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Transcript

Mega Edition: Jane Doe 17 And Her Allegations Made Against Jeffrey Epstein (8/2/26) · The Epstein Chronicles

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  Speaker 1: What's up everyone, and welcome back to the Epstein Chronicles.
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  Speaker 1: In this episode, we're going to hear the allegations from
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  Speaker 1: Jane Doe number seventeen, and we're going to keep the
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  Speaker 1: discuss bus rolling. The complaint. Plaintiff Jane Doe seventeen buy
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  Speaker 1: and through the undersigned Council in support of her claims
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  Speaker 1: against defendant alleges and states as follows. One, This action
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  Speaker 1: is brought inter ally a pursuant to common law, statutory law,
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  Speaker 1: and US Code eighteen section fifteen ninety one and fifteen
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  Speaker 1: ninety five. Therefore, jurisdiction is proper under US Code twenty
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  Speaker 1: eight thirteen thirty one, and the damages sought exceed the
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  Speaker 1: jurisdictional requirements of this Court. Two Plaintiff files this complaint
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  Speaker 1: under a pseudonym in order to protect her identity, because
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  Speaker 1: the complaint makes allegations of a sensitive sexual nature, the
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  Speaker 1: disclosure of which, in association with her name, would further
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  Speaker 1: cause her harm. Three Plaintiff is currently resident and domiciled
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  Speaker 1: in the state of Florida and over the age of
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  Speaker 1: eighteen four. At all times material, Jeffrey Epstein was a
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  Speaker 1: citizen of the United States and resident of the US
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  Speaker 1: Virgin Islands. Epstein was a man of extreme wealth who
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  Speaker 1: frequently traveled between and regularly stayed in his numerous residences,
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  Speaker 1: including in New York within the Southern District of New
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  Speaker 1: York at nine East seventy first Street, New York, New York.
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  Speaker 1: In pom Beach, Florida at three fifty eight l Brio Way,
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  Speaker 1: pom Beach, Florida, in New Mexico at forty nine Zora
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  Speaker 1: Ranch Road, Stanley, New Mexico, in Paris, France at twenty
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  Speaker 1: two Avenue Fought, Paris, France, and in the United States
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  Speaker 1: Virgin Islands at Little Saint James Island, number five. At
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  Speaker 1: all times material to this cause of action. Epstein was
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  Speaker 1: an adult male born on January twentieth, nineteen fifty three,
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  Speaker 1: who died on August tenth, twenty nineteen six. Defendant Darren
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  Speaker 1: Ky and Richard D. Con as joint personal representatives of
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  Speaker 1: the Estate of Jeffrey e Epstein. A State of Jeffrey
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  Speaker 1: e Epstein was opened and domiciled in the United States
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  Speaker 1: Virgin Islands, Saint Thomas Division, and is the legal entity
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  Speaker 1: responsible for intentional, criminal, or tortious conduct committed by Epstein
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  Speaker 1: as described in this complaint seven. At all times material
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  Speaker 1: here too. Defendant ninety seventy first Street Corporation was a
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  Speaker 1: domestic business corporation conducting business in New York, with its
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  Speaker 1: principal place of business located at five seventy five Lexington,
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  Speaker 1: fourth Floor, New York eight. At all times material here too.
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  Speaker 1: Defendant Laurel Incorporated was and is the US Virgin Islands
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  Speaker 1: corporation conducting business in multiple locations, including New York and
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  Speaker 1: Florida number nine. At all times material here too. Defendant
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  Speaker 1: Financial Trust Company Incorporated was and it is the US
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  Speaker 1: Virgin Islands corporation conducting business in multiple locations, including New
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  Speaker 1: York number ten. At all times material here too. Defendant
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  Speaker 1: nes LLC nes was and is a domestic limited liability
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  Speaker 1: company registered in and conducting business in multiple locations, including
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  Speaker 1: New York eleven at all times material here too. Defendant
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  Speaker 1: Maple Incorporated was and is a US Virgin Island corporation
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  Speaker 1: conducting business in New York number twelve. At all times
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  Speaker 1: material here too. Lsje LLC LSJ was and is a
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  Speaker 1: US Virgin Islands corporation conducting business in the United States
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  Speaker 1: Virgin Islands conducting business in New York thirteen at all
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  Speaker 1: times material here too. Defendant HBRK Associates was and is
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  Speaker 1: a domestic business corporation registered in and conducting business and
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  Speaker 1: multiple locations, including New York, with a registered agent located
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  Speaker 1: at thirteen sixty five York Avenue, Apartment twenty eight, New
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  Speaker 1: York fifteen. At all times material here too. Defendant Cypress
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  Speaker 1: Incorporated was and is the US Virgin Islands corporation conducting
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  Speaker 1: business in New York and New Mexico sixteen at all
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  Speaker 1: times material here too. Defendant Jege Incorporated is the US
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  Speaker 1: Virgin Islands corporation conducting business throughout the United States of America,
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  Speaker 1: including but not limited to Florida, New York, and the
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  Speaker 1: Virgin Islands, United States. Seventeen Corporate defendants nine East Laurel
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  Speaker 1: Financial Trust, NES maple Ls, je HBRK, Jege, Nautilus, and Cypress,
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  Speaker 1: referred to as corporate defendants, each performed business in whole
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  Speaker 1: or in part in New York eighteen. Plaintiff intends to
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  Speaker 1: amend this complaint to add or substitute additional parties as
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  Speaker 1: discovery reveals the identity of other tortious corporate or individual
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  Speaker 1: actors nineteen. Epstein, the leader of a complex commercial sex
