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Mega Edition: Mary Doe And Her Allegations Against Jeffrey Epstein (8/11/26) · The Vault: The Epstein Files

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  Speaker 1: What's up, everyone, and welcome back to the Epstein Chronicles.
• 0:04
  Speaker 1: In today's episode, we're going to dive right back into
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  Speaker 1: those core documents, and this time we're going to take
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  Speaker 1: a look at the claims made by Mary Doe against
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  Speaker 1: the Jeffrey Epstein a State. And if you pay attention,
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  Speaker 1: you'll notice the same names popping up time and time
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  Speaker 1: again in these core documents, people like Sarah Kellen Vickers
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  Speaker 1: and Leslie Groth. And guess what, none of them have
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  Speaker 1: ever even come close to being indicted as far as
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  Speaker 1: we know. So go ahead and chew on that for
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  Speaker 1: a little while and see if it doesn't make you sick.
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  Speaker 1: Case number st Dash nineteen dash PEB Dash eighty Action
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  Speaker 1: for Probate in the matter of the Estate of Jeffrey
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  Speaker 1: e Epstein, Claim the undersigned Mary Anne Meyer Wang Esquire
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  Speaker 1: and Cuddy Hecker Wang LLP and Richard P. Bourne Vanik
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  Speaker 1: Esquire hereby present and file this claim on behalf of
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  Speaker 1: Mary Doe, the claimant for unliquidated and unsecured damages from
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  Speaker 1: the estate of Jeffrey e Epstein, the estate in the
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  Speaker 1: above captioned matter now pending before court, and in support
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  Speaker 1: thereof status follows. One. Jeffrey Edward Epstein. The decedent was
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  Speaker 1: arrested in New York City, New York, on July six,
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  Speaker 1: twenty nineteen, and held in custody on sex trafficking charges
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  Speaker 1: following a series of investigations into his activities prior there too. Two.
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  Speaker 1: Claimant is one of several underage victims of decedent's criminal actions. Three. Decedent,
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  Speaker 1: upon information and belief, conspired with multiple individuals, including attorneys
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  Speaker 1: and advisors, to fraudently convey and tied assets from his victims,
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  Speaker 1: including claimant, by transferring assets to a newly created trust
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  Speaker 1: through the provisions of a contemporaneously drafted last will and
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  Speaker 1: testament honor about a DA bugst eight twenty nineteen, number four.
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  Speaker 1: On November twentieth, twenty nineteen, Claimant filed a civil action
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  Speaker 1: in the United States District Court for the Southern District
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  Speaker 1: of New York seeking damages against the estate. A true
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  Speaker 1: and correct copy of the complaint so filed and indexed
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  Speaker 1: as case number nineteen ev. Dash one zero seven to
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  Speaker 1: five eight, is attached Heer two as Exhibit A five.
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  Speaker 1: Pursuant to the New York Child's Victim Act, claimants civil
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  Speaker 1: action in New York was commenced timely six decedent sexually
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  Speaker 1: abused claimant on multiple occasions. Seven. The first quarterly accounting
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  Speaker 1: filed in the probate of the decedents estate lists personal
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  Speaker 1: and real property valued at six hundred thirty four million,
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  Speaker 1: seven hundred ninety seven thousand and forty seven dollars eight.
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  Speaker 1: Claimant's claim as determined and a final judgment in the
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  Speaker 1: matter attached heer two as exhibit A, including compensatory damages,
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  Speaker 1: punitive damages, costs and feet is rightfully entitled to payment
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  Speaker 1: whether or not the claim has been reduced or judgment liquidated,
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  Speaker 1: fixed or matured, and has an equitable lean on all
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  Speaker 1: unencumbered assets and property of the estate. And this was
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  Speaker 1: signed by Mary Ann Meyer Wang and it was signed
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  Speaker 1: on the second day of March of twenty twenty. Moving
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  Speaker 1: on to the next document, we have the complaint and
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  Speaker 1: Jerry Demand case number nineteen SIV DOT zero seven five
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  Speaker 1: eight Mary Doe plaintiff against Darren Endyke and Richard Kahn
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  Speaker 1: as executors of the estate of Jeffrey Epstein and Sarah Vickers. Well,
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  Speaker 1: that's interesting, isn't it. All These Sarah Vickers, all of
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  Speaker 1: these comments, all of these insertions and court documents, and
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  Speaker 1: never once has this lady been slapped in bracelets and
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  Speaker 1: dragged into a police house for questioning go figure. Plaintiff
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  Speaker 1: Mary Doe buy and, through her attorneys Cuddy, Hecker, Wang
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  Speaker 1: and All Read Morocco and Goldberg for her complaint alleges
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  Speaker 1: as follows. Nature of the action. One. Beginning when Plaintiff
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  Speaker 1: Mary Doe was sixteen years old, Jeffrey Epstein preyed upon her,
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  Speaker 1: manipulated her to be completely dependent on him, and repeatedly
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  Speaker 1: sexually assaulted her. As a result, she attempted suicide multiple times.
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  Speaker 1: His degradation of her was total for years. Two. As
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  Speaker 1: a young child, Mary had fled a war torn region
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  Speaker 1: with her parents and come to the United States as
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  Speaker 1: a refugee. When she met Epstein in two thousand and eight,
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  Speaker 1: Mary was sixteen years old, living in New York and
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  Speaker 1: working NonStop in pursuit of a promising career as a model.
