Latest / Beyond The Horizon / Mega Edition: The Amended Epstein Survivor Lawsuit Filed Against The USVI (Part 4-7) (11/1/26)

Transcript

Mega Edition: The Amended Epstein Survivor Lawsuit Filed Against The USVI (Part 4-7) (11/1/26) · Beyond The Horizon

• 0:00
  Speaker 1: What's up everyone and welcome back to the Epstein Chronicles.
• 0:04
  Speaker 1: In this episode we're picking up where we left off
• 0:06
  Speaker 1: with the survivors amended complaint against the USVI. 5. Class
• 0:13
  Speaker 1: Action Allegations 107. Plaintiff Jane Doe 1, Jane Doe 2,
• 0:18
  Speaker 1: Jane Doe 3, Jane Doe 4, Jane Doe 5, and
• 0:21
  Speaker 1: Jane Doe 6 bring this action pursuant to federal rule
• 0:25
  Speaker 1: of civil procedure 23B3 and 23C4 on behalf of themselves
• 0:30
  Speaker 1: and the following class. All women who are sexually trafficked
• 0:33
  Speaker 1: to and through the United States Virgin Islands by Jeffrey
• 0:36
  Speaker 1: Epstein between the years of 2001 through 2019. Both dates inclusive,
• 0:42
  Speaker 1: the class period. 108. Plaintiffs reserve the right to seek
• 0:46
  Speaker 1: leave to modify this definition, including the addition of one
• 0:50
  Speaker 1: or more subclasses after having the opportunity to conduct discovery. 109.
• 0:56
  Speaker 1: Numerosity The class consists of dozens of women, making joinder
• 1:00
  Speaker 1: impracticable in satisfaction of FedR's Civ P-23A1. The exact size
• 1:06
  Speaker 1: of the class and the identities of the individual class
• 1:08
  Speaker 1: members are ascertainable through records maintained by the Epstein estate
• 1:12
  Speaker 1: executors and the defendants, including but not limited to defendants
• 1:17
  Speaker 1: and other records related to Epstein and his sex trafficking
• 1:20
  Speaker 1: to and through the United States Virgin Islands. 110. Typicality.
• 1:25
  Speaker 1: Plaintiffs' claims are typical of the claims of the other
• 1:28
  Speaker 1: class members that they seek to represent. The claims of
• 1:31
  Speaker 1: plaintiffs and other class members are based on the same
• 1:33
  Speaker 1: legal theories and arise from the same unlawful pattern and
• 1:37
  Speaker 1: practice of defendants' participation in and funding of Epstein's sex
• 1:41
  Speaker 1: abuse and Epstein's sex trafficking venture as set forth above
• 1:45
  Speaker 1: and otherwise discovered. 111. Commonality. There are many questions of
• 1:50
  Speaker 1: law and fact common to the claims of plaintiffs and
• 1:52
  Speaker 1: other class members, and those questions predominant over any questions
• 1:57
  Speaker 1: that may affect only individual class members, within the meaning
• 2:00
  Speaker 1: of FedR Civ P-23, A-2, and B-3. Class treatment of
• 2:06
  Speaker 1: common issues under FedR Civ P-23-C-4 will materially advance the litigation. 112.
• 2:12
  Speaker 1: Common questions of fact and law affecting class members include,
• 2:16
  Speaker 1: but are not limited to, the following. A. Whether the
• 2:20
  Speaker 1: Epstein sex trafficking venture caused its victims to engage in
• 2:23
  Speaker 1: commercial sex acts in violation of Trafficking Victims Protection Act, U.S.
• 2:28
  Speaker 1: Code 18, Section 1591, A and 1. B. Whether the
• 2:32
  Speaker 1: Epstein sex trafficking venture recruited, enticed, solicited, harbored, provided, obtained,
• 2:36
  Speaker 1: and transported victims in ways that were in or affecting
• 2:40
  Speaker 1: interstate or foreign commerce. C. Whether Epstein and his co-conspirators
• 2:45
  Speaker 1: used means of force, fraud, coercion, and abuse of the
• 2:49
  Speaker 1: legal process or a combination of such means to sexually
• 2:52
  Speaker 1: abuse the victims and to cause victims to engage in
• 2:55
  Speaker 1: commercial sex acts. D. Whether defendants knowingly assisted, facilitated, and
• 3:00
  Speaker 1: supported the Epstein sex trafficking venture pattern and practice of
• 3:03
  Speaker 1: coercively forcing victims to engage in commercial sex acts. E.
• 3:08
  Speaker 1: Whether defendants benefited financially or by receiving things of value
• 3:12
  Speaker 1: from their participation in a venture which is engaged in
• 3:15
  Speaker 1: sex trafficking in violation of TVPA U.S. Code 18, Section 1591,
• 3:21
  Speaker 1: A and 1. F. Whether defendants knew or should have
• 3:24
  Speaker 1: known that the Epstein sex trafficking venture had engaged in
• 3:27
  Speaker 1: violations of the TVPA U.S. Code 18, Section 1591, A
• 3:32
  Speaker 1: and G. Whether defendants committed... Negligent acts are omissions that
• 3:36
  Speaker 1: facilitated sexual abuse, which would constitute a sexual offense as
• 3:40
  Speaker 1: defined in Article 130 of the penal law committed against
• 3:44
  Speaker 1: such persons who were 18 years of age or older. 113.
• 3:49
  Speaker 1: Absent a class action, most of the class members would
• 3:51
  Speaker 1: find the cost of litigating their claims to be cost
• 3:54
  Speaker 1: prohibitive and will have no effective remedy. The class treatment
• 3:57
  Speaker 1: of common questions of law and fact is also superior
• 4:01
  Speaker 1: to multiple individual actions or piecemeal litigation in that it
• 4:05
  Speaker 1: conserves the resources of the courts and the litigants and
• 4:09
  Speaker 1: promotes consistency and efficiency of adjudication. 114. Adequacy The Jane
• 4:15
  Speaker 1: Doe plaintiffs will fairly and adequately represent and protect the
• 4:19
  Speaker 1: interests of the other class members she seeks to represent.
• 4:22
  Speaker 1: The Jane Doe plaintiffs have retained counsel with substantial experience
• 4:26
  Speaker 1: in prosecuting complex litigation and large-scale high-profile sexual abuse-related litigation.
• 4:32
  Speaker 1: Plaintiffs and their counsel are are committed to vigorously prosecuting
• 4:36
  Speaker 1: this action on behalf of other class members and have
• 4:39
  Speaker 1: financial resources to do so. Neither plaintiffs nor their counsel
• 4:43
  Speaker 1: have any interest adverse to those of the other class members. 115.
• 4:47
  Speaker 1: This action has been brought and may properly be maintained
• 4:51
  Speaker 1: as a class action against defendants pursuant to Rule 23
• 4:55
  Speaker 1: of the Federal Rules of Civil Procedure because there is
• 4:58
  Speaker 1: a well-defined community of interest in the litigation, and the
• 5:01
  Speaker 1: proposed class is easily ascertainable from the defendant's records. 116. Superiority.
• 5:08
  Speaker 1: A class action is superior to all other available methods
• 5:11
  Speaker 1: for the fair and efficient adjudication of this controversy because a.
• 5:16
  Speaker 1: Joinder of all class members is impracticable. b. The prosecution
• 5:21
  Speaker 1: of individual remedies by members of the class will tend
• 5:24
  Speaker 1: to establish inconsistent standards of conduct for defendants, and result
• 5:29
  Speaker 1: in the impairment of the class member's rights and disposition
• 5:32
  Speaker 1: of their interests through actions to which they were not parties. C.
• 5:36
  Speaker 1: Class action treatment will permit a larger number of similarly
• 5:40
  Speaker 1: situated persons to prosecute their common claims in a single
• 5:43
  Speaker 1: forum simultaneously, efficiently, and without the unnecessary duplication of effort
• 5:49
  Speaker 1: and expense that numerous individual actions would engender. D. Absent
• 5:53
  Speaker 1: a class action, class members will continue to suffer losses
• 5:56
  Speaker 1: and be aggrieved and defendants will continue to violate New
• 5:59
  Speaker 1: York and federal law without remedy. E. Class treatment of
• 6:03
  Speaker 1: this action will cause an orderly and expeditious administration of
• 6:07
  Speaker 1: class claims, economies of time, effort, and expense will be fostered,
• 6:11
  Speaker 1: and uniformity of decisions will be ensured. F. Plaintiff and
• 6:16
  Speaker 1: her counsel are unaware of any class action brought against
• 6:19
  Speaker 1: any defendant for the violations alleged in this action. G.