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  Speaker 1: trafficking and abuse ring, was an officer, director, or employee
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  Speaker 1: of many corporate entities registered in various states throughout the
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  Speaker 1: United States, one or more of which may also be
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  Speaker 1: legally responsible for the crimes and torts he committed against
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  Speaker 1: young females, including Plaintiff twenty Additionally, individuals who worked at
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  Speaker 1: the residences where sexual crime acts were committed, or friends
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  Speaker 1: or acquaintances who assisted Epstein in committing such violations, or
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  Speaker 1: those of his wealthy, famous, or socially powerful friends with
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  Speaker 1: whom Epstein caused Plaintiff to be sexually abused by, or
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  Speaker 1: those who were employed, through, or worked for numerous other
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  Speaker 1: corporate entities whose participation caused or contributed to causing the
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  Speaker 1: sexual violations that caused arm to plaintiff may additionally be
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  Speaker 1: added as defendants twenty one. A substantial part of the acts, events,
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  Speaker 1: and omissions giving rise to this cause of action occurred
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  Speaker 1: in the Southern District of New York. Venue is proper
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  Speaker 1: in this district according to US Code twenty eight thirteen
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  Speaker 1: ninety one B two twenty two. At all times material
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  Speaker 1: to this cause of action Epstein legally represented now through
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  Speaker 1: Darren k Endyke and Richard D. Con as joint personal
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  Speaker 1: representatives of the Estate of Jeffrey e Epstein, referred to
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  Speaker 1: herein as a state of Jeffrey e Epstein and corporate
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  Speaker 1: defendants owe a duty to plaintiff to treat her in
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  Speaker 1: a non negligent manner and not to commit or conspire
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  Speaker 1: to commit, or cause to be committed intentional, criminal, fraudulent,
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  Speaker 1: or tortious acts against plaintiff, including any acts that would
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  Speaker 1: cause plaintiff to be harmed through conduct committed against her
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  Speaker 1: in violation of common law battery New York Penal Code
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  Speaker 1: Section one thirty dot twenty or New York Penal Law
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  Speaker 1: Section one thirty dot thirty five or New York Penal
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  Speaker 1: Law Section three thirty dot five zero or New York
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  Speaker 1: Penal Law one thirty dot five to two or New
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  Speaker 1: York Penal Law one thirty dot sixty six, any violation
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  Speaker 1: of US Code eighteen, Section fifteen ninety one or section
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  Speaker 1: fifteen ninety five the factual allegations twenty three at all
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  Speaker 1: times material to this cause of action. Epstein was an
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  Speaker 1: adult male over forty five years old. Epstein was a
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  Speaker 1: tremendously wealthy individual widely recognized as a billionaire, who used
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  Speaker 1: his wealth, power, resources, and connections to commit illlegal sexual
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  Speaker 1: crimes in violation of federal and state laws, and who
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  Speaker 1: employed or conspired with other individuals and corporate entities to
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  Speaker 1: assist them in committing those crimes or torts, or who
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  Speaker 1: facilitated or enabled those acts to occur. Twenty four. Epstein
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  Speaker 1: displayed enormous wealth power and influence to his employees, to
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  Speaker 1: the employees of the corporate or company entities who worked
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  Speaker 1: at his direction, to the victims pro cured for sexual purposes,
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  Speaker 1: and to the public in order to advance, carry out,
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  Speaker 1: and conceal his crimes and torts twenty five. At all
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  Speaker 1: relevant times, Epstein had access to numerous mansions, as well
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  Speaker 1: as a fleet of airplanes, motor vehicles, boats, and one
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  Speaker 1: or more helicopters. For example, he regularly traveled by private
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  Speaker 1: jet aboard a Boeing Aircraft of making model B seven
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  Speaker 1: twenty seven thirty one H with a tail number of
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  Speaker 1: N nine zero eight JE or a Gulfstream Jet of
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  Speaker 1: making model G eleven five nine B with tail number
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  Speaker 1: N nine oh nine JE. Twenty six. Epstein also inhabited
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  Speaker 1: and frequently traveled between numerous properties and homes, each of
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  Speaker 1: which he admitted to being owned or controlled by them,
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  Speaker 1: including a Manhattan town home located at nine e seventy
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  Speaker 1: first Street, New York, valued conservatively by Epstein's own admission
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  Speaker 1: at fifty five million, nine hundred and thirty one thousand dollars,
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  Speaker 1: but valued by the US Attorney's Office for this district
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  Speaker 1: at seventy seven million. A ranch located at forty nine
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  Speaker 1: Zoro Ranch Road in Stanley, New Mexico, valued conservatively by
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  Speaker 1: Epstein's own admission at seventeen million, two hundred and forty
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  Speaker 1: six thousand, two hundred and eight dollars. Home located at
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  Speaker 1: three fifty eight lbri O Way, Palm Beach, Florida, valued
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  Speaker 1: conservatively by Epstein's own admission at twelve million, three hundred
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  Speaker 1: and eighty thousand, two hundred and nine dollars. An apartment
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  Speaker 1: located at twenty two Avenue Foch, Paris, France, valued conservatively
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  Speaker 1: by Epstein's own admission at eight million, six hundred and
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  Speaker 1: seventy two thousand, eight hundred and twenty dollars. An island
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  Speaker 1: located at Great Saint James Island number six A USVII
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  Speaker 1: zero zero eight zero two parcels A, B and C,
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  Speaker 1: and An Island, Little Saint James Island number six B
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  Speaker 1: USVII zero zero eight zero two parcels A, B and C.