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  Speaker 1: She had success. She had numerous spreads in major fashion
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  Speaker 1: magazines and appeared in various high fashion campaigns. Three, Mary
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  Speaker 1: met Epstein through another model. He made clear to Mary
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  Speaker 1: how important and powerful he was. He indicated to her
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  Speaker 1: that he could help her with connections in modeling world
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  Speaker 1: and could even get her admitted to Harvard if she
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  Speaker 1: got the necessary grades. Four. Mary felt very fortunate to
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  Speaker 1: have Epstein. She was amazed that such a powerful man
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  Speaker 1: wanted to help her, and she believed that she could
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  Speaker 1: trust him Because they had hours of conversation about her
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  Speaker 1: and her desire for an education. She understood that he
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  Speaker 1: could change her life and help her achieve her parents'
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  Speaker 1: dream of going to a top school. Five. Epstein used
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  Speaker 1: his power over Mary to sexually abuse her viciously and repeatedly. Epstein,
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  Speaker 1: often through defendant Sarah Vickers Kellen, would summon Mary to
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  Speaker 1: his Manhattan townhouse, order her to give him massages, and
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  Speaker 1: then subject her to sexual acts, the severity of which
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  Speaker 1: increased over time. Number six. Mary's first visit to the townhouse,
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  Speaker 1: it was only a massage. The second time, Epstein ordered
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  Speaker 1: her to take off her top and sit on top
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  Speaker 1: of him while she massaged them. The third time, Epstein
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  Speaker 1: forcibly pressed an electric massage device against Mary's genitals. Seven.
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  Speaker 1: In subsequent encounters, Epstein ordered Mary to masturbate him. He
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  Speaker 1: forcefully penetrated her with his fingers. He forced her to
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  Speaker 1: perform oral sex on him numerous times, holding her head
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  Speaker 1: down on his penis. Even as she gagged and tried
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  Speaker 1: to escape, he ejaculated in her mouth and on her body.
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  Speaker 1: Epstein repeated this violent sexual abuse dozens of times. After
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  Speaker 1: each massage, Epstein gave Mary a few hundred dollars bills. Eight.
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  Speaker 1: Epstein manipulated and threatened Mary to ensure that she understood
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  Speaker 1: his total power over her life, with both offers to
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  Speaker 1: help and threats not to contradict them. Sixteen, Mary understood
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  Speaker 1: that she had no choice but to follow his commands. Nine.
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  Speaker 1: In approximately late two thousand and four, when Mary was
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  Speaker 1: sixteen years old, Epstein took her virginity. Epstein first ordered
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  Speaker 1: her to strip down and shower, washed her compulsive, and
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  Speaker 1: threatened that if she was not a virgin, he would
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  Speaker 1: have her killed. Epstein then forcibly penetrated her and took
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  Speaker 1: her virginity, pushing her face onto the bed to silence
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  Speaker 1: her protests. Ten. Kellen played an integral role in facilitating
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  Speaker 1: Epstein's sexual abuse of Mary. Kellen arranged for Mary to
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  Speaker 1: come to the townhouse and frequently saw Mary going into
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  Speaker 1: the massage room with Epstein. Epstein openly commented to Kellen
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  Speaker 1: about Mary performing sexual lax for him, and Kellen once
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  Speaker 1: witnessed Epstein forcing Mary to perform oral sex on him. Eleven.
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  Speaker 1: In late two thousand and five, after being sexually abused
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  Speaker 1: by Epstein yet again, she heard Epstein shout to Kellen
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  Speaker 1: that Mary was the best cocksucker. Mary was mortified and ashamed,
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  Speaker 1: and in that moment suddenly saw the truth. She was
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  Speaker 1: not even a human being to Epstein. She was an object.
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  Speaker 1: She left the townhouse feeling physically ill. Mary saw another
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  Speaker 1: girl her age entering his town house. The penny dropped.
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  Speaker 1: Mary suddenly felt like Epstein's prostitute, as one of many
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  Speaker 1: girls he treated as sexual objects. Twelve. Mary's realization caused
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  Speaker 1: a breakdown. She nearly immediately left New York City, returned
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  Speaker 1: to her parents home across the country, and never saw
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  Speaker 1: Epstein again. Thirteen. Epstein's abuse devastated Mary. She abruptly quit
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  Speaker 1: the modeling world in which she had been a budding star.
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  Speaker 1: She felt humiliated, angry, and suicidal. She cried inconsolably and
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  Speaker 1: had debilitating panic attacks. She developed severe depression and anxiety.
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  Speaker 1: She isolated herself and had to rebuild from a dark place. Fourteen.
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  Speaker 1: Mary continues to feel the dramatic psychological scars from Epstein's
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  Speaker 1: abuse every day. Fifteen. When Epstein was arrested in July
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  Speaker 1: twenty nineteen, Mary was briefly hopeful that he might finally
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  Speaker 1: face consequences, but his death left Mary with a desolate
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  Speaker 1: sense that he has evaded justice yet again. Sixteen Mary
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  Speaker 1: brings us action at last, some measure of justice for
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  Speaker 1: the egregious abuse at Epstein inflicted on her when she
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  Speaker 1: was a child, which irreparably scarred her for life. The
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  Speaker 1: parties seventeen. Plaintiff Mary Doe is an individual who resides
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  Speaker 1: in the Western United States. Eighteen Defendants Darren Kyan Dyke
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  Speaker 1: and Richard D. kN are the executors of the estate
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  Speaker 1: of Jeffrey Epstein. The estate. As executors of the estate,
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  Speaker 1: defendants In, Dyke and Khan are liable for the acts
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  Speaker 1: and omissions of Epstein and his agents for purposes of
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  Speaker 1: twenty eight US Code thirteen thirty two. Defendants In, Dyke
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  Speaker 1: and Khan are deemed to be citizens of the United
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  Speaker 1: virgin Islands, where Epstein was domiciled at the time. Of
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  Speaker 1: his death nineteen. Defendants. Sarah Vickers aka Sarah Kellen Vickers
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  Speaker 1: is an individual who, at all relevant times resided in
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  Speaker 1: New York, New York. Kellen was Epstein's assistant and scheduler, who,
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  Speaker 1: upon information and belief, played an integral role in operating
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  Speaker 1: Epstein's operation of sex trafficking Mary and other underage girls.
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  Speaker 1: Upon information and belief, Kellen is a resident of North Carolina.