• 6:23
  Speaker 1: The forum is desirable because the defendants conducted the subject
• 6:27
  Speaker 1: business with Jeffrey Epstein in this district, and class members
• 6:31
  Speaker 1: were consequently trafficked in this district, and h. This action
• 6:35
  Speaker 1: presents no difficulty that would impede its management by the
• 6:38
  Speaker 1: court as a class action. 6. Causes of Action As
• 6:44
  Speaker 1: for the first cause of action as to participation in
• 6:47
  Speaker 1: a sex trafficking venture in violation of Trafficking Victims Protection
• 6:51
  Speaker 1: Act under U.S. Code 18, Section 1591, A2-1595D. As to
• 6:58
  Speaker 1: all defendants. 117. Plaintiffs incorporate the foregoing paragraphs herein as
• 7:03
  Speaker 1: if set forth at length. 118. Defendants knowingly and intentionally
• 7:08
  Speaker 1: through various means participated in, perpetrated, assisted, supported, facilitated a
• 7:14
  Speaker 1: sex trafficking venture that was in and affecting interstate and
• 7:17
  Speaker 1: foreign commerce, together and with others in violation of U.S.
• 7:21
  Speaker 1: Code 18 Section 1591 A and 1. 119. Defendants knowingly
• 7:27
  Speaker 1: benefited from their participation in Epstein's enterprise. 120. Defendants knowingly
• 7:33
  Speaker 1: and intentionally participated in an Epstein sex trafficking venture that
• 7:36
  Speaker 1: was in and affecting interstate and foreign commerce together and
• 7:40
  Speaker 1: with others in violation of U.S. Code 18, Section 1591,
• 7:45
  Speaker 1: A and 1. 121. Among other things, defendants knowingly and
• 7:49
  Speaker 1: intentionally through various means recruited, enticed, provided, facilitated, obtained, advertised,
• 7:55
  Speaker 1: and solicited by various means plaintiffs, knowing that Epstein would
• 7:59
  Speaker 1: use means of force, threats of force, fraud, coercion, and
• 8:03
  Speaker 1: a combination of such means to cause plaintiffs to engage
• 8:06
  Speaker 1: in commercial sex acts. 122. Defendants and their officers and
• 8:11
  Speaker 1: employees had actual knowledge that they were perpetrating and facilitating
• 8:15
  Speaker 1: Epstein sexual abuse and sex trafficking conspiracy to recruit, solicit, entice, coerce, harbor, transport, facilitate, obtain,
• 8:23
  Speaker 1: and provide plaintiffs into commercial sex acts through the means
• 8:26
  Speaker 1: of force, threats of force, fraud, abuse of process, and coercion. 123.
• 8:32
  Speaker 1: Despite such knowledge, defendants intentionally accepted payment for, facilitated, perpetrated,
• 8:38
  Speaker 1: and participated in Epstein's violations of U.S. Code 18, Section
• 8:43
  Speaker 1: 1591a and 1, which defendants knew and were in reckless
• 8:46
  Speaker 1: disregard of the fact that Epstein would coerce, defraud, and
• 8:49
  Speaker 1: force plaintiffs as well as other young women, to engage
• 8:53
  Speaker 1: in commercial sex acts. 124. As part of perpetrating TVPA violations,
• 8:59
  Speaker 1: defendants concealed their extensive involvement and efforts in furtherance of
• 9:03
  Speaker 1: Epstein's sex trafficking ventures, Epstein's, and his associates. 125. Defendants'
• 9:09
  Speaker 1: conduct was committed knowingly and in reckless disregard of the
• 9:12
  Speaker 1: facts that Epstein would use said governmental support provided by
• 9:16
  Speaker 1: defendants as a means of defrauding, forcing, and coercing sex
• 9:20
  Speaker 1: acts from plaintiffs, defendant's conduct was outrageous and intentional. 126.
• 9:26
  Speaker 1: Defendant's intentional or negligent conduct has caused plaintiff and many
• 9:30
  Speaker 1: other young women serious harm including, without limitation, physical, psychological, emotional, financial,
• 9:37
  Speaker 1: and reputational harm. 127. Defendants also should have known that
• 9:43
  Speaker 1: they were participating in and facilitating a venture that had
• 9:46
  Speaker 1: engaged In coercive sex trafficking, in violation of U.S. Code 18,
• 9:51
  Speaker 1: Section 1591A1. 128. In exchange for facilitating and covering up
• 9:58
  Speaker 1: Epstein's commercial sex trafficking. defendants receive financial benefits therefrom. 129.
• 10:04
  Speaker 1: Facilitating and covering up Epstein's sexual misconduct was a means
• 10:08
  Speaker 1: of ensuring access to wealth and influence. 130. Defendants knowing
• 10:13
  Speaker 1: an intentional conduct has caused Jane Doe's 1 through 6,
• 10:17
  Speaker 1: and other members of the class serious harm, including without limitation, physical, psychological, emotional,
• 10:23
  Speaker 1: and reputational harm. 131. Defendants knowing an intentional conduct has
• 10:29
  Speaker 1: caused Jane Doe's 1-6 and other members of the class
• 10:32
  Speaker 1: harm that is sufficiently serious under all surrounding circumstances to
• 10:37
  Speaker 1: compel a reasonable person of the same background and in
• 10:40
  Speaker 1: the same circumstances to to perform or to continue performing
• 10:43
  Speaker 1: commercial sexual activity in order to avoid incurring that harm. 132.
• 10:48
  Speaker 1: Defendants' notorious conduct in violating the TVPA was outrageous and
• 10:53
  Speaker 1: intentional because it was in deliberate furtherance of a widespread
• 10:57
  Speaker 1: and dangerous criminal sex trafficking organization. Defendants' tortious conduct also
• 11:02
  Speaker 1: evinced a high degree of moral turptitude and demonstrated such
• 11:06
  Speaker 1: wanton dishonesty as to imply a criminal indifference to civil obligations.
• 11:11
  Speaker 1: Defendant's tortious conduct was directed specifically at Jane Doe's 1-6
• 11:16
  Speaker 1: and other members of the class who were victims of
• 11:18
  Speaker 1: Epstein's sexual abuse and sex trafficking organization. 133. Defendant's outrageous
• 11:24
  Speaker 1: and intentional conduct in this case is part of a
• 11:27
  Speaker 1: pattern and practice of defendants to profit from Epstein's sex
• 11:31
  Speaker 1: trafficking enterprise by gaining access to money and influential people
• 11:35
  Speaker 1: from around the world. 134. By virtue of its knowing
• 11:39
  Speaker 1: and intentional violations of U.S. Code 18, Section 1591, A
• 11:44
  Speaker 1: and 1, 1595, defendants are liable to plaintiffs for the
• 11:48
  Speaker 1: damages that they sustained and reasonable attorney fees by virtue
• 11:52
  Speaker 1: of these international and outrageous violations of U.S. Code 18,
• 11:57
  Speaker 1: Section 1591, A and 1, and 1595. 135. By virtue
• 12:04
  Speaker 1: of these intentional and outrageous violations of U.S. Code 18,
• 12:07
  Speaker 1: Section 1591, A and 2, 1595, defendants are liable to
• 12:13
  Speaker 1: Jane Doe 1 through 6 and other members of the
• 12:15
  Speaker 1: class for punitive damages. 136. The amount of damages sought
• 12:20
  Speaker 1: exceeds the jurisdiction of all lower courts which would otherwise
• 12:24
  Speaker 1: have jurisdiction. 137. This action falls within exceptions to Article
• 12:30
  Speaker 1: 16 of the CPLR. All right, we're going to wrap
• 12:32
  Speaker 1: up this episode here. And in the next episode, we're
• 12:35
  Speaker 1: going to pick up with as in for a second
• 12:37
  Speaker 1: cause of action as to aiding, abetting, and inducing a
• 12:40
  Speaker 1: sex trafficking venture in violation of the Trafficking Victims Protection
• 12:44
  Speaker 1: Act under U.S. Code 18, Section 2, 1591, A1 and A2, 1595.
• 12:52
  Speaker 1: All of the information that goes with this episode can
• 12:55
  Speaker 1: be found in the description box. What's up, everyone? And
• 12:58
  Speaker 1: welcome back to the Epstein Chronicles. In this episode, we're
• 13:02
  Speaker 1: picking up where we left off with the survivor's amended
• 13:06
  Speaker 1: complaint against the USVI. As in for a second cause
• 13:10
  Speaker 1: of action as to aiding, abetting, and inducing a sex
• 13:13
  Speaker 1: trafficking venture in violation of the Trafficking Victims Protection Act
• 13:17
  Speaker 1: under U.S. Code 18, Section 2, 1591, A1, N2, and 1595. 138.
• 13:25
  Speaker 1: Plaintiffs incorporate the foregoing paragraphs herein as if set forth
• 13:29
  Speaker 1: at length. 139. Defendants and their officers, agents, and employees aided, abetted,
• 13:35
  Speaker 1: and induced Epstein's sex trafficking venture that was in and
• 13:38
  Speaker 1: affecting interstate and foreign commerce together and with others in
• 13:41
  Speaker 1: violation of U.S. Code 18, Section 2, 1591, A1 and A2.
