29
  Speaker 1: Sex Offender Monitoring Bill. Eighty-six. When Epstein's preferred language was
• 34:34
  Speaker 1: omitted from the final bill, the First Lady assured Epstein
• 34:37
  Speaker 1: that we will work with Vincent Frazier, then Attorney General,
• 34:40
  Speaker 1: to give the discretion for status quo for you. That's
• 34:43
  Speaker 1: the least he can do. 87. With the assistance of
• 34:47
  Speaker 1: First Lady de Jong, the Attorney General, Vincent Frazier, promptly
• 34:50
  Speaker 1: provided Epstein with special treatment, a waiver of the 21-day
• 34:54
  Speaker 1: prior notice requirement for Epstein when traveling out of the
• 34:57
  Speaker 1: Virgin Islands. 88. After Epstein's attorneys complained again, the Attorney
• 35:02
  Speaker 1: General loosened it further, offering that Epstein be allowed to
• 35:06
  Speaker 1: notify the USVI Justice Department of his intention to travel
• 35:10
  Speaker 1: out of the USVI 24 hours prior to his departure. 89.
• 35:14
  Speaker 1: Epstein was thus allowed to circumvent the recently passed legislation
• 35:19
  Speaker 1: with assistance of Senator Carlton Dow, Senator Celestino White, and
• 35:23
  Speaker 1: Attorney General Vincent Frazier. 90. Had his 91-day notice requirement
• 35:28
  Speaker 1: been enforced, Epstein would not have been able to freely
• 35:31
  Speaker 1: traffic young women and girls to the USVI as he
• 35:34
  Speaker 1: did for years. 2. The USVI gave Epstein Enterprise $ 300
• 35:39
  Speaker 1: million in tax breaks. 91. For 20 years, USVI subsidized
• 35:43
  Speaker 1: the operation of Epstein's two USVI-based companies that were fronts
• 35:48
  Speaker 1: for his sex-trafficking enterprise by granting them, and by extension Epstein,
• 35:52
  Speaker 1: between 100% and 90% reductions in income taxes. 92. The
• 35:57
  Speaker 1: ultimate decision to provide such tax breaks was made by
• 36:00
  Speaker 1: the USVI governor. Plaskett was the attorney on the EDC
• 36:04
  Speaker 1: responsible for, upon information and belief, recommending that the EDC
• 36:08
  Speaker 1: provides these benefits to Epstein and his companies and enterprise. 93.
• 36:14
  Speaker 1: These tax breaks amounted to $ 300 million in direct benefits
• 36:17
  Speaker 1: to Epstein and his companies and enterprise. 3. Government officials
• 36:23
  Speaker 1: and workers gave Epstein free reign in the country. bypassing customs,
• 36:27
  Speaker 1: law enforcement, airport, and Coast Guard security, and were instructed
• 36:31
  Speaker 1: to disregard any pleas for help from the victims. 94.
• 36:36
  Speaker 1: With the help of First Lady DeJong and other government
• 36:38
  Speaker 1: officials and staff, Epstein traveled openly through USVI airports, accompanied
• 36:43
  Speaker 1: by young sex-trafficked women and girls. 95. Defendants were responsible
• 36:48
  Speaker 1: for monitoring Epstein's movements after his release from Palm Beach
• 36:52
  Speaker 1: County Jail, in 2009 for procuring a minor for prostitution
• 36:57
  Speaker 1: and felony solicitation, but admittedly took no steps to ensure
• 37:00
  Speaker 1: that he was no longer harming minors. 96. Defendant First
• 37:06
  Speaker 1: Lady de Jong was an active player in providing Epstein
• 37:08
  Speaker 1: with numerous opportunities to influence government for the benefit of
• 37:12
  Speaker 1: Epstein and his companies. Throughout their relationship, the First Lady
• 37:16
  Speaker 1: often facilitated gifts from Epstein to airport personnel and 78
• 37:20
  Speaker 1: customs employees. 97. Despite Epstein's status as a sex offender, U.S.
• 37:26
  Speaker 1: Customs officials on the USVI never examined either the passports
• 37:30
  Speaker 1: or luggage of anyone arriving on Epstein's private jet. In fact, Epstein,
• 37:34
  Speaker 1: his clients, and his victims were never mandated to enter
• 37:38
  Speaker 1: through Customs. They deplaned from the private jet before boarding
• 37:42
  Speaker 1: Epstein's helicopter or boat. 98. Upon information and belief, Epstein
• 37:47
  Speaker 1: and or his assistants, agents, and others were seized victims'
• 37:50
  Speaker 1: passports with the full knowledge and consent of defendants who
• 37:53
  Speaker 1: were directed not to assist the victims if they complained
• 37:56
  Speaker 1: of their virtual captivity. 99. Indeed, Epstein complained by email
• 38:01
  Speaker 1: to First Lady de Jong in 2010 because a U.S.