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  Speaker 1: See Jeffrey Epstein Asset Summary June thirtieth, two thousand, nineteen,
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  Speaker 1: filed in Case number one nineteen dash cr DASH zero
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  Speaker 1: zero four to nine zero dash RMB on July fifteenth,
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  Speaker 1: twenty nineteen twenty seven. Epstein controlled or was affiliated with
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  Speaker 1: the corporation or business entities that owned, managed, or maintained
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  Speaker 1: each of the real properties listed in the preceding paragraph
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  Speaker 1: and numerated in Exhibit A twenty eight. The allegations here
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  Speaker 1: in concerned Epstein's tortious conduct committed against plaintiff while that
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  Speaker 1: the residence is owned by defendant nine East, New York,
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  Speaker 1: defendant Laurel in Florida, Defendant Cyprus in New Mexico, and
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  Speaker 1: defendant's LSJE and Nautilus in the US Virgin Islands. Many
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  Speaker 1: such acts were facilitated by defendant nes or, defendant HBRK
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  Speaker 1: or defendant JEGE twenty nine. Epstein had a compulsive sexual
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  Speaker 1: preference for young females as young as fourteen years old,
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  Speaker 1: and acted on that sexual preference for decades. Thirty Epstein
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  Speaker 1: enjoyed sexual contact with young females, including minor children, and
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  Speaker 1: also took pleasure corrupting vulnerable and innocent young females, including
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  Speaker 1: minor children, into engaging in sexual acts with them. Thirty one.
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  Speaker 1: Epstein directed a complex system of individuals, including employees and
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  Speaker 1: associates of defendants entities, to work in concert and that
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  Speaker 1: is direction, for the purpose of harming young females through
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  Speaker 1: sexual exploitation, abuse, and trafficking. Thirty two. It was widely
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  Speaker 1: known among individuals regularly in Epstein's presence that he obtained
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  Speaker 1: pleasure from corrupting and inducing vulnerable young girls into engaging
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  Speaker 1: into uncomfortable and unwanted sexual acts for his own gratification.
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  Speaker 1: Thirty three. Epstein's illegal sexual activities were investigated by law
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  Speaker 1: enforcement on at least two occasions, once in two thousand
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  Speaker 1: and five and two thousand and eight by the United
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  Speaker 1: States Attorney for the Southern District of Florida and more
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  Speaker 1: recently by the United Nited States Attorney for the Southern
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  Speaker 1: District of New York. Thirty four. On July sewo twenty nineteen,
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  Speaker 1: the United States Attorney's Office for the Southern District of
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  Speaker 1: New York filed a sealed two count indictment, including one
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  Speaker 1: count of sex trafficking conspiracy and one count of sex
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  Speaker 1: trafficking for violations of US Code eighteen fifteen ninety one,
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  Speaker 1: in part due to Epstein's criminal activities against children in
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  Speaker 1: the New York mansion located at ninety seventy first Street
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  Speaker 1: thirty five. In addition to the allegations in the criminal
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  Speaker 1: indictment referenced above, Epstein also utilized a similar, if not
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  Speaker 1: the same scheme many years before the time period that
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  Speaker 1: was charged and many years after, as well as an
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  Speaker 1: additional location. Nationally and internationally, thirty six corporate defendants enabled
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  Speaker 1: Epstein to receive daily massages from young females, often miners,
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  Speaker 1: who were not experienced in massage. Rather than receive regular
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  Speaker 1: body massages, Epstein was predictably sexually abusing a young females,
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  Speaker 1: including plaintiff, in violation of New York Penal Code one
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  Speaker 1: point thirty thirty seven. Additionally, employees of the various corporate
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  Speaker 1: defendants performed actions or failed to perform actions that further
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  Speaker 1: places victims, including plaintiff in danger of being sexually abused
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  Speaker 1: by Epstein and assisted in the concealment of his sexually
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  Speaker 1: abusive acts. Thirty eight defendants employed many recruiters of young
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  Speaker 1: females or directed employees of his related companies to recruit
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  Speaker 1: young females in order to grow the enterprise and satisfy
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  Speaker 1: his insatiable sexual desire. Epstein and those working at his
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  Speaker 1: direction enabled victims themselves to elevate their status within the
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  Speaker 1: enterprise to that of a paid recruiter of other victims,
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  Speaker 1: an elevation only made possible through the assistance of defendants.
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  Speaker 1: Thirty nine recruiters were taught by Epstein or by employees
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  Speaker 1: of corporate defendants to inform target young females that Epstein
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  Speaker 1: possessed extraordinary wealth, power, resources, and influence, that he was
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  Speaker 1: a philanthropist who would help female victims advance her education,
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  Speaker 1: careers and lives, and that she only needed to provide
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  Speaker 1: Epstein with body massages in order to avail herself of
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  Speaker 1: his nearly unlimited assistance and influence. Forty Epstein and corporate
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  Speaker 1: defendants and their many employees fulfilled Epstein's compulsive need for
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  Speaker 1: sex with young females by praying on their personal, psychological, financial,
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  Speaker 1: and related vulnerabilities. Epstein and defendants tactics included promising the
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  Speaker 1: victim's money, shelter, transportation, gifts, employment, admission into educational institutions,
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  Speaker 1: professional licensure, protection, health care, and other things of value.