• 13:45
  Speaker 1: Under U.S. Code 18, Section 2, defendants are punishable as
• 13:47
  Speaker 1: a principal under U.S. Code 18, Section 1591, A1 and A2.
• 13:57
  Speaker 1: and thereby committed and perpetrated violations of Chapter 77, Title 18, U.S. Code,
• 14:03
  Speaker 1: when it aided, abetted, procured, and induced Epstein's sex trafficking
• 14:07
  Speaker 1: venture and sex trafficking of plaintiffs, as well as many
• 14:10
  Speaker 1: other young women. 141. Under U.S. Code 18, Section 2,
• 14:15
  Speaker 1: defendants committed and perpetrated crimes and violation of U.S. Code 18,
• 14:19
  Speaker 1: Section 1591, A and 1, and A and 2, by aiding, abetting,
• 14:23
  Speaker 1: and inducing Epstein and his conspirators' sex trafficking venture, and
• 14:27
  Speaker 1: sex trafficking of plaintiffs, as well as many other young women.
• 14:31
  Speaker 1: As a consequence, plaintiffs, as well as many other young women,
• 14:34
  Speaker 1: are victims of defendants criminally aiding, abetting, and inducing Epstein's
• 14:39
  Speaker 1: violations of U.S. Code 18, Section 1591, A and 1,
• 14:44
  Speaker 1: and A and 2. These actions were in and affecting
• 14:47
  Speaker 1: interstate and foreign commerce. 142. The crimes the defendants aided
• 14:52
  Speaker 1: and abetted are 1. Epstein's perpetrating of coercive sex trafficking 2.
• 14:56
  Speaker 1: in violation of U.S. Code 18, Section 1591a and 1,
• 15:01
  Speaker 1: and 2, Epstein's co-conspirators knowingly benefiting from coercive sex trafficking
• 15:06
  Speaker 1: in violation of U.S. Code 18, Section 1591a and 2.
• 15:11
  Speaker 1: These crimes were in and affecting interstate and foreign commerce. 143.
• 15:16
  Speaker 1: Defendants benefited financially and received things of value from their
• 15:20
  Speaker 1: participation in the Epstein sex trafficking venture, including payments and
• 15:24
  Speaker 1: other compensation from Epstein. 144. Acting through its officers and employees,
• 15:30
  Speaker 1: the USVI itself perpetrated violations of Chapter 77, Title 18, U.S. Code,
• 15:36
  Speaker 1: including U.S. Code 18, Section 1591, A & 1, and
• 15:41
  Speaker 1: A & 2, by aiding, abetting, and inducing a sex
• 15:44
  Speaker 1: trafficking venture and the sex trafficking of plaintiffs as well
• 15:47
  Speaker 1: as many other young women. Defendant directly violated Chapter 77
• 15:52
  Speaker 1: by committing and perpetrating these violations. 145. Among other things,
• 15:56
  Speaker 1: defendants aided, abetted, facilitated, and induced Epstein's sex trafficking venture
• 16:01
  Speaker 1: and sex trafficking of plaintiffs, as well as many other
• 16:04
  Speaker 1: young women, knowing that Epstein would use means of force,
• 16:07
  Speaker 1: threats of force, fraud, coercion, and a combination of such
• 16:10
  Speaker 1: means to cause plaintiffs, as well as many other young women,
• 16:14
  Speaker 1: some of whom were under the age of 18, to
• 16:16
  Speaker 1: engage in commercial sex acts. 146. By aiding, abetting, and
• 16:20
  Speaker 1: inducing Epstein's sex trafficking venture and sex trafficking of plaintiffs,
• 16:24
  Speaker 1: as well as many other young women, defendants knowingly benefited
• 16:28
  Speaker 1: both financially and by receiving things of value from participating
• 16:32
  Speaker 1: in Epstein's sex trafficking venture. 147. Defendants and their officers
• 16:37
  Speaker 1: and employees had actual knowledge that they were aiding, abetting,
• 16:40
  Speaker 1: and inducing Epstein's sexual abuse and sex trafficking conspiracy to recruit, solicit, entice, coerce, harbor, transport, obtain,
• 16:48
  Speaker 1: and provide plaintiffs. as well as many other young women,
• 16:52
  Speaker 1: into commercial sex acts through the means of force, threats
• 16:55
  Speaker 1: of force, fraud, abuse of process, and coercion. 148. Defendants
• 17:00
  Speaker 1: knew and should have known that Epstein had engaged in
• 17:03
  Speaker 1: acts in violation of the TVPA. 149. Despite such knowledge,
• 17:08
  Speaker 1: defendants intentionally aided, abetted, procured, and induced Epstein and his
• 17:12
  Speaker 1: co-conspirators violations of U.S. Code 18, Section 1591, A & 1,
• 17:16
  Speaker 1: and A & 2. which constituted perpetrating violations of those
• 17:21
  Speaker 1: laws under U.S. Code 18, Section 2. Defendants knew and
• 17:26
  Speaker 1: acted in reckless disregard of the fact that Epstein would coerce, defraud,
• 17:31
  Speaker 1: and force plaintiffs, as well as many other young women,
• 17:34
  Speaker 1: to engage in commercial sex acts. 150. Defendants' affirmative conduct
• 17:38
  Speaker 1: of aiding, abetting, facilitating, procuring, and inducing Epstein and his
• 17:43
  Speaker 1: co-conspirators' violations was committed knowingly and in reckless disregard of
• 17:47
  Speaker 1: the fact that that Epstein would use governmental support provided
• 17:51
  Speaker 1: by defendants as a means of defrauding, forcing, and coercing
• 17:54
  Speaker 1: sex acts from plaintiffs, as well as many other young women.
• 17:58
  Speaker 1: Defendants' conduct was outrageous and intentional. 151. Defendants knowing and
• 18:03
  Speaker 1: intentional conduct of aiding, abetting, and inducing Epstein's violations has
• 18:08
  Speaker 1: caused plaintiffs, as well as many other young women, serious harm,
• 18:11
  Speaker 1: including without limitation, physical, psychological, emotional, financial, and reputational harm. 152.
• 18:18
  Speaker 1: Defendants' knowing and intentional conduct of aiding, abetting, and inducing
• 18:23
  Speaker 1: Epstein's violations has caused plaintiffs, as well as many other
• 18:26
  Speaker 1: young women, harm that is sufficiently serious under all the
• 18:30
  Speaker 1: surrounding circumstances to compel a reasonable person of the same
• 18:33
  Speaker 1: background and in the same circumstances to perform or to
• 18:37
  Speaker 1: continue performing commercial sexual activity against in order to avoid
• 18:41
  Speaker 1: incurring that harm. 153. 154. 155. Defendant's conduct in perpetrating
• 19:11
  Speaker 1: TVPA violations was outrageous and intentional because it was in
• 19:16
  Speaker 1: deliberate furtherance of a widespread and dangerous criminal sex trafficking organization, 156,
• 19:22
  Speaker 1: by virtue of its knowing and intentional violations of U.S.
• 19:25
  Speaker 1: Code 18, Section 1591A1, 1591A2, and 1595. Defendants are liable
• 19:33
  Speaker 1: to plaintiffs for the damages that they sustained and reasonable
• 19:37
  Speaker 1: attorney fees. By virtue of these intentional and outrageous violations
• 19:41
  Speaker 1: of U.S. Code 18, Section 1591A1, 1591A2, and 1595. 157. Defendants
• 19:51
  Speaker 1: are liable to plaintiffs for punitive damages for their aforementioned conduct. 158.
• 19:56
  Speaker 1: The amount of damages sought exceeds the jurisdiction of all
• 20:00
  Speaker 1: lower courts which would otherwise have jurisdiction. 159. This action
• 20:05
  Speaker 1: falls within exceptions to Article 16 of the CPLR. As
• 20:09
  Speaker 1: for the third cause of action, as to conspiracy to
• 20:13
  Speaker 1: commit violations of the Trafficking Victim Protection Act under 18 U.S.
• 20:17
  Speaker 1: Code Section 1594, C. 1591, and 1595. 160. Plaintiffs incorporate
• 20:25
  Speaker 1: the foregoing paragraphs as set forth herein at length. 161.
• 20:29
  Speaker 1: Defendants intentionally conspired with others, including Epstein and his other co-conspirators.
• 20:34
  Speaker 1: by agreement and understanding to violate U.S. Code 18, Section 1591,
• 20:40
  Speaker 1: A and 1 and A and 2, and 1591D, and
• 20:44
  Speaker 1: to further Epstein's sex trafficking venture to coerce commercial sex
• 20:47
  Speaker 1: acts from plaintiffs and other young victims, all in violation
• 20:51
  Speaker 1: of U.S. Code 18, Section 1594C. Defendants and their officers
• 20:55
  Speaker 1: and employees directly conspired with Epstein himself to further the
• 20:59
  Speaker 1: sex trafficking venture. 162. Defendants' conspiracy to violate U.S. Code 18,
• 21:05
  Speaker 1: Section 1591, A and 1, and A and 2 was
• 21:08
  Speaker 1: forbidden by U.S. Code 18, Section 1594C, and defendants thereby
• 21:13
  Speaker 1: violated Chapter 77, Title 18. 163. Defendants' conspiracy directly, proximately,
• 21:21
  Speaker 1: and foreseeably harm plaintiffs and other young victims by directly
• 21:25
  Speaker 1: leading to their forcibly being caused to engage in commercial
• 21:28
  Speaker 1: sex acts and in other ways. Defendant's conspiracy victimized plaintiffs
• 21:33
  Speaker 1: and other young victims. 164. Defendant's conspiracy to violate U.S.
