Latest / The Vault: The Epstein Files / New Mexico's Lawsuit Filed Against Epstein Executors Darren Indyke And Richard Kahn (Part 6) (10/24/26)

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New Mexico's Lawsuit Filed Against Epstein Executors Darren Indyke And Richard Kahn (Part 6) (10/24/26) · The Vault: The Epstein Files

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  Speaker 1: What's up, everyone, and welcome to another episode of the
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  Speaker 1: Epstein Chronicles. In this episode, we're going to dive right
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  Speaker 1: back in to the lawsuit filed by New Mexico against
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  Speaker 1: Indykin Khan. Causes of action, count one. Participating in a
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  Speaker 1: sex trafficking venture, violation of Trafficking Victims Protection Act, U.S.
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  Speaker 1: Code 18, Section 1591A, 1 and 2, and 1595D. The
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  Speaker 1: state of New Mexico restates and re-alleges the foregoing paragraph
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  Speaker 1: of the complaint as if fully set forth therein. The
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  Speaker 1: state of New Mexico brings this count pursuant to the
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  Speaker 1: Attorney General's parents' patriotic powers and express statutory authority to
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  Speaker 1: assure New Mexico residents that the state will take action
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  Speaker 1: to prevent, investigate, and prosecute sex trafficking and to protect
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  Speaker 1: them from the harmful effects of such criminal activity. Indyk
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  Speaker 1: provided obtained and maintained services and property in furtherance of
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  Speaker 1: the Epstein Enterprises trafficking scheme in exchange for financial benefit.
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  Speaker 1: Indyk knowingly and intentionally benefited financially from and received value
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  Speaker 1: for his participation in the sex trafficking venture in which
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  Speaker 1: the Epstein Enterprise was engaged and with knowledge of reckless
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  Speaker 1: disregard of Epstein and his associates' use of force, threats
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  Speaker 1: of force, fraud, coercion, and a combination of such means,
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  Speaker 1: to sexually abuse girls and young women, including by causing
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  Speaker 1: them to engage in commercial sex acts at Zorro Ranch
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  Speaker 1: and elsewhere. Indyk profited, in exchange for his knowing, facilitation
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  Speaker 1: of and implicit participation in Epstein's sex trafficking venture, and
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  Speaker 1: in doing so he knew, recklessly disregarded, and even concealed,
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  Speaker 1: Epstein's pattern and practice of using the channels and instrumentalities
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  Speaker 1: of interstate and foreign commerce to recruit, entice, harbor, transport, obtain,
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  Speaker 1: and maintain girls and young women for purposes of causing
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  Speaker 1: them to engage in commercial sex acts in violation of U.S.
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  Speaker 1: Code Section 1591A1 and 2. Indyk, based on his extensive
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  Speaker 1: involvement in Epstein's financial transactions, as well as his professional training,
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  Speaker 1: knew or recklessly disregarded that he was facilitating Epstein's sexual
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  Speaker 1: abuse and sex trafficking venture. Despite this knowledge, Indyk intentionally concealed, facilitated,
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  Speaker 1: and participated in in Epstein's violation of U.S. Code 18
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  Speaker 1: Section 1591, A1 and 2, and thereby actively facilitated or
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  Speaker 1: participated in the sex trafficking venture. Kahn provided, obtained, and
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  Speaker 1: maintained services and property in furtherance of the Epstein Enterprise
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  Speaker 1: trafficking scheme in exchange for financial benefit. Kahn knowingly and
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  Speaker 1: intentionally benefited financially from and received value for his participation
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  Speaker 1: in the sex trafficking venture in which the Epstein enterprise
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  Speaker 1: was engaged, and with knowledge or reckless disregard of Epstein
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  Speaker 1: and his associates' use of force, threats of force, fraud, coercion,
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  Speaker 1: and a combination of such means to sexually abuse girls
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  Speaker 1: and young women, including by causing them to engage in
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  Speaker 1: commercial sex acts at Zorro Ranch and elsewhere. Kahn profited,
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  Speaker 1: in exchange for his knowing facilitation of and implicit participation
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  Speaker 1: in Epstein's sex trafficking venture, and in doing so he
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  Speaker 1: knew recklessly disregarded and even concealed Epstein's pattern and practice