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  Speaker 1: Jurisdiction and venue twenty This Court has subject matter jurisdiction
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  Speaker 1: pursuant to US Code twenty eight, Section thirteen thirty two
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  Speaker 1: because this case is between citizens of different states and
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  Speaker 1: the amount in controversy exceeds seventy five thousand dollars. Twenty
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  Speaker 1: one venue is proper in this district pursuant to twenty
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  Speaker 1: eight US Code thirteen ninety one be in two because
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  Speaker 1: a substantial part of the events or omissions given rise
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  Speaker 1: to the claim occurred in this district. Twenty two. This
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  Speaker 1: Court has personal jurisdiction over the defendants as executors of
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  Speaker 1: the estate. Defendants Endyke and conn Or subject to personal
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  Speaker 1: jurisdiction in this court because Epstein was subject to personal
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  Speaker 1: jurisdiction at the time of his death. Twenty three. This
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  Speaker 1: court had personal jurisdiction over Epstein at the time of
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  Speaker 1: his death because the tortious acts given rise to plaintiff's
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  Speaker 1: claims took place in New York State. Twenty four. This
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  Speaker 1: court has personal jurisdiction over Kellen because the tortious acts
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  Speaker 1: and omissions giving rise to plaintiff's claims took place in
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  Speaker 1: New York State. Twenty five Jerry Demand plaintiff hereby demands
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  Speaker 1: a trial by jury on all of her claims in
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  Speaker 1: this action. All right, folks, we're gonna wrap up episode
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  Speaker 1: one right here, and then we're gonna pick up an
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  Speaker 1: episode two with the factual allegations. 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 gonna get right back
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  Speaker 1: to it with claims made by Mary Dough against the
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  Speaker 1: Jeffrey Epstein Estate. Factual Allegations twenty six. Mary was born
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  Speaker 1: in nineteen eighty eight outside of the United States in
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  Speaker 1: a small town. Her grandfather was a prominent doctor and
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  Speaker 1: her parents were well educated. Twenty seven, when Mary was
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  Speaker 1: just four years old. However, the region she lived in
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  Speaker 1: descended into Civil War. Two years later, her entire town
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  Speaker 1: was bombed, shelled, and eventually evacuated. She and her family
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  Speaker 1: fled on foot, traveling through war zones in a stream
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  Speaker 1: of refugees. Twenty eight. Her family had no money and
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  Speaker 1: lived together in one room, sharing a bathroom with other families.
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  Speaker 1: Their only clothing was what was provided to them by
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  Speaker 1: the Red Cross. Because of the war torn economy, Mary's
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  Speaker 1: parents were only able to find low paying, unskilled jobs
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  Speaker 1: to survive twenty nine. Eventually, when Mary was nine years old,
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  Speaker 1: her family came to the United States as refugees. Thirty
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  Speaker 1: Mary's family settled in Missouri. Her parents resorted to working
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  Speaker 1: in the kitchen of a McDonald's. They immersed themselves in
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  Speaker 1: the American dream, working hard and becoming proud first generation Americans.
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  Speaker 1: Thirty one. When Mary was thirteen, she learned of a
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  Speaker 1: talent search for models and persuaded her mother to bring
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  Speaker 1: her to the event. Thirty two, Mary quickly found success
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  Speaker 1: as a model. Her parents were devotely Christian and were
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  Speaker 1: displeased by Mary doing that kind of work and unprepared
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  Speaker 1: to deal with a daughter thrust in the spotlight. It
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  Speaker 1: seemed unbelievable to them that their daughter could earn thousands
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  Speaker 1: of dollars just by having pictures of her taken, but
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  Speaker 1: they permitted her to keep doing so, largely because school
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  Speaker 1: counselors and family priests advised them to let Mary pursue
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  Speaker 1: this dream so long as she kept up with her
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  Speaker 1: studies while traveling thirty three. By age fifteen, Mary began
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  Speaker 1: traveling to New York City from modeling while still attending
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  Speaker 1: school in Missouri because of her immediate sexs. She moved
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  Speaker 1: there the following year at age sixteen, living in an
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  Speaker 1: apartment for models in Manhattan with one or two roommates
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  Speaker 1: but no adult on the premises. Thirty four. In New York,
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  Speaker 1: Mary had a hectic schedule for modeling work, frequently working
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  Speaker 1: eleven hour days that involved ten or twelve casting events.
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  Speaker 1: She was represented by a prominent agency and worked with
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  Speaker 1: top tier of clients. She was featured in prominent magazines
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  Speaker 1: and Harold did as a rising star in the modeling world.
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  Speaker 1: Thirty five. At casting events, Mary was often the youngest
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  Speaker 1: person surrounded by older models. She felt empowered, feeling that
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  Speaker 1: she was a big girl and that she was smarter
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  Speaker 1: than the older models and able to do what they
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  Speaker 1: did despite her young age thirty six. At the same time,
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  Speaker 1: Mary's parents distanced themselves from her as they did not
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  Speaker 1: approve of the modeling profession. Her father made it known
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  Speaker 1: to her that he did not approve of her doing
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  Speaker 1: that kind of work thirty seven. In this context, Mary
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  Speaker 1: met Jeffrey Epstein for the first time in approximately the
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  Speaker 1: summer of two thousand and four, when she was sixteen
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  Speaker 1: years old thirty eight. At one of the casting events,
• 15:09
  Speaker 1: a model who was several years older than Mary mentioned
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  Speaker 1: Epstein to Mary. The woman said that Epstein had connections
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  Speaker 1: to Victoria's Secret and told Mary that he would be
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  Speaker 1: the most interesting person that she would ever meet. Thirty nine,
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  Speaker 1: Mary made an appointment to meet Epstein at his townhouse
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  Speaker 1: at nine East seventy first Street in Manhattan forty. Mary
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  Speaker 1: did not view it as strange or concerning to go
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  Speaker 1: to Epstein's home. During that time period, it was common
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  Speaker 1: for her and other models to run around the city,
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  Speaker 1: ringing the doorbells of artists and photographers to meet with
• 15:43
  Speaker 1: them at their studios and homes. Casting calls and waiting
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  Speaker 1: around in townhouses were a normal part of the work.
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  Speaker 1: In those interactions, she had found nearly all of the
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  Speaker 1: people she met to be nice, and found that they
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  Speaker 1: were not predators and understood that she was a child.
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  Speaker 1: Forty one, when Mary rang the doorbell of Epstein's townhouse,
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  Speaker 1: a maid answered the door, but Epstein was standing right
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  Speaker 1: beside her, giving the impression that he was expecting Mary.