• 21:38
  Speaker 1: Code 18, Section 1591-D was forbidden by U.S. Code 18,
• 21:42
  Speaker 1: Section 1594-C, and defendants thereby violated Chapter 77, Title 18. 165.
• 21:50
  Speaker 1: Defendant's conspiracy directly, proximately, and foreseeably harmed plaintiffs and other
• 21:54
  Speaker 1: young victims by directly leading to their forcibly being caused
• 21:58
  Speaker 1: to engage in in commercial sex acts, and in other ways. 166.
• 22:03
  Speaker 1: Defendants conspiracy victimized plaintiffs and other young victims. 167. Defendants
• 22:09
  Speaker 1: conspired with Epstein and his other co-conspirators to further the
• 22:12
  Speaker 1: Epstein sex trafficking venture and with the purpose of facilitating
• 22:16
  Speaker 1: Epstein's illegal sex trafficking. Defendants had actual and or constructive
• 22:20
  Speaker 1: knowledge of Epstein's sex trafficking venture. Defendants acted with the
• 22:24
  Speaker 1: specific intent to violate U.S. Code 18, Section 1591A1 and A2,
• 22:30
  Speaker 1: that is, with consciousness of the nature of Epstein's sex
• 22:33
  Speaker 1: trafficking venture and with the specific intent to further the venture.
• 22:37
  Speaker 1: Defendants and Epstein had a meeting of the minds as
• 22:40
  Speaker 1: to the essential nature of the plan. 168. Defendant's conspiracy
• 22:44
  Speaker 1: with Epstein was part of its participation in his sex
• 22:48
  Speaker 1: trafficking venture. Without defendant's agreement to facilitate the venture, Epstein
• 22:52
  Speaker 1: would not have been in a position to move forward
• 22:55
  Speaker 1: with his sex trafficking venture on the USVI and to
• 22:58
  Speaker 1: recruit and entice victims of the venture there and transport
• 23:01
  Speaker 1: them elsewhere to engage in commercial sex acts. 169. Defendants
• 23:06
  Speaker 1: also conspired with Epstein and his other co-conspirators to obstruct,
• 23:11
  Speaker 1: attempt to obstruct, to interfere with, and to prevent the
• 23:14
  Speaker 1: enforcement of the TVPA, violating U.S. Code 18, Section 1591D.
• 23:20
  Speaker 1: The conspiracy included an agreement to keep Epstein's sex trafficking
• 23:23
  Speaker 1: venture secret, or at least concealed, to the greatest extent possible. 170.
• 23:29
  Speaker 1: Defendants intentionally committed overt acts in furtherance of the conspiracy
• 23:32
  Speaker 1: agreement and understanding to violate U.S. Code 18 Section 1591A
• 23:38
  Speaker 1: by knowingly playing an active role in assisting, supporting, and
• 23:41
  Speaker 1: facilitating the recruiting, enticing, coercing, harboring, transporting, and inducing, and
• 23:47
  Speaker 1: forcibly causing plaintiffs and other young victims to engage in
• 23:50
  Speaker 1: commercial sex acts through providing financial and other support for
• 23:54
  Speaker 1: the Epstein sex trafficking venture. A number of those acts
• 23:58
  Speaker 1: were committed by First Lady de Jong, acting within the
• 24:01
  Speaker 1: actual and apparent scope of her office to further USVI
• 24:05
  Speaker 1: and Epstein's interests. Alright, we're going to wrap up right here.
• 24:08
  Speaker 1: And in the next episode dealing with the topic, we're
• 24:10
  Speaker 1: going to pick up with 171, among the many overt
• 24:14
  Speaker 1: acts intentionally committed. All of the information that goes with
• 24:18
  Speaker 1: this episode can be found in the description box. What's
• 24:22
  Speaker 1: up everyone and welcome back to the Epstein Chronicles. In
• 24:26
  Speaker 1: this episode, we're getting right back to it, and we're
• 24:28
  Speaker 1: going to pick up where we left off with the
• 24:30
  Speaker 1: survivor's amended complaint filed against the USVI. 170. Defendants intentionally
• 24:37
  Speaker 1: committed overt acts in furtherance of the conspiracy agreement and
• 24:41
  Speaker 1: understanding to violate U.S. Code 18, Section 1591A by knowingly
• 24:46
  Speaker 1: playing an active role in assisting, supporting, and facilitating the recruiting, enticing, coercing, harboring, transporting,
• 24:54
  Speaker 1: and inducing of and forcibly causing plaintiffs and other young
• 24:58
  Speaker 1: victims to engage in commercial sex acts through providing financial
• 25:02
  Speaker 1: and other support for Epstein's sex trafficking venture. A number
• 25:06
  Speaker 1: of those acts were committed by First Lady Cecile de Jong,
• 25:09
  Speaker 1: acting within the actual and apparent scope of her office
• 25:12
  Speaker 1: to further USVI and Epstein's interests. 171 Among the many
• 25:18
  Speaker 1: overt acts intentionally committed by defendants and furtherance of the
• 25:21
  Speaker 1: sex trafficking venture, were creating and maintaining a special and
• 25:25
  Speaker 1: unusual relationship between defendants and Epstein within the USVI designed
• 25:30
  Speaker 1: to facilitate Epstein's unfettered sex trafficking on the islands. 172.
• 25:36
  Speaker 1: Defendants' actions in furtherance of Epstein's conspiracy were intertwined with
• 25:40
  Speaker 1: Epstein's sex trafficking venture as providing a place, protection, favorable laws,
• 25:45
  Speaker 1: and beneficial treatment for the sex trafficking venture were essential
• 25:49
  Speaker 1: tools for Epstein to commit coercive commercial sex acts. 173.
• 25:54
  Speaker 1: It was part of the conspiracy that defendants would financially
• 25:57
  Speaker 1: benefit from providing financial support for the Epstein sex trafficking venture.
• 26:02
  Speaker 1: Defendants did financially benefit from its participation in the venture,
• 26:06
  Speaker 1: including receiving valuable donations and business opportunities from Epstein. 174.
• 26:13
  Speaker 1: Defendants' participation in furthering Epstein's sex trafficking venture was intentional
• 26:17
  Speaker 1: and willful, and therefore defendants intentionally and willfully caused Epstein's
• 26:21
  Speaker 1: commission to defendant knew and acted in reckless disregard of
• 26:50
  Speaker 1: the fact and should have known that its conspiracy would
• 26:53
  Speaker 1: directly and proximately lead to unlawful coercive commercial sex acts
• 26:58
  Speaker 1: by Epstein with young women and girls, including plaintiffs, as
• 27:02
  Speaker 1: well as many other young women. 176. The conspiracy that
• 27:06
  Speaker 1: defendants joined had specific knowledge that plaintiffs, as well as
• 27:10
  Speaker 1: many other young women, were being coercively sex trafficked by Epstein.
• 27:14
  Speaker 1: The conspiracy's knowledge extended to meeting and knowing Epstein's victims,
• 27:18
  Speaker 1: because Epstein and his co-conspirators met some of the victims,
• 27:21
  Speaker 1: including Jane Doe's 1-6, specifically First Lady de Jong, met
• 27:26
  Speaker 1: and knew many of Epstein's victims. 177. Defendants conspired to
• 27:31
  Speaker 1: violate U.S. Code 18, Section 1591-A, with Epstein and through
• 27:35
  Speaker 1: its affirmative acts, and substantial support to Epstein committed, perpetrated,
• 27:40
  Speaker 1: and directly and proximately cause plaintiffs, as well as many
• 27:44
  Speaker 1: other young women to engage in commercial sex acts through
• 27:47
  Speaker 1: means of force, threats of force, fraud, coercion, and a
• 27:50
  Speaker 1: combination of such means. 178. Defendants benefited financially from conspiring
• 27:56
  Speaker 1: to participate in Epstein's sex trafficking venture, which defendants knew
• 28:00
  Speaker 1: and should have known that had engaged in coercive sex
• 28:03
  Speaker 1: trafficking in violation of U.S. Code 18, Section 1591, A
• 28:07
  Speaker 1: and 1, and A and 2. as well as obstruction
• 28:11
  Speaker 1: of the enforcement of the TVPA in violation of U.S.