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  Speaker 1: Forty one. Epstein's sexual attraction to young, often underage females
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  Speaker 1: dated back to at least the mid nineties, and the
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  Speaker 1: number of victims increased substantially with the necessary assistance from
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  Speaker 1: the defendants and the defendants employees. Forty two. Defendants, at
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  Speaker 1: the direction of Epstein or in furtherance of his demands
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  Speaker 1: and with help from assistance associates and underlings and even
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  Speaker 1: other victims, recruited or procured dozens, if not hundreds of
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  Speaker 1: young females, including miners, for the purpose of Epstein's sexual gratification.
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  Speaker 1: Forty three. Epstein and employees of certain corporate defendants, including
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  Speaker 1: at least defendant HBRK, specifically targeted underprivileged, emotionally vulnerable, and
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  Speaker 1: or economically disadvantage young females to sexually molest and abuse
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  Speaker 1: forty four. Additionally, Epstein and corporate defendants, through employees inform
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  Speaker 1: young females, including plaintiff, that Epstein was wealthy, well connected,
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  Speaker 1: and had the power and ability to impact her life
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  Speaker 1: of any young female recruited or obtained to provide a massage.
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  Speaker 1: Forty five each of the corporate defendants committed acts of
• 15:51
  Speaker 1: negligence that allowed for Epstein to commit acts of violation
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  Speaker 1: of New York Penal Law Section one thirty forty six
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  Speaker 1: each of the defendants emitted acts against plaintiff in violation
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  Speaker 1: of US Code eighteen, fifteen ninety one and fifteen ninety five.
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  Speaker 1: All right, folks, we're gonna wrap up part one here
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  Speaker 1: and we're gonna pick up in the next episode with
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  Speaker 1: Part two. All of the information that goes with this
• 16:15
  Speaker 1: episode can be found in the description box. What's up everyone,
• 16:19
  Speaker 1: and welcome back to the Epstein chronicles. In this episode,
• 16:24
  Speaker 1: we're gonna pick up where we left off with Jane
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  Speaker 1: Doe number seventeen forty seven. Consistent with Epstein's foregoing plan
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  Speaker 1: scheme Enterprise, the plaintiff was recruited to provide Epstein with
• 16:37
  Speaker 1: massages for monetary compensation. These massages provided to Abstein by
• 16:43
  Speaker 1: a plaintiff progressed to instances of inappropriate sexual contact with
• 16:47
  Speaker 1: a plaintiff by Epstein in touching, inappropriate vaginal penetration and
• 16:52
  Speaker 1: outright rape. Plaintiff was sexually assaulted, violated, and otherwise degraded, injured, victimized,
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  Speaker 1: and sub rejected to outrageous, reckless abuse and insult forty eight.
• 17:05
  Speaker 1: In this regard, the defendants willingly participated, contributed, cooperated, and
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  Speaker 1: assisted the inappropriate and the legal scheme by facilitating such
• 17:14
  Speaker 1: scheme by and through the employees of the corporate defendant,
• 17:18
  Speaker 1: such as the corporate defendants were acting jointly and in
• 17:22
  Speaker 1: concert with the illegal scheme, with the goal designed to
• 17:25
  Speaker 1: produce corrupt sexual gratification for Epstein and degradation for the
• 17:30
  Speaker 1: targets and victims of the corrupt scheme set in motion
• 17:33
  Speaker 1: with the active involvement of the corporate defendants and their
• 17:36
  Speaker 1: employees forty nine. Epstein's abuse of plaintiff was not incidental
• 17:41
  Speaker 1: or fleeting, but rather was borne out of a pathological
• 17:44
  Speaker 1: desire to achieve corrupt and deviate sexual gratification through the
• 17:50
  Speaker 1: subjugation and abuse of Epstein's targeted victims. The actions on
• 17:54
  Speaker 1: behalf of the corporate defendants buy and through its employees, enhanced,
• 17:59
  Speaker 1: facilitated and promoted the deviate sexual acts of Epstein and
• 18:03
  Speaker 1: contributed a corrupting influence which ensnared unsuspecting women and girls
• 18:08
  Speaker 1: in its reach. Fifty Epstein, by acting singularly and in
• 18:13
  Speaker 1: concert with the corporate defendants, devised a sophisticated plan and
• 18:17
  Speaker 1: modus operandi which subtly and pervasively over time, connived to
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  Speaker 1: influence the victims and subjects of the corrupt and deviant
• 18:26
  Speaker 1: sexual scheme, to influence the will to resist the temptations
• 18:30
  Speaker 1: both actual and promised on behalf of the scheme, and
• 18:34
  Speaker 1: thereby manipulate the victims into acceptance of the scheme as
• 18:38
  Speaker 1: being one that was acceptable and appropriate. By virtue of
• 18:42
  Speaker 1: communications and representations made on behalf of Abstein by the
• 18:46
  Speaker 1: corporate defendants and in fact Epstein himself, the scheme utilized
• 18:51
  Speaker 1: a gradual wearing down of the victim's will to resist,
• 18:54
  Speaker 1: and did so by virtue of offering positive and negative
• 18:57
  Speaker 1: rewards for compliance with the schemes overall deviant methodology and
• 19:02
  Speaker 1: goals fifty one. Once Epstein and the corporate defendants, victims
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  Speaker 1: were entrapped and the scheme's methodologies enabled, Epstein and the
• 19:12
  Speaker 1: corporate defendants through the employees utilized techniques to further inhibit, indoctrinate,
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  Speaker 1: and threaten Epstein's victims such that compliance with the deviant
• 19:21
  Speaker 1: scheme's goals could further be obtained. Fifty two. The deviant
• 19:26
  Speaker 1: scheme was perpetrated over years by the actions of Epstein
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  Speaker 1: and the corporate defendants, such that victims were caught up
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  Speaker 1: in the scheme. Pressure, threats, and indoctrination techniques utilized to
• 19:37
  Speaker 1: bring the victims to heal fifty three. For victims young, vulnerable,
• 19:42
  Speaker 1: and struggling financially, the scheme's methodology was particularly effective fifty four.