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  Speaker 1: Epstein seemed larger than life to Mary. Forty two, Mary
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  Speaker 1: was impressed with the grandeur of Epstein's townhouse, the ornate furnishings,
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  Speaker 1: and the numerous photographs of famous people. Forty three, Epstein
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  Speaker 1: quickly touted his connection to important people. He pointed out
• 16:27
  Speaker 1: of Mary a photo of Bill Clinton, the president who
• 16:30
  Speaker 1: made it possible for Mary and her family to come
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  Speaker 1: to the United States as refugees. Epstein told her that
• 16:36
  Speaker 1: he and President Clinton were best friends. When Mary explained
• 16:40
  Speaker 1: her family story, Epstein told her that he would personally
• 16:43
  Speaker 1: thank Bill on her and her family's behalf. Boy, that's
• 16:47
  Speaker 1: a bit embarrassing, isn't it. I wonder if anybody's ever
• 16:51
  Speaker 1: going to bring that up to Bill Clinton. I guess not.
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  Speaker 1: Forty four Epstein told her about himself, including about his
• 16:58
  Speaker 1: healthy lifestyle and that he did not do drugs or drink.
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  Speaker 1: This put her at ease and caused her to think
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  Speaker 1: I'm in good hands. Forty five, Epstein asked Mary whether
• 17:09
  Speaker 1: she had a boyfriend. Mary explained that she had never
• 17:12
  Speaker 1: dated anyone, that her family was very religious, and that
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  Speaker 1: she was saving herself for marriage. Forty six, after they conversed,
• 17:19
  Speaker 1: Epstein told Mary that he had ant in his back
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  Speaker 1: and that his massuse had not gotten it out, and
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  Speaker 1: asked if she would help get it out. Mary took
• 17:28
  Speaker 1: this to be an innocent request. She had given massages
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  Speaker 1: to her mother and father, so Epstein's request did not
• 17:33
  Speaker 1: seem strange. Forty seven, Epstein led Mary to a massage
• 17:38
  Speaker 1: room in his townhouse. He gave her a large massage
• 17:41
  Speaker 1: device to use on his back, and she did so. Afterwards,
• 17:44
  Speaker 1: Epstein told her she was an excellent messuse. He pulled
• 17:48
  Speaker 1: two or three hundred dollars bills out of his wallet
• 17:51
  Speaker 1: and gave them to Mary's saying, in substance, I was
• 17:53
  Speaker 1: going to give it to my massuse anyway, so you
• 17:56
  Speaker 1: take it and pay for your car service or something.
• 17:59
  Speaker 1: Forty eight. Afterwards, Mary felt very fortunate to have made
• 18:03
  Speaker 1: the connection with Epstein. She found him very impressive and
• 18:06
  Speaker 1: the smartest person that she had ever met. She could
• 18:10
  Speaker 1: not fathom the wealth and luxury that he had and
• 18:12
  Speaker 1: felt that she wanted to be like him. She assumed
• 18:15
  Speaker 1: she would never see Epstein again and she would move
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  Speaker 1: on with her life. Forty nine. To Mary's surprise, Epstein
• 18:22
  Speaker 1: called soon afterward, and he told her that he had
• 18:24
  Speaker 1: enjoyed talking to her, and that he was impressed at
• 18:27
  Speaker 1: how smart she was for a sixteen year old, and
• 18:29
  Speaker 1: that our life story was touching. Epstein asked Mary if
• 18:32
  Speaker 1: she would like to see him again. Fifty Mary found
• 18:36
  Speaker 1: it unbelievable that Epstein, such a smart and powerful man,
• 18:39
  Speaker 1: was impressed by her. She was thrilled at the successful
• 18:42
  Speaker 1: track her life appeared to be taking. She believed that
• 18:45
  Speaker 1: if she stuck by Epstein, she would be in good hands.
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  Speaker 1: Fifty one. When Mary went to Epstein's townhouse a second time,
• 18:52
  Speaker 1: Epstein discussed his connections with Victoria's secret and said he
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  Speaker 1: would put in a good word for Mary. Fifty two.
• 18:59
  Speaker 1: When Mary Mary conversed with Epstein, she felt like she
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  Speaker 1: was in the presence of someone who was powerful and perfect.
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  Speaker 1: She saw that he had the ability to reach down
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  Speaker 1: from his powerful position and influence the people directly involved
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  Speaker 1: with Mary's daily life and her future prosperity. Fifty three,
• 19:18
  Speaker 1: Epstein made a point of calling massive celebrities such as
• 19:22
  Speaker 1: an oscar winning actress and world famous supermodel on a
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  Speaker 1: speakerphone in Mary's presence to show her the tremendous influence
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  Speaker 1: that he had. Those two famous women did pick up
• 19:32
  Speaker 1: the phone and talk to Epstein when he called them.
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  Speaker 1: They plainly also thought he was impressive and important. Fifty four,
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  Speaker 1: Mary told Epstein about her parents being upset that she
• 19:44
  Speaker 1: was pursuing modeling, and explained that it was their dream
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  Speaker 1: for Mary to attend a prestigious college. Epstein told Mary
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  Speaker 1: that he was on the board of directors at Harvard University.
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  Speaker 1: He promised her that if she did well on her SATs,
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  Speaker 1: he would write her a letter of recommendation for Harvard,
• 20:01
  Speaker 1: which he said would carry significant weight in the admission decision.
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  Speaker 1: Fifty five Mary strongly desired for her parents to be
• 20:08
  Speaker 1: proud of her. Accordingly, Epstein's assurance that he could help
• 20:12
  Speaker 1: her get into Harvard was deeply meaningful to her. Fifty six,
• 20:17
  Speaker 1: Epstein brought Mary back to the massage room. He asked
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  Speaker 1: her to get on top of him and to take
• 20:22
  Speaker 1: her shirt off. Epstein instructed Mary to massage them, which
• 20:25
  Speaker 1: he did. She had never done anything like this before,
• 20:28
  Speaker 1: but also felt that this older man, who had spent
• 20:31
  Speaker 1: so much time with her and had promised her access
• 20:33
  Speaker 1: to everything she wanted, with someone she could not disappoint.