• 28:15
  Speaker 1: Code 18, Section 1591D-179. Defendant's conspiracy has caused plaintiffs, as
• 28:21
  Speaker 1: well as many other young women, serious harm, including, without limitation, physical, psychological, financial,
• 28:28
  Speaker 1: and reputational harm. That harm was directly and proximately caused
• 28:32
  Speaker 1: by the conspiracy, and the harm resulting from conspiracy was foreseeable. 180.
• 28:38
  Speaker 1: Defendants' conspiracy has caused plaintiffs harm that is sufficiently serious
• 28:43
  Speaker 1: under all the surrounding circumstances to compel a reasonable person
• 28:46
  Speaker 1: of the same background and in the same circumstances to
• 28:49
  Speaker 1: perform or to continue performing commercial sexual activity in order
• 28:53
  Speaker 1: to avoid incurring that harm. 181. By virtue of these
• 28:57
  Speaker 1: violations of U.S. Code 18, Section 1594C, 1595, defendants are
• 29:03
  Speaker 1: liable to plaintiffs for the damage that they sustained and
• 29:07
  Speaker 1: reasonable attorney fees under U.S. Code 18, Section 1595.451. 182.
• 29:14
  Speaker 1: Defendants' tortious conduct in conspiring to violate the TVPA was
• 29:19
  Speaker 1: outrageous and intentional because it was deliberate in furtherance of
• 29:23
  Speaker 1: a widespread and dangerous criminal sex trafficking organization. Defendants' tortious
• 29:28
  Speaker 1: conspiracy also evinced a high degree of moral turpitude and
• 29:32
  Speaker 1: demonstrated such wanton dishonesty as to imply a criminal indifference
• 29:36
  Speaker 1: to civil obligations. defendants tortious conspiracy. was directed specifically at
• 29:41
  Speaker 1: Jane Does 1-5 and other members of the class who
• 29:44
  Speaker 1: were the victims of Epstein's sex trafficking organization. 183. By
• 29:49
  Speaker 1: virtue of defendants' conspiracy to violate U.S. Code 18, Section 1594C, 1595,
• 29:56
  Speaker 1: defendants are liable to plaintiffs for punitive damages Under U.S.
• 30:00
  Speaker 1: Code 18, Section 1595. 184. The amount of damages sought
• 30:05
  Speaker 1: exceeds the jurisdiction of all lower courts which would otherwise
• 30:09
  Speaker 1: have jurisdiction. 185. This action falls within exceptions of Article
• 30:15
  Speaker 1: 16 of the CPLR. As and for the fourth cause
• 30:19
  Speaker 1: of action as to negligence to all defendants. 186. Plaintiffs
• 30:24
  Speaker 1: incorporate the foregoing paragraphs and set forth herein at length. 187.
• 30:29
  Speaker 1: Plaintiff Jane Doe 1 was sexually abused, forced to engage
• 30:32
  Speaker 1: in commercial sex acts, and trafficked by Epstein and his
• 30:35
  Speaker 1: co-conspirators from 2001 to 2019 in New York, Florida, USVI,
• 30:41
  Speaker 1: and around the world. 188. Plaintiff Jane Doe 2 was
• 30:44
  Speaker 1: sexually abused, forced to engage in commercial sex acts, and
• 30:48
  Speaker 1: trafficked by Epstein and his co-conspirators from 2015 to 2019
• 30:50
  Speaker 1: in New York, Florida, USVI, and around the world. 189.
• 30:57
  Speaker 1: Plaintiff Jane Doe III was sexually abused, forced to engage
• 31:00
  Speaker 1: in commercial sex acts, and trafficked by Epstein and his
• 31:03
  Speaker 1: co-conspirators from 2015 to 2019 in New York, Florida, USVI,
• 31:09
  Speaker 1: and around the world. 190 Plaintiff Jane Doe IV was
• 31:13
  Speaker 1: sexually abused, forced to engage in commercial sex acts, and
• 31:17
  Speaker 1: trafficked by Epstein and his co-conspirators from 2001 to 2009
• 31:20
  Speaker 1: in New York, Florida, USVI, and around the world. 191
• 31:26
  Speaker 1: Plaintiff Jane Doe 5 was sexually abused, forced to engage
• 31:29
  Speaker 1: in commercial sex acts, and trafficked by Epstein and his
• 31:32
  Speaker 1: co-conspirators from 2001 to 2009 in New York, Florida, USVI,
• 31:38
  Speaker 1: and around the world. 192. Plaintiff Jane Doe 6 was
• 31:41
  Speaker 1: sexually abused, forced to engage in commercial sex acts, and
• 31:45
  Speaker 1: trafficked by Epstein and his co-conspirators in approximately 2004 in
• 31:49
  Speaker 1: New York and the USVI. 193. Epstein and his co-conspirators
• 31:54
  Speaker 1: committed numerous intentional acts against Plaintiff Jane Doe I, which
• 31:58
  Speaker 1: constitute sexual offenses as defined in New York Penal Law
• 32:02
  Speaker 1: Section 130, including but not limited to the following. A.
• 32:05
  Speaker 1: Sexual misconduct, as defined in Section 130.20, inasmuch as Jeffrey
• 32:11
  Speaker 1: Epstein engaged in sexual intercourse with Jane Doe I without
• 32:14
  Speaker 1: her consent. B. Rape in the first degree, as defined
• 32:18
  Speaker 1: in Section 130.35. inasmuch as Jeffrey Epstein engaged in sexual
• 32:23
  Speaker 1: intercourse with Jane Doe 1 by forcible compulsion. C. Criminal
• 32:28
  Speaker 1: sexual act in the first degree, as defined in Section 130.50,
• 32:33
  Speaker 1: inasmuch as Jeffrey Epstein engaged in oral sexual conduct with
• 32:37
  Speaker 1: Jane Doe 1 by forcible compulsion. D. Forcible touching, as
• 32:41
  Speaker 1: defined in Section 130.52, inasmuch as Jeffrey Epstein intentionally and
• 32:47
  Speaker 1: for no legitimate purpose engaged the forcible sexual touching of
• 32:50
  Speaker 1: Jane Doe 1 for the purpose of degrading or abusing
• 32:53
  Speaker 1: her or for the purpose of gratifying his own sexual
• 32:56
  Speaker 1: desire and e. sexual abuse in the third degree as
• 33:00
  Speaker 1: defined in section 130.66 inasmuch as Jeffrey Epstein inserted a
• 33:05
  Speaker 1: foreign object in the vagina of Jane Doe 1 by
• 33:08
  Speaker 1: forcible compulsion. 194. Epstein and his co-conspirators committed numerous intentional
• 33:14
  Speaker 1: acts against plaintiff Jane Doe 2 which constitute sexual offenses,
• 33:19
  Speaker 1: as defined in the New York Penal Law, Section 130,
• 33:22
  Speaker 1: including but not limited to the following. A. Sexual misconduct
• 33:26
  Speaker 1: is defined in Section 130.20 inasmuch as Jeffrey Epstein engaged
• 33:31
  Speaker 1: in sexual intercourse with Jane Doe II without her consent. B.
• 33:35
  Speaker 1: Rape in the first degree, as defined in Section 130.35,
• 33:38
  Speaker 1: inasmuch as Jeffrey Epstein engaged in sexual intercourse with Jane
• 33:43
  Speaker 1: Doe II by forcible compulsion. C. criminal sexual act in
• 33:47
  Speaker 1: the first degree, as defined in Section 130.50, inasmuch as
• 33:52
  Speaker 1: Jeffrey Epstein engaged in oral sexual conduct with Jane Doe
• 33:56
  Speaker 1: II by forcible compulsion. d. Forcible touching, as defined in
• 34:00
  Speaker 1: Section 130.52, inasmuch as Jeffrey Epstein intentionally and for no
• 34:05
  Speaker 1: legitimate purpose engaged the forcible sexual touching of Jane Doe
• 34:09
  Speaker 1: II for the purpose of degrading or abusing her for
• 34:12
  Speaker 1: the purpose of gratifying his own sexual desire. and E.
• 34:16
  Speaker 1: Sexual Abuse in the Third Degree, as defined in Section 130.66,
• 34:21
  Speaker 1: inasmuch as Jeffrey Epstein inserted a foreign object into the
• 34:24
  Speaker 1: vagina of Jane Doe II by forcible compulsion. 195. Epstein
• 34:29
  Speaker 1: and his co-conspirators committed numerous intentional acts against plaintiff Jane
• 34:33
  Speaker 1: Doe III, which constitute sexual offenses, as defined in New
• 34:37
  Speaker 1: York Penal Law, Section 130, including but not limited to
• 34:40
  Speaker 1: the following. A. Sexual misconduct as defined in Section 130.20
• 34:46
  Speaker 1: inasmuch as Jeffrey Epstein engaged in sexual intercourse with Jane
• 34:49
  Speaker 1: Doe III without her consent. B. Rape in the first
• 34:53
  Speaker 1: degree as defined in Section 130.35 inasmuch as Jeffrey Epstein
• 34:57
  Speaker 1: engaged in sexual intercourse with Jane Doe III by forcible compulsion. C.