• 38:05
  Speaker 1: customs official caused him difficulty, and First Lady de Jong
• 38:08
  Speaker 1: promised that she would ensure this would not happen again
• 38:11
  Speaker 1: by calling the head of customs. 100. USVI, its officials,
• 38:16
  Speaker 1: and law enforcement never investigated Epstein, even after Florida law
• 38:20
  Speaker 1: enforcement faxed Epstein's sexual predator registration information to USVI's Department
• 38:25
  Speaker 1: of Justice officials in July of 2010, with which they
• 38:30
  Speaker 1: included a news article confirming his status as a sex offender. 101.
• 38:35
  Speaker 1: Upon information and belief, USVI officials directed law enforcement officers,
• 38:39
  Speaker 1: airport personnel, customs officials, and other government employees to extend
• 38:44
  Speaker 1: any courtesy or assistance to Epstein and as affluent customers
• 38:48
  Speaker 1: and guests, as part of their official duties. 102. Upon
• 38:52
  Speaker 1: information and belief, USVI officials, directed law enforcement officers, airport personnel,
• 38:57
  Speaker 1: customs officials, and any other government employees to disregard or
• 39:01
  Speaker 1: refuse any requests for assistance by any of Epstein's female victims,
• 39:06
  Speaker 1: such as securing a return of the passports from Epstein
• 39:09
  Speaker 1: and to report any pleas for help directly to Epstein. 4.
• 39:14
  Speaker 1: Defendants secured visas so that Epstein could transport his victims
• 39:17
  Speaker 1: into the USVI. 103. First Lady de Jong, who was
• 39:21
  Speaker 1: employed by Epstein at his office as his manager, facilitated
• 39:25
  Speaker 1: him in obtaining travel documents, including visas, to bring minor
• 39:29
  Speaker 1: women from the USVI. other countries to the USVI. First
• 39:33
  Speaker 1: Lady de Jong earned $ 200, 000 in annual salary, in addition
• 39:37
  Speaker 1: to payment of her children's private school and college tuition,
• 39:40
  Speaker 1: among other perks. 104. Upon information and belief, First Lady
• 39:44
  Speaker 1: de Jong also arranged for three young European women to
• 39:48
  Speaker 1: secure student visas to enroll at the University of the
• 39:51
  Speaker 1: Virgin Islands to attend a custom-tailored class to provide cover
• 39:55
  Speaker 1: for the virtual enslavement of these women. Epstein's quid pro
• 39:59
  Speaker 1: quo was a $ 20, 000 donation to the university through one
• 40:03
  Speaker 1: of his companies. 105. Epstein corresponded with First Lady de
• 40:07
  Speaker 1: Jong and other high-level government officials about securing visas and
• 40:12
  Speaker 1: setting up ESL classes for many of his female victims
• 40:15
  Speaker 1: in USVI. On one occasion when Ms. DeJong became aware
• 40:19
  Speaker 1: that at least one of Epstein's young female associates had
• 40:22
  Speaker 1: only a B-1 temporary business visitor visa, she worked with
• 40:26
  Speaker 1: Epstein to contrive a means for an individual to obtain
• 40:29
  Speaker 1: an I-20 through the University of the Virgin Islands. 106.
• 40:34
  Speaker 1: The First Lady also frequently assisted on immigration matters related
• 40:38
  Speaker 1: to Epstein's foreign female associates by speaking with immigration attorneys
• 40:43
  Speaker 1: on Epstein's behalf. and by coordinating with members of the
• 40:46
  Speaker 1: USVI's government for letters of support for visa applications. But
• 40:51
  Speaker 1: for defendants above described negligent and or reckless acts and
• 40:54
  Speaker 1: or omissions, plaintiff and others similarly situated would not have
• 40:58
  Speaker 1: suffered the mental and physical anguish she endures to date.
• 41:02
  Speaker 1: All right, we're going to wrap up this episode here.
• 41:04
  Speaker 1: And in the next episode, we're going to pick up
• 41:06
  Speaker 1: with five class action allegations. All of the information that
• 41:10
  Speaker 1: goes with this episode can be found in the description box.