• 20:38
  Speaker 1: Fifty seven. Afterwards, Epstein again gave her two hundred dollars
• 20:42
  Speaker 1: and she left. Fifty eight. The third time Mary went
• 20:45
  Speaker 1: to Epstein's townhouse, Epstein brought her to the massage room
• 20:49
  Speaker 1: and pressed the massage device against her genitals. Mary had
• 20:53
  Speaker 1: lived a chase life, and Epstein's conduct made her feel
• 20:56
  Speaker 1: ashamed and embarrassed. Mary vividly remembered looking up at the
• 21:01
  Speaker 1: dome ceiling of the massage room, painted with clouds and
• 21:04
  Speaker 1: feeling claustrophobic. Fifty nine, Epstein aggressively ordered Mary to masturbate
• 21:10
  Speaker 1: him in a forceful manner. He barked commands at Mary
• 21:13
  Speaker 1: to stroke his penis and to play with his nipples.
• 21:16
  Speaker 1: Sixty Afterwards, Epstein gave her three hundred dollars and left.
• 21:20
  Speaker 1: Sixty one. Epstein's pattern of abuse continued. Epstein would tell
• 21:24
  Speaker 1: Mary to come to his townhouse, order her to strip
• 21:27
  Speaker 1: down in massage them, and sexually abuse her. At the
• 21:30
  Speaker 1: end of each massage, Epstein would ejaculate while Mary touched them.
• 21:34
  Speaker 1: Epstein would then tell her what a good girl she
• 21:36
  Speaker 1: is and that he loved her and that he would
• 21:38
  Speaker 1: call her later. Each time, Epstein would give her two
• 21:41
  Speaker 1: to three hundred dollars bills sixty two. Epstein acted as
• 21:45
  Speaker 1: if he was Merry's sexual teacher, guiding her sexual awakening.
• 21:49
  Speaker 1: Mary experienced sexual feelings for the first time, but they
• 21:52
  Speaker 1: were intertwined with the men's shame and deep seated fear
• 21:56
  Speaker 1: sixty three. Epstein escalated his second abuse over time. During
• 22:02
  Speaker 1: one of Mary's visits to his townhouse in approximately mid
• 22:06
  Speaker 1: two thousand and four, Epstein forced his penis into her
• 22:09
  Speaker 1: mouth and forced her to perform oral sex on him
• 22:12
  Speaker 1: in a very aggressive manner. Mary choked and gagged, not
• 22:16
  Speaker 1: knowing what to do, but when she tried to move
• 22:18
  Speaker 1: her head away from Epstein's penis, he forced it back
• 22:21
  Speaker 1: into place sixty four. Afterwards, Epstein told her how amazing
• 22:26
  Speaker 1: she was, and he gave her two hundred dollars sixty five.
• 22:29
  Speaker 1: As time went on, Mary's relationship with her parents remained
• 22:33
  Speaker 1: distant due to their objection of her career choices. Epstein
• 22:36
  Speaker 1: became the only adult presence in her life. Epstein began
• 22:40
  Speaker 1: calling Mary constantly, whether she was in New York or traveling.
• 22:44
  Speaker 1: He told her that he loved her. Mary continued to
• 22:47
  Speaker 1: have arduous schedule of modeling events, and as a child,
• 22:50
  Speaker 1: she perceived Epstein's daily check up as giving her emotional
• 22:54
  Speaker 1: support that she did not otherwise have. Sixty six, Epstein
• 23:00
  Speaker 1: told Mary about the island he owned in the Virgin Islands,
• 23:03
  Speaker 1: and he made repeated attempts to fly her to the
• 23:06
  Speaker 1: Virgin Islands to meet people he assured her were very
• 23:09
  Speaker 1: influential and would help her with her future. Epstein told
• 23:13
  Speaker 1: Mary that she should be willing to give other people
• 23:15
  Speaker 1: massages as well. Sixty seven, Epstein invited Mary to stay
• 23:21
  Speaker 1: at his home in Paris and arrange for her to
• 23:23
  Speaker 1: attend a concert accompanied by a world famous supermodel. Sixty eight.
• 23:28
  Speaker 1: Epstein had manipulated Mary into believing that Epstein's thoughts were
• 23:32
  Speaker 1: focused on her career and her future sixty nine. At
• 23:36
  Speaker 1: the same time, Epstein made sure Mary understood his power
• 23:39
  Speaker 1: over her. If she was ever late to meet him,
• 23:41
  Speaker 1: He would tell her that nobody messes with his time
• 23:44
  Speaker 1: and that she could lose everything. When Mary told Epstein
• 23:47
  Speaker 1: she needed to leave her modeling commitments, he often demanded
• 23:50
  Speaker 1: that she stay, telling her things like I could buy
• 23:53
  Speaker 1: her agency today, you can miss that appointment seventy Epstein
• 23:58
  Speaker 1: continued to train Mary to be submissive to and to
• 24:00
  Speaker 1: submit to his orders seventy one. Anytime Mary failed to
• 24:04
  Speaker 1: do exactly what Epstein commanded of her, Epstein threatened her
• 24:08
  Speaker 1: and verbally beraided her. On one occasion, when Mary failed
• 24:11
  Speaker 1: to show up precisely when Epstein had asked her to,
• 24:14
  Speaker 1: he reacted with anger, telling her in substance, how dare you?
• 24:18
  Speaker 1: I could make you disappear. I could destroy you. I
• 24:20
  Speaker 1: own this city seventy two. Mary believed that was true,
• 24:24
  Speaker 1: that Epstein could make her disappear. She felt the total
• 24:28
  Speaker 1: control to help her dreams come true or to make
• 24:31
  Speaker 1: them disappear. Seventy three. Epstein's drets terrified Mary. She made
• 24:36
  Speaker 1: sure to stay in line and not to disobey him
• 24:39
  Speaker 1: seventy four. When Mary talked back, Epstein would belittle her
• 24:43
  Speaker 1: and scrutinize her appearance. At one point Epstein critiqued Mary's body,
• 24:48
  Speaker 1: telling her that her legs were too big. Epstein went
• 24:51
  Speaker 1: so far as to send Mary to a plastic surgeon,
• 24:53
  Speaker 1: who declined to perform the procedure's honor seventy five. On
• 24:58
  Speaker 1: one occasion, Epstein had Mary Mary sit on his lap
• 25:01
  Speaker 1: and yelled at her, saying, in substance, we need to
• 25:03
  Speaker 1: teach you how to please a man. Seventy six, Epstein
• 25:07
  Speaker 1: wrote Mary and penetrated her vagina with his fingers. Seventy seven.