• 35:02
  Speaker 1: Criminal sexual act in the first degree as defined in
• 35:05
  Speaker 1: Section 130.50 inasmuch as Jeffrey Epstein engaged in oral sexual
• 35:10
  Speaker 1: conduct with Jane Doe 3, by a forcible compulsion. D.
• 35:14
  Speaker 1: Forcible touching as defined in section 130.52, inasmuch as Jeffrey
• 35:19
  Speaker 1: Epstein intentionally and for no legitimate purpose engaged in the
• 35:22
  Speaker 1: forcible sexual touching of Jane Doe 3 for the purpose
• 35:25
  Speaker 1: of degrading or abusing her or for the purpose of
• 35:28
  Speaker 1: gratifying his own sexual desire. And E. Sexual abuse in
• 35:33
  Speaker 1: the third degree, as defined in section 130.66, inasmuch as
• 35:38
  Speaker 1: Jeffrey Epstein inserted a foreign object in the vagina of
• 35:41
  Speaker 1: Jane Doe 3 by forcible compulsion. 196. Epstein and his
• 35:46
  Speaker 1: co-conspirators committed numerous intentional acts against plaintiff Jane Doe 4,
• 35:50
  Speaker 1: which constitute sexual offenses, as defined in New York Penal
• 35:54
  Speaker 1: Law Section 130, including but not limited to the following. A.
• 35:59
  Speaker 1: Sexual misconduct, as defined in Section 130.20, inasmuch as Jeffrey
• 36:03
  Speaker 1: Epstein engaged in sexual intercourse with Jane Doe 4 without
• 36:07
  Speaker 1: her consent. B. rape in the first degree, as defined
• 36:11
  Speaker 1: in Section 130.35, inasmuch as Jeffrey Epstein engaged in sexual
• 36:15
  Speaker 1: intercourse with Jane Doe 4 by forcible compulsion. C. Criminal
• 36:20
  Speaker 1: sexual act in the first degree, as defined in Section 130.50,
• 36:24
  Speaker 1: inasmuch as Jeffrey Epstein engaged in oral sexual conduct with
• 36:28
  Speaker 1: Jane Doe 4 by forcible compulsion. D. Forcible touching, as
• 36:33
  Speaker 1: defined in Section 130.52, inasmuch as Jeffrey Epstein intentionally and
• 36:38
  Speaker 1: for no legitimate purpose, engaged in forcible sexual touching of
• 36:42
  Speaker 1: Jane Doe IV for the purpose of degrading or abusing her,
• 36:46
  Speaker 1: or for the purpose of gratifying his own sexual desire.
• 36:49
  Speaker 1: And E. Sexual abuse in the third degree, as defined
• 36:52
  Speaker 1: in Section 130.66, inasmuch as Jeffrey Epstein inserted a foreign
• 36:57
  Speaker 1: object in the vagina of Jane Doe IV by forcible compulsion. 197.
• 37:03
  Speaker 1: Epstein and his co-conspirators committed numerous intentional acts against plaintiff
• 37:06
  Speaker 1: Jane Doe V, which constitutes sexual offenses as defined in
• 37:10
  Speaker 1: New York Penal Law Section 130, including but not limited
• 37:14
  Speaker 1: to the following. A. Sexual misconduct as defined in Section 130.20
• 37:19
  Speaker 1: inasmuch as Jeffrey Epstein engaged in sexual intercourse with Jane
• 37:22
  Speaker 1: Doe 5 without her consent. B. Rape in the first
• 37:26
  Speaker 1: degree as defined in Section 130.35 inasmuch as Jeffrey Epstein
• 37:30
  Speaker 1: engaged in sexual intercourse with Jane Doe 5 by forcible compulsion. C.
• 37:35
  Speaker 1: Criminal sexual act in the first degree. as defined in
• 37:38
  Speaker 1: Section 130.50, inasmuch as Jeffrey Epstein engaged in oral sexual
• 37:43
  Speaker 1: conduct with Jane Doe 5 by forcible compulsion. D. Forcible
• 37:48
  Speaker 1: touching as defined in Section 130.52, inasmuch as Jeffrey Epstein intentionally,
• 37:53
  Speaker 1: and for no legitimate purpose, engaged the forcible sexual touching
• 37:57
  Speaker 1: of Jane Doe 5 for the purpose of degrading or
• 38:00
  Speaker 1: abusing her, or for the purpose of gratifying his own
• 38:03
  Speaker 1: sexual desire. And E. Sexual abuse in the third degree,
• 38:07
  Speaker 1: as defined in Section 130.66, inasmuch as Jeffrey Epstein inserted
• 38:12
  Speaker 1: a foreign object in the vagina of Jane Doe 5
• 38:15
  Speaker 1: by forcible compulsion. Alright, we're going to wrap up right here,
• 38:18
  Speaker 1: and in the next episode we're going to pick up
• 38:20
  Speaker 1: with 198, Epstein and his co-conspirators committed numerous intentional acts.
• 38:25
  Speaker 1: All of the information that goes with this episode can
• 38:28
  Speaker 1: be found in the description box. What's up everyone, and
• 38:31
  Speaker 1: welcome back to the Epstein Chronicles. In this episode, we're
• 38:34
  Speaker 1: getting right back to the amended survivor's lawsuit filed against
• 38:39
  Speaker 1: the USVI. 198. Epstein and his co-conspirators committed numerous intentional
• 38:45
  Speaker 1: acts against plaintiff Jane Doe Six, which constitutes sexual offenses
• 38:49
  Speaker 1: as defined in New York Penal Law Section 130, including
• 38:53
  Speaker 1: but not limited to the following. A. Sexual misconduct as
• 38:57
  Speaker 1: defined in Section 130.20. inasmuch as Jeffrey Epstein engaged in
• 39:02
  Speaker 1: sexual intercourse with Jane Doe No. 6 without her consent. B.
• 39:06
  Speaker 1: Rape in the first degree is defined in Section 130.35,
• 39:10
  Speaker 1: inasmuch as Jeffrey Epstein engaged in sexual intercourse with Jane
• 39:14
  Speaker 1: Doe 6 by a forcible compulsion. 199. At all times
• 39:18
  Speaker 1: mentioned herein, defendants owed a duty of care including, but
• 39:22
  Speaker 1: not limited to, ensuring the citizens, aliens, and travelers to
• 39:26
  Speaker 1: USVI are protected by the USVI government, uniformly under the
• 39:31
  Speaker 1: federal law, including U.S. Code 18, Section 1591, 1594, and 1595,
• 39:39
  Speaker 1: prohibiting the facilitation and promotion of sex trafficking and the
• 39:42
  Speaker 1: profiting thereof, 200. At all times mentioned herein, defendants owed
• 39:47
  Speaker 1: a duty of care, including but not limited, to ensuring
• 39:50
  Speaker 1: the citizens, aliens, and travelers to the USVI are reasonably
• 39:54
  Speaker 1: protected by the USVI's government under the federal law prohibiting
• 39:58
  Speaker 1: sex trafficking and in the promotion of sex trafficking and
• 40:01
  Speaker 1: facilitating of sex trafficking when on the USVI's territories. 202.