• 19:48
  Speaker 1: As part and parcel of the scheme's goals, Epstein's colleagues
• 19:52
  Speaker 1: and acquaintances were involved in the scheme and benefited from
• 19:55
  Speaker 1: the scheme by virtue of receiving sexual favors and inappropriate, illegal,
• 20:01
  Speaker 1: and otherwise commercial sexual services provided by Epstein's victims, such
• 20:05
  Speaker 1: that the corrupt intent of this scheme involved males other
• 20:09
  Speaker 1: than Epstein himself. So is anyone going to get arrested
• 20:12
  Speaker 1: or are we going to talk about the flight logs
• 20:14
  Speaker 1: a little bit more? As a direct and proximate result
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  Speaker 1: of the methodology of the deviant scheme and the goals
• 20:20
  Speaker 1: of sexual exploitation of the women recruited and victimized plaintiff
• 20:25
  Speaker 1: with subject to unwonted touching of her breasts and genitals
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  Speaker 1: other sensitive areas of her body, required to perform acts
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  Speaker 1: of a sexual nature against her will and subjected to
• 20:35
  Speaker 1: genital penetration, and otherwise sexually degraded, abused, insulted, coerced, and
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  Speaker 1: injured experience, resulting in confusion, emotional distress, mental pain and suffering, shame, humiliation,
• 20:49
  Speaker 1: loss of the enjoyment of life, inconvenience, and other injuries
• 20:52
  Speaker 1: to body, mind, and soul. Fifty five. Epstein and the
• 20:57
  Speaker 1: corporate defendants buy And, through their employees and agents, substantially
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  Speaker 1: contributed to proximately cause injury to the plaintiff as aforementioned
• 21:07
  Speaker 1: fifty six. Over the course of years, Epstein and the
• 21:10
  Speaker 1: corporate defendants buy And, through its employees and agents, facilitated
• 21:14
  Speaker 1: the multiple rapes conducted on the plaintiff, in addition to
• 21:17
  Speaker 1: other deviant sexual acts against her will. Furthermore, the Plaintiff's
• 21:21
  Speaker 1: virginity was forcefully taken from her against her will. Fifty seven.
• 21:27
  Speaker 1: This fraudulent scheme of Epstein's constituted acts of coercion from
• 21:30
  Speaker 1: beginning to end from two thousand and one through mid
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  Speaker 1: two thousand and six, inasmuch as the scheme was designed
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  Speaker 1: to end, in fact caused plaintiff to believe that her
• 21:40
  Speaker 1: failure to perform any sex act required by Epstein would
• 21:44
  Speaker 1: result in serious financial, reputational, physical and emotional harm. Tour
• 21:50
  Speaker 1: count one battery against Darren ky Endyke and Richard D.
• 21:53
  Speaker 1: Coon as joint personal representatives of the estate of Jeffrey Epstein,
• 21:58
  Speaker 1: fifty eight. The plaintiff adopts and re alleges paragraphs one
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  Speaker 1: through fifty seven above fifty nine, Epstein committed a harmful
• 22:06
  Speaker 1: or offensive touching against plaintiff sixty As a direct and
• 22:10
  Speaker 1: proximate result of Epstein's battery, the plaintiff has in the
• 22:14
  Speaker 1: past suffered and in the future will continue to suffer
• 22:17
  Speaker 1: physical injury, pain, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment,
• 22:24
  Speaker 1: loss of self esteem, loss of dignity, invasion of her privacy,
• 22:28
  Speaker 1: and the loss of her capacity to enjoy life, as
• 22:31
  Speaker 1: well as other damages. Plaintiff incurred medical and psychological expenses,
• 22:36
  Speaker 1: and plaintiff will in the future suffer additional medical and
• 22:39
  Speaker 1: psychological expenses. These injuries are permanent in nature, and plaintiff
• 22:44
  Speaker 1: will continue to suffer these losses in the future. Wherefore,
• 22:48
  Speaker 1: Plaintiff demands judgment against the Estate of Jeffrey E. Epstein
• 22:52
  Speaker 1: for compensentory in general damages, attorney fees, punitive damages, and
• 22:57
  Speaker 1: other and further relief. As this Court deems just and proper.
• 23:02
  Speaker 1: Plaintiff hereby demands trial by jury on all issues triable
• 23:06
  Speaker 1: as the right by a jury. Count two battery violation
• 23:10
  Speaker 1: of Section one thirty against Darren kay Endyke and Richard D.