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  Speaker 1: of using the channels and instrumentalities of interstate and foreign
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  Speaker 1: commerce to recruit, entice, harbor, transport, obtain, and maintain girls
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  Speaker 1: and young women for purposes of causing them to engage
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  Speaker 1: in commercial sex acts in violation of U.S. Code 18,
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  Speaker 1: Section 1591A, 1 and 2. Kahn, based on this extensive
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  Speaker 1: involvement in Epstein's financial transactions, as well as his professional training,
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  Speaker 1: knew or recklessly disregarded that he was facilitating Epstein's sexual
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  Speaker 1: abuse and sex trafficking venture. Despite this knowledge, Kahn intentionally concealed, facilitated,
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  Speaker 1: and participated in Epstein's violation of U.S. Code Section 1591A1
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  Speaker 1: and 2, and thereby actively facilitated or participated in the
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  Speaker 1: sex trafficking venture. This knowing and intentional conduct has caused
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  Speaker 1: serious harm to the state of New Mexico and its residents,
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  Speaker 1: including without limitation financial harm by facilitating the sexual abuse
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  Speaker 1: of girls and young women, including their engagement in commercial
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  Speaker 1: sex acts in New Mexico. Indycan Khan's individual violation of
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  Speaker 1: the TVPA was outrageous and intentional because it was in
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  Speaker 1: deliberate furtherance of a widespread and dangerous criminal sex trafficking
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  Speaker 1: venture operated in and from New Mexico. This conduct also
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  Speaker 1: evidenced a high degree of moral turpitude and demonstrated such
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  Speaker 1: wanton disregard for the safety of the girls and young
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  Speaker 1: women in New Mexico and elsewhere, as to imply deliberate
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  Speaker 1: indifference to its legal obligations. By virtue of these knowing
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  Speaker 1: and intentional violations of U.S. Code 18, Section 1591, A1
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  Speaker 1: and 2, defendant Indyk and Kahn are liable for all
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  Speaker 1: appropriate relief under U.S. Code 18, Section 1595d, including compensatory
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  Speaker 1: and punitive damages to those injured under by defendants, disgorgement
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  Speaker 1: to those injured by indictment, restitution, attorney fees, and other
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  Speaker 1: equitable relief as the court deems appropriate. Count No. 2.
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  Speaker 1: Violation of N.M. 's Racketeering Act. New Mexico Statute Section
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  Speaker 1: 30-42-4C Kidnapping. The State of New Mexico restates and re-alleges
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  Speaker 1: the foregoing paragraphs of this complaint as if fully set
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  Speaker 1: forth herein. as alleged above defendant Indyk Kahn and Epstein,
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  Speaker 1: have received proceeds derived directly or indirectly from a pattern
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  Speaker 1: of racketeering activity in which each of these defendants participated
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  Speaker 1: either to establish or operate an enterprise that engaged in
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  Speaker 1: a pattern and practice of kidnapping and criminal solicitation in
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  Speaker 1: violation of the New Mexico Racketeering Act. The Epstein enterprise recruited, transported, transferred, harbored, received, provided, obtained, isolated, maintained,
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  Speaker 1: and entice girls and young women in the furtherance and
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  Speaker 1: performance of sex trafficking and sexual abuse, either of minors
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  Speaker 1: or through deception, intimidation, or force. In furtherance of these crimes,
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  Speaker 1: the Epstein enterprise engaged in two or more occasions of
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  Speaker 1: conduct that constitutes criminal predicate acts, as defined by the
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  Speaker 1: Racketeering Act. Specifically, as part of this pattern of racketeering activity,
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  Speaker 1: defendant Indyk and Kahn engaged in kidnapping in violation of
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  Speaker 1: New Mexico law Statute 3041. On lawfully taking, restraining, transporting,
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  Speaker 1: or confining survivors by force, intimidation, or deception with the
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  Speaker 1: intent to commit a sexual offense against the survivors. Specifically,
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  Speaker 1: Epstein deceived survivors with false promises of educational assistance, career advancement,
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  Speaker 1: financial support, and other benefits. Recruiting and transporting survivors to
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  Speaker 1: Zorro Ranch and other locations controlled by the Epstein Enterprise.