• 40:07
  Speaker 1: USVI had a duty to supervise their government employees, such
• 40:10
  Speaker 1: as defendants, to ensure that their actions, in following government-directed orders,
• 40:15
  Speaker 1: do not promote, encourage, or facilitate sex trafficking within the USVI,
• 40:19
  Speaker 1: from the USVI, or to the USVI. 203. USVI had
• 40:25
  Speaker 1: a duty to supervise their government employees, defendants to ensure
• 40:29
  Speaker 1: their actions in following the government-directed orders, enforce the law reasonably,
• 40:33
  Speaker 1: and equally within the USVI. 204. At all times mentioned herein,
• 40:38
  Speaker 1: defendants and or their agents, servants, and or employees breached
• 40:42
  Speaker 1: the above stated duty in a negligent manner, and enabled, facilitated,
• 40:46
  Speaker 1: and allowed Epstein sex trafficking to continue unfettered. 205. Defendant
• 40:51
  Speaker 1: USVI negligently hired, supervised, and retained defendants John Doe's 1
• 40:56
  Speaker 1: through 100. 206. Defendants were negligent in their failure to
• 41:01
  Speaker 1: carry out their jobs, positions, and duties as government employees
• 41:04
  Speaker 1: to their fullest extent, and instead following orders from others
• 41:09
  Speaker 1: directing them to ignore Epstein's enterprise of continuous and open
• 41:12
  Speaker 1: sex trafficking of young women and and or directing them
• 41:15
  Speaker 1: to provide specialized services to Epstein, a civilian, in furtherance
• 41:20
  Speaker 1: of Epstein's sex trafficking scheme. Defendants as USVI customs agents
• 41:26
  Speaker 1: facilitated Epstein, his associates, and many female victims being trafficked
• 41:30
  Speaker 1: by Epstein, including plaintiffs, by failing to check and or
• 41:34
  Speaker 1: inspect plaintiffs and Epstein's guests for legally valid travel documents
• 41:38
  Speaker 1: including customs forms, passports, and or visas, and by failing
• 41:42
  Speaker 1: to inspect his guests' or Jane Doe's travel documents, including
• 41:46
  Speaker 1: custom forms, passports, and or visas, by failing to inquire
• 41:50
  Speaker 1: as to Jane Doe's and Epstein's guests' legally valid travel documents,
• 41:54
  Speaker 1: including custom forms, passports, and or visas, by failing to
• 41:58
  Speaker 1: require plaintiffs and Epstein's guests to provide and or present
• 42:02
  Speaker 1: the agents with legally valid and required travel documents, including
• 42:06
  Speaker 1: custom forms, passports, and or visas, and by failing to
• 42:10
  Speaker 1: require plaintiffs and Epstein's guests to provide and or present
• 42:14
  Speaker 1: the agents with any form of identification before granting plaintiffs
• 42:17
  Speaker 1: and Epstein's guests entry into the USVI. By failing to
• 42:21
  Speaker 1: require plaintiffs and Epstein's guests to provide and or present
• 42:25
  Speaker 1: the agents with legally valid and required travel documents, including
• 42:29
  Speaker 1: custom forms, passports, and or visas, before issuing plaintiffs and
• 42:32
  Speaker 1: Epstein's guests travel documentation, allowing plaintiffs and Epstein's guests to
• 42:37
  Speaker 1: travel back into the United States from the USVI. By
• 42:41
  Speaker 1: failing to require plaintiff and Epstein's guests to provide and
• 42:44
  Speaker 1: or present the agents with any form of identification before
• 42:48
  Speaker 1: issuing plaintiffs and Epstein's guests travel documentation allowing plaintiffs and
• 42:52
  Speaker 1: Epstein's guests to travel back into the United States from
• 42:55
  Speaker 1: the USVI. By allowing plaintiffs, Epstein, and his associates to
• 43:00
  Speaker 1: enter and remain on USVI territory without the proper travel documentation,
• 43:06
  Speaker 1: by failing to ensure plaintiffs, Epstein, and his associates were
• 43:09
  Speaker 1: entering the USVI legally, by failing to ensure plaintiffs Epstein
• 43:14
  Speaker 1: and his associates did not remain in the USVI illegally,
• 43:18
  Speaker 1: by failing to question and or investigate plaintiffs and other
• 43:21
  Speaker 1: sex trafficking victims to ensure that they were in the
• 43:24
  Speaker 1: USVI legally, on their own accord, and not being sex trafficked,
• 43:29
  Speaker 1: by failing to ensure plaintiffs Epstein and his associates were
• 43:32
  Speaker 1: leaving the USVI legally, and of their own accord, by
• 43:36
  Speaker 1: and in accordance with government orders. Not conducting searches or
• 43:40
  Speaker 1: questioning of Epstein and his female guests by and accordance
• 43:43
  Speaker 1: with no government orders, not detaining under any circumstances Epstein
• 43:48
  Speaker 1: and his female guests by and accordance with government orders,
• 43:51
  Speaker 1: not questioning Epstein and any of his female guests, providing
• 43:55
  Speaker 1: any and all courtesies to Epstein, and by failing to
• 43:58
  Speaker 1: perform the proper checks when granting plaintiffs Epstein and his
• 44:02
  Speaker 1: associates entry into the USVI. 208. Defendants as USVI air
• 44:07
  Speaker 1: traffic controllers facilitated Epstein, his associates, and many female victims
• 44:12
  Speaker 1: being trafficked by Epstein, including plaintiffs, by allowing Epstein to
• 44:16
  Speaker 1: land his plane at the USVI airports without entering the plane, providing,
• 44:21
  Speaker 1: and any and all courtesies to Epstein, by allowing Epstein
• 44:25
  Speaker 1: to land his plane at the USVI airports without inspecting
• 44:28
  Speaker 1: the plane, by allowing and ensuring Epstein could at all
• 44:31
  Speaker 1: times land his plane in isolated areas, to protect a
• 44:34
  Speaker 1: sex trafficking enterprise, to allowing Epstein to land his plane
• 44:38
  Speaker 1: and disembark without any government oversight or inquiry, by allowing
• 44:42
  Speaker 1: plaintiffs Epstein and his associates to enter and remain on
• 44:46
  Speaker 1: USVI territory without checking them for proper travel documentation, by
• 44:51
  Speaker 1: failing to ensure plaintiffs Epstein and his associates were entering
• 44:55
  Speaker 1: the USVI legally, and by failing to perform the proper
• 44:58
  Speaker 1: checks when granting plaintiffs Epstein and his associates entry into
• 45:02
  Speaker 1: the USVI. 209. Defendants, as USVI airport baggage check agents,
• 45:09
  Speaker 1: facilitated Epstein, his associates, and many female victims being trafficked
• 45:13
  Speaker 1: by Epstein, including plaintiffs, by allowing Epstein to land his
• 45:17
  Speaker 1: plane at the USVI airports without entering the plane, by
• 45:20
  Speaker 1: allowing Epstein to land his plane at the USVI airports
• 45:24
  Speaker 1: without inspecting the plane, by allowing and ensuring Epstein could
• 45:28
  Speaker 1: land at all times in isolated areas to protected sex
• 45:31
  Speaker 1: trafficking enterprise, providing... and any and all courtesies to Epstein by,
• 45:37
  Speaker 1: in accordance with government orders, not conducting searches of Epstein
• 45:41
  Speaker 1: and his female guests, by failing to question and or
• 45:43
  Speaker 1: investigate plaintiffs and the other sex trafficking victims to ensure
• 45:47
  Speaker 1: that they were in the USVI legally, on their own accord,
• 45:51
  Speaker 1: and not being sex trafficked, by failing to question and
• 45:54
  Speaker 1: or investigate plaintiffs and the other sex trafficking victims to
• 45:58
  Speaker 1: ensure that they were in the USVI legally, on their
• 46:01
  Speaker 1: own accord, and not being sex trafficked, by in accordance
• 46:04
  Speaker 1: with government orders not detaining, under any circumstances, Epstein and
• 46:08
  Speaker 1: his female guests, by in accordance with government orders not
• 46:12
  Speaker 1: questioning Epstein and any of his female guests, to allowing
• 46:15
  Speaker 1: Epstein to land his plane and disembark without any government
• 46:18
  Speaker 1: oversight or inquiry, by allowing plaintiffs, Epstein, and his associates
• 46:23
  Speaker 1: to enter and remain on USVI territory without checking them
• 46:27
  Speaker 1: for proper travel documentation, by failing to ensure plaintiff, Epstein,
• 46:31
  Speaker 1: and his associates were entering the USVI legally, and by
• 46:35
  Speaker 1: failing to perform the proper checks when granting plaintiffs, Epstein,
• 46:38
  Speaker 1: and his associates entry into the USVI. 210. Defendants as
• 46:44
  Speaker 1: USVI police officers facilitated Epstein, his associates, and many female
• 46:48
  Speaker 1: victims being trafficked by Epstein, including plaintiffs, by, when instructed,
• 46:53
  Speaker 1: providing Epstein with protection when traveling around USVI, by, in
• 46:57
  Speaker 1: accordance with government orders, not conducting searches of Epstein, and
• 47:01
  Speaker 1: his female guests, by failing to question and or investigate
• 47:05
  Speaker 1: plaintiffs and the other sex trafficking victims to ensure that
• 47:08
  Speaker 1: they were in the USVI legally, on their own accord,
• 47:11
  Speaker 1: and not being trafficked, by, in accordance with government orders,
• 47:15
  Speaker 1: not detaining under any circumstances Epstein and his female guests, by,
• 47:19
  Speaker 1: in accordance with government orders, not questioning Epstein and any
• 47:23
  Speaker 1: of his female guests, and in providing any and all
• 47:26
  Speaker 1: courtesies to Epstein when on USVI. 211. Defendants as USVI
• 47:33
  Speaker 1: Coast Guard agents facilitated Epstein and his associates and many
• 47:37
  Speaker 1: female victims being trafficked by Epstein, including Jane Doe's one
• 47:40
  Speaker 1: through six, in providing any and all courtesies to Epstein
• 47:44
  Speaker 1: on the USVI waterways by, in accordance with government orders,
• 47:49
  Speaker 1: not conducting searches of Epstein and his female guests by
• 47:52
  Speaker 1: failing to question and or investigate plaintiffs and the other
• 47:55
  Speaker 1: sex trafficking victims to ensure that they were in the
• 47:58
  Speaker 1: USVI legally on their own accord and and not being trafficked, by,
• 48:03
  Speaker 1: in accordance with government orders, not detaining, under any circumstances,
• 48:06
  Speaker 1: Epstein and his female guests, by, in accordance with government orders,
• 48:11
  Speaker 1: not questioning Epstein and any of his female guests, by,
• 48:14
  Speaker 1: in accordance with government orders, not boarding, searching, and or
• 48:17
  Speaker 1: inspecting any of Epstein's watercrafts or boats, providing, and any
• 48:23
  Speaker 1: and all courtesy to Epstein, by allowing and ensuring Epstein
• 48:26
  Speaker 1: could travel and traffic females freely on the waters of
• 48:29
  Speaker 1: the U.S. V.I., and by failing to perform the proper
• 48:32
  Speaker 1: checks when granting plaintiff Epstein and his associates entry into
• 48:36
  Speaker 1: the USVI. 212. As a direct and proximate result of
• 48:40
  Speaker 1: defendant's acts and or omissions, Epstein's sex trafficking enterprise was
• 48:45
  Speaker 1: able to continue to traffic plaintiffs, and as a result thereof,
• 48:48
  Speaker 1: plaintiffs and the class members were continually and repeatedly sexually
• 48:52
  Speaker 1: abused by Epstein and others within his sex trafficking venture,
• 48:56
  Speaker 1: and suffered severe and serious injuries. 213. The injuries that
• 49:00
  Speaker 1: Plaintiff Jane Doe's 1-6 and the class members suffered include
• 49:04
  Speaker 1: injuries directly and proximately suffered as a result of sex
• 49:08
  Speaker 1: offenses committed by Epstein and the other co-conspirators and criminalized
• 49:13
  Speaker 1: under Article 130 of the New York Penal Laws. The
• 49:16
  Speaker 1: offenses include sexual intercourse without consent and oral sexual harassment.