• 25:12
  Speaker 1: Epstein forced Mary to perform oral sex on him on
• 25:15
  Speaker 1: a number of other occasions. Epstein got very aggressive as
• 25:19
  Speaker 1: he did so, holding Mary's head down on his penis
• 25:22
  Speaker 1: and giving her constant orders for how to please him.
• 25:25
  Speaker 1: Seventy eight. Mary saw Epstein numerous times from the summer
• 25:30
  Speaker 1: of two thousand and four until the end of two
• 25:32
  Speaker 1: thousand and five. These meetings were often arranged by calls
• 25:35
  Speaker 1: from Epstein himself seventy nine. On numerous other occasions, defendant
• 25:40
  Speaker 1: Sarah Vickers called Mary in scheduled deployments between Mary and Epstein.
• 25:45
  Speaker 1: Eighty Mary first met Kellen approximately in early two thousand
• 25:49
  Speaker 1: and five, when Mary was approximately sixteen years old. Eighty one,
• 25:54
  Speaker 1: Upon information and belief, Kellen knew that Epstein engaged in
• 25:58
  Speaker 1: numerous sexual acts with Mary when Mary was a miner.
• 26:01
  Speaker 1: Eighty two. When Kellen called Mary to arrange meetings between
• 26:05
  Speaker 1: Mary and Epstein, Kellen referred to them as massage appointments.
• 26:10
  Speaker 1: Upon information and belief, Kellen knew that Epstein would engage
• 26:13
  Speaker 1: in sexual acts with Mary, a minor, at some or
• 26:16
  Speaker 1: all of these massage appointments at the time Kellen arranged
• 26:20
  Speaker 1: those meetings. Eighty three, while Mary was traveling, Kellen wired
• 26:24
  Speaker 1: money tour in order to facilitate further encounters between Mary
• 26:28
  Speaker 1: and Epstein. Eighty four. Upon information and belief, Kellen was
• 26:33
  Speaker 1: an integral part of Epstein's child sex trafficking operation. Eighty five.
• 26:38
  Speaker 1: Upon information and belief, Kellen engaged in a long pattern
• 26:42
  Speaker 1: of actions aimed at recruiting underage girls for Epstein to
• 26:45
  Speaker 1: use for sexual purposes and to facilitate sexual encounters between
• 26:50
  Speaker 1: underage girls and Epstein. Eighty six. Upon information and belief,
• 26:55
  Speaker 1: Kellen kept a rolodex that included numerous underage girls for
• 26:59
  Speaker 1: Epstein to use for sexual purposes. Eighty seven. Upon information
• 27:04
  Speaker 1: and belief, Kellen Warren numerous underage girls who had been
• 27:08
  Speaker 1: sexually abused by Epstein to not talk to the police,
• 27:11
  Speaker 1: causing them to feel intimidated and frightened. Eighty eight. Kellen
• 27:16
  Speaker 1: was often present in the townhouse when Mary came there.
• 27:19
  Speaker 1: Mary frequently observed Kellen at Epstein's side, and Kellen often
• 27:24
  Speaker 1: observed Mary going in and out of the massage room.
• 27:27
  Speaker 1: Eighty nine. On one occasion, Epstein violently forced Mary to
• 27:32
  Speaker 1: perform oral sex on him in a hallway in the townhouse.
• 27:35
  Speaker 1: Kellen walked into the area and witnessed the sexual act,
• 27:39
  Speaker 1: then quickly walked away. Minutes later, Mary heard Epstein gleefully
• 27:43
  Speaker 1: comment to Kellen in crude terms that Mary was the
• 27:46
  Speaker 1: best at performing oral sex. Mary was incredibly embarrassed and thought,
• 27:51
  Speaker 1: that's not me. I don't want to be presented this way.
• 27:54
  Speaker 1: Ninety On another occasion, in Mary's presence, Epstein instructed Kellen
• 27:59
  Speaker 1: to a range for a new underwear to be purchased
• 28:01
  Speaker 1: for Mary from Victoria's secret. Just minutes later, the new
• 28:05
  Speaker 1: underwear arrived and Kellen handed it to Epstein. Immediately after
• 28:09
  Speaker 1: Kellen left, Epstein ordered Mary to strip down to try
• 28:13
  Speaker 1: the underwear on, and she obeyed. Epstein then took photographs
• 28:17
  Speaker 1: of Mary in the underwear ninety one. One day in
• 28:21
  Speaker 1: approximately late two thousand and four, when Mary was sixteen
• 28:24
  Speaker 1: years old, Epstein raped her. Mary went to Epstein's townhouse
• 28:28
  Speaker 1: that day, and Epstein was angry with her. He ordered
• 28:31
  Speaker 1: her to strip down and shower, telling her that she
• 28:33
  Speaker 1: did not smell good. Epstein washed Mary's entire body compulsively,
• 28:38
  Speaker 1: and then angrily told her in substance, if you're lying
• 28:40
  Speaker 1: to me about being a virgin, I will have you killed.
• 28:44
  Speaker 1: Mary believed the threat to be true. Ninety two, after
• 28:47
  Speaker 1: Mary showered, Epstein forcibly penetrated her vagina with his penis
• 28:53
  Speaker 1: and took her virginity. While Epstein raped her and Mary
• 28:56
  Speaker 1: felt numb, she felt her mind separate from her body.