• 23:14
  Speaker 1: Con as joint personal representatives of the Estate of Jeffrey Epstein,
• 23:19
  Speaker 1: sixty one. The plaintiff adopts and re alleges Paragraphs one
• 23:23
  Speaker 1: through fifty seven above sixty two. The intentional acts of
• 23:26
  Speaker 1: Epstein against plaintiff constitute a sexual offense as defined in
• 23:31
  Speaker 1: New York Penal Law Section one thirty, including but not
• 23:34
  Speaker 1: limited to the following. A sexual misconduct is defined in
• 23:39
  Speaker 1: section one thirty dot twenty. Inasmuch as Epstein engaged in
• 23:43
  Speaker 1: sexual intercourse with plaintiff without Plaintiff's consent. B Rape in
• 23:48
  Speaker 1: the first degree is defined in Section one thirty dot
• 23:51
  Speaker 1: thirty five inasmuch as Epstein engaged in sexual intercourse with
• 23:55
  Speaker 1: plaintiff by forcible compulsion see criminal sexual act in the
• 23:59
  Speaker 1: first degree as defined in section one thirty dot five zero,
• 24:04
  Speaker 1: inasmuch as Epstein engaged in oral sexual conduct with plaintiff
• 24:08
  Speaker 1: by forcible compulsion d Forcible touching has defined in section
• 24:13
  Speaker 1: one thirty dot fifty two, inasmuch as Epstein intentionally and
• 24:17
  Speaker 1: for no legitimate purpose, engage the forcible sexual touching of
• 24:21
  Speaker 1: plaintiff for the purpose of degrading or abusing her, or
• 24:25
  Speaker 1: for the purpose of gratifying his own sexual desire n E.
• 24:30
  Speaker 1: Aggravated sexual abuse in the third degree as defined in
• 24:34
  Speaker 1: section one thirty dot sixty six, inasmuch as Epstein and
• 24:37
  Speaker 1: started a foreign object in the vagina of plaintiff by
• 24:41
  Speaker 1: forcible compulsion sixty three. As a direct and proximate result
• 24:46
  Speaker 1: of Epstein's violations of New York Penal Law Section one thirty,
• 24:50
  Speaker 1: plaintiff has in the past suffered, and in the future
• 24:53
  Speaker 1: will continue to suffer physical injury, pain, emotional distress, psychological trauma,
• 24:58
  Speaker 1: mental anguish, humiliate embarrassment, loss of self esteem, loss of dignity,
• 25:03
  Speaker 1: invasion of her privacy and the loss of her capacity
• 25:06
  Speaker 1: to enjoy life, as well as other damages. Plaintiff incurred
• 25:11
  Speaker 1: medical and psychological expenses, and plaintiff in the future will
• 25:15
  Speaker 1: suffer additional medical and psychological expenses. These injuries are permanent
• 25:20
  Speaker 1: in nature, and Plaintiff will continue to suffer these losses
• 25:23
  Speaker 1: in the future. Wherefore, Plaintiff demands judgment against the Estate
• 25:28
  Speaker 1: of Jeffrey e Epstein for compensantory in general damages, attorney fees,
• 25:33
  Speaker 1: punitive damages, and such other and further relief as this
• 25:36
  Speaker 1: Court deems just and proper. Plaintiff hereby demands trial by
• 25:41
  Speaker 1: jury on all issues triable as a right by a jury.
• 25:45
  Speaker 1: Count three. Cause of action against Darren ky Endyke and
• 25:48
  Speaker 1: Richard D. Con as joint personal representatives of the Estate
• 25:52
  Speaker 1: of Jeffrey e Epstein, pursuanto US Code eighteen, Section fifteen
• 25:57
  Speaker 1: ninety five, sixty four. Plaintiff adopts and re alleges Paragraphs
• 26:02
  Speaker 1: one through fifty seven above sixty five. Epstein within the
• 26:06
  Speaker 1: special maritime and territorial jurisdiction of the United States is
• 26:10
  Speaker 1: interstate and foreign commerce and or affecting interstate and foreign
• 26:15
  Speaker 1: commerce knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized, solicited, threatened, forced,
• 26:23
  Speaker 1: and coerse plaintiff to engage in commercial sex acts sixty six.
• 26:28
  Speaker 1: Such actions were undertaken knowing that his use of force,
• 26:32
  Speaker 1: threats of force, fraud, coercion, and or a combination of
• 26:36
  Speaker 1: such means would be used, and were in fact used
• 26:39
  Speaker 1: in order to cause plaintiff to engage in commercial sex acts.
• 26:43
  Speaker 1: In doing so, Epstein violated US Code eighteen, fifteen ninety one,
• 26:48
  Speaker 1: sixty seven. Furthermore, Epstein attempted to violate US Code eighteen,
• 26:53
  Speaker 1: section fifteen ninety one. In doing so, violated section eighteen
• 26:57
  Speaker 1: of US Code fifteen ninety four A. Sixty eight. Epstein
• 27:01
  Speaker 1: conspired with each member of the enterprise and with other
• 27:04
  Speaker 1: persons known and unknown, to violate US Code eighteen fifteen
• 27:09
  Speaker 1: ninety one. In doing so, violated eighteen fifteen ninety four C.
• 27:14
  Speaker 1: Sixty nine. By virtue of Epstein's violations of US Code eighteen,
• 27:19
  Speaker 1: section fifteen ninety one, fifteen ninety three A, and fifteen
• 27:22
  Speaker 1: ninety four, defendants Darren K. Endike and Richard D. Con
• 27:27
  Speaker 1: as joint personal representatives of the estate of Jeffrey E.