• 49:20
  Speaker 1: conduct without consent, forbidden by New York Penal Law, Section 130.20.
• 49:25
  Speaker 1: The offenses included forcible touching of sexual or other intimate
• 49:28
  Speaker 1: parts without consent, forbidden by New York Penal Law, Section 130.20, 130.35, 130.50, 130.52,
• 49:32
  Speaker 1: and and 130.66. 214. The breaches of legal duty by
• 49:43
  Speaker 1: defendant proximately caused Plaintiff Jane Doe's 1-6 and the Master
• 49:47
  Speaker 1: Class members to repeatedly suffer injuries from Epstein and his co-conspirators,
• 49:52
  Speaker 1: including sexual assaults and resulting emotional distress, mental pain, suffering,
• 49:56
  Speaker 1: and other physical and psychological trauma. These injuries were easily
• 50:00
  Speaker 1: foreseeable because defendants knew and acted in reckless disregard of
• 50:04
  Speaker 1: the fact that their actions and omissions supporting and facilitating
• 50:08
  Speaker 1: Epstein would lead to, among other crimes, sex offenses by
• 50:11
  Speaker 1: Epstein and his co-conspirators forbidden by Article 130 of the
• 50:15
  Speaker 1: New York Penal Law against his victims, including Jane Doe's
• 50:18
  Speaker 1: 1-6 and class members. 215. In the exercise of reasonable care,
• 50:24
  Speaker 1: defendants knew or should have known of the dangerous propensities
• 50:27
  Speaker 1: of Jeffrey Epstein and the proximate harm that would be
• 50:30
  Speaker 1: caused by his likely sexual crimes and various violations of
• 50:33
  Speaker 1: Article 130 of New York Penal Law. 216. Defendants could
• 50:38
  Speaker 1: reasonably foresee that their actions and omissions in facilitating Epstein's
• 50:42
  Speaker 1: sex trafficking enterprise would lead to sex offenses against plaintiffs
• 50:46
  Speaker 1: and class members. Among other things, the defendants were specifically
• 50:50
  Speaker 1: aware that Epstein had previously been prosecuted for similar sex
• 50:54
  Speaker 1: crimes and previously paid numerous civil settlements associated with similar
• 50:58
  Speaker 1: sex crimes. Indeed, the defendants were aware and should have
• 51:02
  Speaker 1: been aware that Epstein was a high risk to commit
• 51:05
  Speaker 1: sex offenses against young women and girls. 217. Plaintiff and
• 51:09
  Speaker 1: the class members were easily within the zone of foreseeable
• 51:12
  Speaker 1: harm from defendants' reckless and negligent acts and omissions. Defendants'
• 51:17
  Speaker 1: acts and omissions foreseeably created substantial risk of Jeffrey Epstein
• 51:22
  Speaker 1: and his co-conspirators committing sex crimes against young women with
• 51:25
  Speaker 1: whom he was in contact. Tragically, plaintiffs and the class
• 51:29
  Speaker 1: members fell within that zone. 218. The sex offenses Jeffrey
• 51:34
  Speaker 1: Epstein committed against plaintiffs and the class members were easily
• 51:37
  Speaker 1: within the zone of foreseeable risks that the defendants created
• 51:40
  Speaker 1: with their reckless and negligent actions and omissions. Those actions
• 51:44
  Speaker 1: and omissions foreseeably risked further sex crimes by Jeffrey Epstein
• 51:49
  Speaker 1: and his co-conspirators, which is exactly and tragically the harm
• 51:52
  Speaker 1: that he inflicted on plaintiffs and the class members. 219.
• 51:56
  Speaker 1: Defendants' tortious conduct, in this case, evinced a high degree
• 52:00
  Speaker 1: of moral turpitude and demonstrated such wanton dishonesty as to
• 52:04
  Speaker 1: imply a criminal indifference to civil obligations. It is also
• 52:08
  Speaker 1: involved in outrageous and intentional acts and omissions because it
• 52:12
  Speaker 1: was a deliberate attempt to further the crimes of a
• 52:14
  Speaker 1: widespread and dangerous criminal sex trafficking organization. Defendant's tortious conduct
• 52:20
  Speaker 1: was directed specifically at plaintiffs and the class members who
• 52:24
  Speaker 1: were the victims of Epstein's sexual abuse and sex trafficking organization.
• 52:28
  Speaker 1: 220 As a result of the intentional and negligent actions
• 52:32
  Speaker 1: and omissions described in the count, plaintiffs and the class
• 52:35
  Speaker 1: members have sustained both general and specific damages in substantial amounts. 221.
• 52:41
  Speaker 1: Defendants' intentional, outrageous conduct evinced a high degree of moral
• 52:46
  Speaker 1: turpitude and demonstrated wanton dishonesty as to imply a criminal
• 52:50
  Speaker 1: indifference to civil obligations, making defendants liable to plaintiffs and
• 52:54
  Speaker 1: the class members for punitive damages. 222. The amount of
• 52:59
  Speaker 1: damages sought exceeds the jurisdiction of all lower courts which
• 53:02
  Speaker 1: would otherwise have jurisdiction. 223. This action falls within exceptions
• 53:07
  Speaker 1: to Article 16 of the CPLR. 7. Request for relief. 224.
• 53:13
  Speaker 1: Jane Doe 1, Jane Doe 2, Jane Doe 3, Jane
• 53:17
  Speaker 1: Doe 4, Jane Doe 5, and Jane Doe 6 respectfully
• 53:20
  Speaker 1: request that the court enter judgment in their favor and
• 53:23
  Speaker 1: against defendants as follows. A. That the court certify the class...
• 53:28
  Speaker 1: Name Jane Doe 1, Jane Doe 2, Jane Doe 3,
• 53:30
  Speaker 1: Jane Doe 4, Jane Doe 5, and Jane Doe 6
• 53:33
  Speaker 1: as class representatives and appoint their lawyers as class counsel. B.
• 53:38
  Speaker 1: That the court award plaintiffs and other members of the
• 53:41
  Speaker 1: class compensatory, consequential, general, and nominal damages against defendants in
• 53:46
  Speaker 1: an amount to be determined at trial. C. The court
• 53:49
  Speaker 1: award punitive and exemplary damages and treble damages against defendants
• 53:54
  Speaker 1: in an amount to be determined at trial. D. That
• 53:57
  Speaker 1: the court award plaintiffs the cost and disbursements of the
• 54:00
  Speaker 1: action along with reasonable attorney fees, costs, and expenses. E.
• 54:05
  Speaker 1: That the court award pre- and post-judgment interest at the
• 54:08
  Speaker 1: maximum legal rate. And F. That the court grant all
• 54:11
  Speaker 1: such other and further relief as it deems just and proper.
• 54:15
  Speaker 1: Jury Demand 225. Pursuant the Federal Rule of Civil Procedure 38B,
• 54:21
  Speaker 1: plaintiffs hereby demand a trial by jury in As to
• 54:24
  Speaker 1: all issues. And this document was signed by Jordan K. Merson.
• 54:29
  Speaker 1: Alright folks, that's going to do it for the amended complaint.
• 54:32
  Speaker 1: And obviously there's a ton more on the way. All
• 54:35
  Speaker 1: of the information that goes with this episode can be
• 54:37
  Speaker 1: found in the description box.