• 29:00
  Speaker 1: Mary protested, but Epstein forced her face into the bed
• 29:03
  Speaker 1: to stifle her cries. Ninety three Afterwards, Epstein gave Mary
• 29:08
  Speaker 1: two hundred dollars and let her out of the townhouse,
• 29:11
  Speaker 1: assuring her, as he had many other times, that she
• 29:14
  Speaker 1: was on the right path under his guidance. Epstein told
• 29:17
  Speaker 1: Mary that he loved her and said, don't fuck it up.
• 29:21
  Speaker 1: Ninety four. Throughout two thousand and five, Epstein continued to
• 29:24
  Speaker 1: exercise tremendous control over Mary's life. Ninety five. In the
• 29:29
  Speaker 1: spring of two thousand and five, when Mary was seventeen
• 29:32
  Speaker 1: years old, Epstein arranged for Mary to stay in an
• 29:35
  Speaker 1: apartment in one of his Upper East Side of Manhattan,
• 29:38
  Speaker 1: close to his townhouse. Ninety six. One day around Thanksgiving
• 29:42
  Speaker 1: two thousand and five, when Mary was seventeen years old,
• 29:45
  Speaker 1: Mary again went to Epstein's townhouse, this time for the
• 29:48
  Speaker 1: final time. As he had many times before, Epstein has
• 29:52
  Speaker 1: sexually assaulted her. He then gave her a few hundred dollars.
• 29:55
  Speaker 1: After he did so, he shouted out disparaging and demeaning
• 29:59
  Speaker 1: remarks about her to Kellen, saying that she had performed well.
• 30:03
  Speaker 1: Mary felt deep shame. Ninety seven. As Mary walked out
• 30:08
  Speaker 1: of the townhouse and onto the street, she saw another
• 30:10
  Speaker 1: young girl walk by and go into the townhouse. Ninety eight.
• 30:15
  Speaker 1: At that moment, Mary's world shattered. Epstein had made himself
• 30:19
  Speaker 1: the center of her young existence, masking himself as a parental,
• 30:23
  Speaker 1: substitute and mentor who had her best interests in mind.
• 30:27
  Speaker 1: She realized that Epstein was paying for her sexual acts
• 30:31
  Speaker 1: and that she was just one of many young girls
• 30:33
  Speaker 1: Epstein had in rotation for his use as sexual objects.
• 30:38
  Speaker 1: She felt that she was no longer a human being.
• 30:41
  Speaker 1: Ninety nine, Mary effectively had a nervous breakdown. She was humiliated, angry,
• 30:46
  Speaker 1: and suicidal. She felt immense desolation. She found herself crying, inconsolably, shaking,
• 30:53
  Speaker 1: and hyperventilating. One hundred Mary found herself unable to go
• 30:58
  Speaker 1: to casting events or meetings. She locked herself away from everything.
• 31:02
  Speaker 1: One oh one. Mary was desperate to escape circumstances Epstein
• 31:07
  Speaker 1: had her living in, but she needed Epstein's permission to
• 31:10
  Speaker 1: leave New York. She asked Epstein to let her visit
• 31:13
  Speaker 1: her parents in the Midwest for her mother's birthday. Epstein
• 31:16
  Speaker 1: agreed to let Mary go, but only if she returned
• 31:19
  Speaker 1: immediately after. Epstein made sure to have his close associates
• 31:24
  Speaker 1: purchase a round trip ticket for Mary. But once Mary
• 31:27
  Speaker 1: left New York, she never went back, even though she
• 31:30
  Speaker 1: had significant jobs lined up and was burning professional bridges
• 31:33
  Speaker 1: and giving up her modeling career by going to the Midwest.
• 31:37
  Speaker 1: One oh two. Epstein and his agents continued to contact Mary,
• 31:41
  Speaker 1: but she refused to go back. Near the end of
• 31:43
  Speaker 1: two thousand and five, Epstein tracked down the home phone
• 31:46
  Speaker 1: number for Mary's parents and called. Mary's mother answered the phone,
• 31:51
  Speaker 1: told Epstein that he should go out with women his
• 31:54
  Speaker 1: own age, and told her she was going to call
• 31:57
  Speaker 1: the police. At the same time, Mary aimed extremely frightened
• 32:01
  Speaker 1: of all of Epstein's power and threats, and would never
• 32:04
  Speaker 1: let her parents call the police. One o three. In
• 32:08
  Speaker 1: the subsequent months, Mary became chronically depressed. She had severe anxiety,
• 32:13
  Speaker 1: She had frequent suicidal ideations. She felt debilitating nausea and
• 32:17
  Speaker 1: stomach pain. She felt dead inside, unable to connect with anyone,
• 32:22
  Speaker 1: She numbed herself and tried to bury the pain and
• 32:25
  Speaker 1: avoid dealing with what had happened. One o four, Mary
• 32:29
  Speaker 1: abruptly stopped modeling, given up the lucrative career in which
• 32:32
  Speaker 1: she was a rising star and which she had given
• 32:35
  Speaker 1: up so much. She stopped pursuing or attending modeling appointments,
• 32:39
  Speaker 1: ruining the momentum of her career and causing her irreparably
• 32:43
  Speaker 1: to lose connections with top agencies and clients in the industry,
• 32:47
  Speaker 1: even when she finally returned to modeling years later one
• 32:50
  Speaker 1: oh five. The sexual abuse that Epstein inflicted on Mary
• 32:54
  Speaker 1: left permanent psychological scars. She remained plagued with self doubt, insecurity,
• 33:00
  Speaker 1: and despair. She often has difficulties sleeping. She has struggled
• 33:04
  Speaker 1: to build healthy relationships, as she finds it nearly impossible
• 33:08
  Speaker 1: to separate memories of Epstein's manipulation and abuse from new
• 33:12
  Speaker 1: relationships that she tries to develop. One O six. When
• 33:17
  Speaker 1: Epstein was arrested in July twenty nineteen, Mary was briefly
• 33:21
  Speaker 1: hopeful that he might face justice, but the worldwide publicity
• 33:25
  Speaker 1: that he subsequently received only deepened her despair. Epstein's death
• 33:30
  Speaker 1: left Mary with a desolate sense that he has managed
• 33:33
  Speaker 1: to evade justice yet again. She desperately wants some measure
• 33:37
  Speaker 1: of justice for herself and all of Epstein's other underage victims.