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  Speaker 1: Once there, Epstein confined survivors against their will, held them
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  Speaker 1: to service against their will, and exercised control over them
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  Speaker 1: through various tactics, either personally or through others, at his direction,
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  Speaker 1: through intimidation, coercion, psychological manipulation, and continued deception, including but
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  Speaker 1: not limited to threatening reputational harm, threatening abuse of process,
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  Speaker 1: passport confiscation, controlling the extinguishing external communications, and threatening violence.
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  Speaker 1: Defendant Indyk and Khan each committed their respective acts with
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  Speaker 1: the intent that survivors be confined against their will, that
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  Speaker 1: survivors engage in commercial sex acts against their will, and
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  Speaker 1: that sexual offenses be inflicted upon them during their confinement,
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  Speaker 1: thereby furthering the purpose and objectives of the Epstein enterprise.
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  Speaker 1: For instance, Jane Doe One was under the age of
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  Speaker 1: 18 when she was first transported to Zorro Ranch based
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  Speaker 1: on deception. She was the only guest at the sprawling
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  Speaker 1: estate where she was led to believe the trip was
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  Speaker 1: intended as an opportunity for Maxwell and Epstein to get
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  Speaker 1: to know Jane Doe 1 better and finalize plans for
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  Speaker 1: her summer trip to Thailand. Maxwell and Epstein used Jane
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  Speaker 1: Doe 1's trip to Zorro Ranch as an opportunity to isolate, groom,
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  Speaker 1: and abuse her. Jane Doe 3 was transported on Epstein's
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  Speaker 1: personal plane through deception to Zorro Ranch when she was
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  Speaker 1: 15 years old. Jane Doe 3 was transported with the
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  Speaker 1: intent of being sexually abused by Epstein, who did so
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  Speaker 1: for hours. Jane Doe 4 was transported to Zorro Ranch
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  Speaker 1: through intimidation and deception for the purpose of being sexually
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  Speaker 1: abused at Zorro Ranch and to be held to service
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  Speaker 1: by Epstein to be sexually abused by others. Jane Doe
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  Speaker 1: 5 was transported to Zorro Ranch through intimidation for the
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  Speaker 1: purpose of sexual abuse by Epstein and others. Epstein uses
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  Speaker 1: money and power to intimidate Jane Doe 5 to have
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  Speaker 1: sex with Epstein and others. Jane Doe 6 was transported
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  Speaker 1: to Zorro Ranch through intimidation and or deception for the
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  Speaker 1: intent of being sexually abused. Jane Doe 7 was brought
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  Speaker 1: to Zorro Ranch under deception, believing she was there to
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  Speaker 1: provide massages to Epstein and guests. Epstein instead forced Jane
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  Speaker 1: Doe 7 to have non-consensual sex with him. Each of
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  Speaker 1: these defendants, through a pattern of criminal activity acquired and
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  Speaker 1: maintained directly or indirectly, An interest in or control of
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  Speaker 1: the Epstein Enterprise or real property. The pattern of kidnapping
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  Speaker 1: was not isolated, but was related to and conducted through
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  Speaker 1: the affairs of the Epstein Enterprise, in willful violation of
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  Speaker 1: the Racketeering Act. As a direct and proximate result of
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  Speaker 1: each of these defendants' individual wrong actions, the State of
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  Speaker 1: New Mexico and the residents sustained injury to person, business,
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  Speaker 1: and property. Each of these defendants' wrongful actions and inactions
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  Speaker 1: directly and proximately caused injury to the girls and women
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  Speaker 1: who were trafficked, abused, coerced, held against their will, and
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  Speaker 1: solicited through the Epstein Enterprise. In addition, the state brings
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  Speaker 1: this count pursuant to New Mexico statute 30-426B on behalf
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  Speaker 1: of the people injured by the pattern of racketeering activity
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  Speaker 1: in New Mexico and to prevent, restrain, and remedy the
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  Speaker 1: racketeering activity and its effects. All right, we're going to
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  Speaker 1: wrap up right here, folks. And in the next episode,
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  Speaker 1: we're going to finish this bad boy off. All the
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  Speaker 1: information that goes with this episode can be found in
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  Speaker 1: the description box.