• 27:31
  Speaker 1: Epstein is subject to civil causes of action under US
• 27:35
  Speaker 1: Code eighteen, Section fifteen ninety five by plaintiff who is
• 27:38
  Speaker 1: a victim of the violations seventy Certain property of Epstein's
• 27:43
  Speaker 1: was essential to the commission of the federal crimes and
• 27:46
  Speaker 1: torts described herein, including the Palm Beach, Florida estate located
• 27:51
  Speaker 1: at three fifty eight Elbrio Way, pom Beach, Florida, the
• 27:54
  Speaker 1: use of multiple private aircrafts, including a Boeing aircraft and
• 27:59
  Speaker 1: the Gulfstream aircas Such real property and aircraft, along with
• 28:03
  Speaker 1: other of Epstein's property, were used as the means and
• 28:06
  Speaker 1: instruments of Epstein's tortious and criminal offenses, and as such
• 28:10
  Speaker 1: are subject to forfeiture seventy one. Additionally, Epstein's New York
• 28:15
  Speaker 1: townhouse located at ninety seventy first Street in the Southern
• 28:18
  Speaker 1: District of New York, Epstein's private island located in the
• 28:22
  Speaker 1: United States Virgin Islands, and Epstein's New Mexico estate were
• 28:26
  Speaker 1: used as means and instruments of Epstein's tortious and criminal
• 28:30
  Speaker 1: offenses as they relate to plaintiff, and as such are
• 28:33
  Speaker 1: subject to forfeiture seventy two as a direct and approximate
• 28:38
  Speaker 1: result of Epstein's commission of the aforementioned criminal offenses enumerated
• 28:43
  Speaker 1: in US Code eighteen, section fifteen ninety one, fifteen ninety
• 28:47
  Speaker 1: three A, and fifteen ninety four, and the associated civil
• 28:51
  Speaker 1: remedies provided in section fifteen ninety five. Plaintiff has in
• 28:55
  Speaker 1: the past suffered and will continue to suffer injury and pain,
• 28:59
  Speaker 1: emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
• 29:06
  Speaker 1: loss of self esteem, loss of dignity, loss of enjoyment
• 29:09
  Speaker 1: of life, invasion of privacy, and other damages associated with
• 29:13
  Speaker 1: Epstein's actions. Plaintiff will incur further medical and psychological expenses.
• 29:19
  Speaker 1: These injuries are permanent in nature, and Plaintiff will continue
• 29:22
  Speaker 1: to suffer from them in the future. In addition to
• 29:25
  Speaker 1: these losses, Plaintiff has incurred attorney's fees and will be
• 29:29
  Speaker 1: required to do so in the future, for which Epstein
• 29:31
  Speaker 1: is liable pursuant to US Code eighteen fifteen ninety five. Wherefore,
• 29:37
  Speaker 1: Plaintiff demands judgment against the estate of Jeffrey E. Epstein
• 29:41
  Speaker 1: for competentory damages and general damages, attorney fees pursuant to
• 29:45
  Speaker 1: US Code eighteen, Section fifteen ninety five, punitive damages forfeiture
• 29:50
  Speaker 1: of Epstein's assets, and such other and further relief as
• 29:54
  Speaker 1: this Court deems just and proper. Plaintiff hereby demands trial
• 29:58
  Speaker 1: by jury on all issues, trial as of right by
• 30:01
  Speaker 1: a jury. All right, folks, we're going to wrap up.
• 30:04
  Speaker 1: We'll part two here and in the next episode we'll
• 30:06
  Speaker 1: pick up where we left off. All of the information
• 30:10
  Speaker 1: that goes with this episode can be found in the
• 30:13
  Speaker 1: description box. What's up, everyone, and welcome back to the
• 30:16
  Speaker 1: Epstein Chronicles. This episode, we're going to pick back up
• 30:20
  Speaker 1: with Jane Doe seventeen and her allegations against Jeffrey Epstein
• 30:25
  Speaker 1: and Jeffrey Epstein's estate. Count number four Cause of Action
• 30:30
  Speaker 1: against ninety seventy First Street Corporation pursuant to US Code eighteen,
• 30:35
  Speaker 1: Section fifteen ninety five. Seventy three Plaintiff adopts and realleges
• 30:40
  Speaker 1: Paragraphs one through fifty seven above seventy four. Defendant buy
• 30:45
  Speaker 1: and through its management and personnel within the special maritime
• 30:49
  Speaker 1: and territorial jurisdiction of the United States in interstate and
• 30:53
  Speaker 1: foreign commerce and or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
• 31:03
  Speaker 1: solicited by any means. Plaintiff. From two thousand and one
• 31:07
  Speaker 1: through two thousand and six, seventy five, Defendant buy And,
• 31:11
  Speaker 1: through its management and personnel, knew what means of fraud
• 31:15
  Speaker 1: or coercion, and or a combination of such means would
• 31:18
  Speaker 1: be used and were in fact used in order to
• 31:21
  Speaker 1: cause Plaintiff to engage in commercial sex acts. In doing so,
• 31:25
  Speaker 1: Defendant Corporation violated US Code eighteen, section fifteen ninety one
• 31:31
  Speaker 1: seventy six. Furthermore, Defendant Corporation attempted to violate US Code eighteen,
• 31:36
  Speaker 1: section fifteen ninety one. In so doing, violated US Code eighteen,
• 31:41
  Speaker 1: fifteen ninety four a. Seventy seven. Defendant buy And, through
• 31:45
  Speaker 1: its management and personnel, conspired with other members of the
• 31:49
  Speaker 1: enterprise and with other persons and companies known and unknown,
• 31:53
  Speaker 1: to violate US Code eighteen, section fifteen ninety one. In
• 31:57
  Speaker 1: doing so, Defendant violated US Code eighteen, section fifteen ninety
• 32:01
  Speaker 1: four c. Seventy eight By virtue of its violations of
• 32:05
  Speaker 1: US Code eighteen, Section fifteen ninety one and fifteen ninety
• 32:09
  Speaker 1: three A and fifteen ninety four. Defendant is subject to
• 32:12
  Speaker 1: civil causes of action under US Code eighteen fifteen ninety
• 32:17
  Speaker 1: five by plaintiff who is a victim of their violations.