• 33:41
  Speaker 1: One O seven. This action is timely because it falls
• 33:45
  Speaker 1: within the New York CPLR Two fourteen G and is
• 33:49
  Speaker 1: brought during the one year time period set forth in
• 33:52
  Speaker 1: that section. The claims brought herein alleged intentional and negligent
• 33:57
  Speaker 1: acts and or omissions for physical, psychological, and other injuries
• 34:01
  Speaker 1: suffered as a result of conduct that would constitute sexual
• 34:05
  Speaker 1: offenses as defined in Article one thirty of the New
• 34:08
  Speaker 1: York penal law, and such acts and or omissions were
• 34:11
  Speaker 1: committed against Mary when she was less than eighteen years
• 34:15
  Speaker 1: of age. First cause of action Battery one o eight.
• 34:19
  Speaker 1: Plaintiff hereby incorporates each of the foregoing paragraphs as if
• 34:23
  Speaker 1: fully set forth herein one oh nine. In committing the
• 34:27
  Speaker 1: acts described above, Epstein intentionally subjected Mary to bodily contact
• 34:32
  Speaker 1: that was offensive in nature. One ten. Kellen is liable
• 34:37
  Speaker 1: for aiding and abetting Epstein's actions one eleven. Upon information
• 34:41
  Speaker 1: and belief, Kellen knowingly provided substantial assistance to Epstein and
• 34:46
  Speaker 1: Epstein's tortious actions against Mary. One twelve Upon information and belief,
• 34:52
  Speaker 1: Kellen was aware at the time that she was playing
• 34:55
  Speaker 1: a role in overall illegal, end or tortious activity by Epstein.
• 35:00
  Speaker 1: One thirteen. As a result of Epstein and Kellen's actions,
• 35:04
  Speaker 1: Mary suffered damages in an amount to be determined at trial.
• 35:08
  Speaker 1: Second cause of action Assault one fourteen. Plaintiff hereby incorporates
• 35:13
  Speaker 1: each of the foregoing paragraphs as I fully set forth
• 35:16
  Speaker 1: herein one fifteen. In committing the acts described above, Epstein
• 35:21
  Speaker 1: engaged in physical conduct that plays Mary in eminent apprehension
• 35:25
  Speaker 1: that he would harmor one sixteen. Kellen is liable for
• 35:29
  Speaker 1: aiding and abetting Epstein's actions one seventeen. Upon information and belief,
• 35:34
  Speaker 1: Kellen knowingly provided substantial assistance to Epstein and Epstein's tortious
• 35:39
  Speaker 1: actions against Mary one eighteen. Upon information and belief, Kellen
• 35:44
  Speaker 1: was aware at the time that she was playing a
• 35:46
  Speaker 1: role in overall illegal and tortious activity by Epstein. One nineteen.
• 35:51
  Speaker 1: As a result of Epstein and Kellen's actions, Mary suffered
• 35:55
  Speaker 1: damages in an amount to be determined at trial. Third
• 35:59
  Speaker 1: cause of action intentional infliction of emotional distress one twenty
• 36:04
  Speaker 1: Plaintiff hereby incorporates each of the foregoing paragraphs as if
• 36:08
  Speaker 1: fully set forth herein one twenty one. In committing the
• 36:12
  Speaker 1: acts described above, Epstein and Kellen engaged in extreme and
• 36:16
  Speaker 1: outrageous conduct one twenty two. In doing so, Epstein and
• 36:20
  Speaker 1: Kellen acted with the intent to cause and lor disregard
• 36:23
  Speaker 1: of substantial likelihood of causing Mary to suffer severe emotional distress.
• 36:28
  Speaker 1: One twenty three. As a direct result of Epstein and
• 36:31
  Speaker 1: Kellen's actions, Mary suffered severe emotional distress one twenty four.
• 36:37
  Speaker 1: Kellen is likewise liable for aiding and abetting Epstein's actions
• 36:41
  Speaker 1: one twenty five, upon information and belief, Kellen knowingly provided
• 36:46
  Speaker 1: substantial assistance to Epstein and Epstein's tortious actions against Mary
• 36:50
  Speaker 1: one twenty six upon information and belief, Kellen was aware
• 36:54
  Speaker 1: at the time that she was playing a role in
• 36:57
  Speaker 1: overall illegal and tortious activity by Epstein. One seven. As
• 37:02
  Speaker 1: a result of Epstein and Kellen's actions, Mary suffered damages
• 37:06
  Speaker 1: in an amount to be determined at trial. Wherefore, Plaintiff
• 37:11
  Speaker 1: respectfully requests that judgment be entered against the defendants as follows.
• 37:15
  Speaker 1: A Awarding compensentory damages for all physical injuries, emotional distress,
• 37:20
  Speaker 1: psychological harm, anxiety, humiliation, physical and emotional pain and suffering,
• 37:26
  Speaker 1: family and social disruption, and other harm in an amount
• 37:29
  Speaker 1: to be determined at trial. B Awarding punitive damages in
• 37:33
  Speaker 1: an amount to be determined at trial. C Awarding attorney
• 37:37
  Speaker 1: fees and cost pursuant to any applicable statute or law.
• 37:41
  Speaker 1: D Awarding pre and post judgment interest on all such damages, fees,
• 37:46
  Speaker 1: and or costs. See Attaching all defendants real property and
• 37:50
  Speaker 1: other assets located in the State of New York pursuant
• 37:53
  Speaker 1: to New York's cpl R. Sixty two oh one and
• 37:57
  Speaker 1: Federal Rule of Civil Procedure sixty four and f awarding
• 38:01
  Speaker 1: such other and further relief as this Court may deem
• 38:04
  Speaker 1: just and proper. This was signed by Mary Anne Meyer Wang,
• 38:09
  Speaker 1: and it was signed on November twentieth of twenty nineteen.
• 38:13
  Speaker 1: All Right, folks, that's gonna do it for this one.
• 38:15
  Speaker 1: All of the information that goes with this episode can
• 38:18
  Speaker 1: be found in the description box.