• 32:21
  Speaker 1: Seventy nine. Defendant buy And, through its management and personnel,
• 32:25
  Speaker 1: participated in a venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining,
• 32:32
  Speaker 1: and maintaining plaintiff, knowing that fraud or coercion would be
• 32:36
  Speaker 1: used to cause plaintiff to commit a commercial sex act
• 32:39
  Speaker 1: eighty As a direct and proximate result of defendant corporations
• 32:44
  Speaker 1: commission of the aforementioned criminal offenses enumerated in US Code eighteen,
• 32:49
  Speaker 1: section fifteen ninety one, fifteen ninety three A, and fifteen
• 32:53
  Speaker 1: ninety four, and the associated civil remedies provided in section
• 32:57
  Speaker 1: fifteen ninety five. Plaintiff has in the has suffered, and
• 33:01
  Speaker 1: will continue to suffer injury and pain, emotional distress, psychological
• 33:05
  Speaker 1: and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of
• 33:11
  Speaker 1: self esteem, loss of dignity, loss of enjoyment of life,
• 33:14
  Speaker 1: invasion of privacy, and other damages, associated with defendant's actions
• 33:20
  Speaker 1: eighty one, Plaintiff will incur further medical and psychological expenses.
• 33:24
  Speaker 1: These injuries are permanent in nature, and Plaintiff will continue
• 33:28
  Speaker 1: to suffer from them in the future. In addition to
• 33:31
  Speaker 1: these losses, Plaintiff has incurred attorney's fees and will continue
• 33:35
  Speaker 1: to do so in the future for which defendant is
• 33:38
  Speaker 1: liable pursu into US Code eighteen, section fifteen ninety five. Wherefore,
• 33:43
  Speaker 1: Plaintiff demands judgment against ninety seventy First Street Corporation for
• 33:48
  Speaker 1: compensatory and general damages, attorney fees pursu into US Code eighteen,
• 33:53
  Speaker 1: section fifteen ninety five, forfeiture of Defendant's assets, punitive damages,
• 33:58
  Speaker 1: and such other and further relief as this Court deems
• 34:01
  Speaker 1: just and proper. Plaintiff hereby demands trial by jury on
• 34:05
  Speaker 1: all issues triable as of a right by a jury.
• 34:09
  Speaker 1: Count number five. Cause of action against Laurel Incorporated pursu
• 34:13
  Speaker 1: into US Code eighteen, fifteen ninety five. Eighty two. Plaintiff
• 34:17
  Speaker 1: adopts and realleges Paragraphs one through fifty seven above. Eighty three.
• 34:22
  Speaker 1: Defendant buy and through its management and personnel within the
• 34:25
  Speaker 1: Special Maritime and territorial jurisdiction of the United States in
• 34:30
  Speaker 1: interstate and foreign commerce, and or affecting interstate and foreign commerce,
• 34:35
  Speaker 1: knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized, solicited
• 34:42
  Speaker 1: by any means Plaintiff From two thousand and one through
• 34:45
  Speaker 1: two thousand and six eighty four, Defendant buy And, through
• 34:48
  Speaker 1: its management and personnel, knew that means of fraud and coercion,
• 34:52
  Speaker 1: and or a combination of such means would be used,
• 34:55
  Speaker 1: and were in fact used, in order to cause plaintiff
• 34:58
  Speaker 1: to engage in commercial sex. In doing so, Defending Corporation
• 35:03
  Speaker 1: violated US Code eighteen, section fifteen ninety one eighty five. Furthermore,
• 35:09
  Speaker 1: Defending Corporation attempted to violate US Code eighteen, section fifteen
• 35:13
  Speaker 1: ninety one. In so doing, violated US Code eighteen, section
• 35:17
  Speaker 1: fifteen ninety four a. Eighty six. Defendant Buying, through its
• 35:21
  Speaker 1: management and personnel, conspired with other members of the enterprise
• 35:25
  Speaker 1: and with other persons and companies known and unknown, to
• 35:29
  Speaker 1: violate US Code eighteen, section fifteen ninety one. In doing so,
• 35:33
  Speaker 1: Defendant violated US Code eighteen, section fifteen ninety four c.
• 35:38
  Speaker 1: Eighty seven by virtue of its violations of US Code eighteen,
• 35:43
  Speaker 1: section fifteen ninety one, fifteen ninety three A, and fifteen
• 35:47
  Speaker 1: ninety four. Defending is subject to civil causes of action
• 35:50
  Speaker 1: under US Code eighteen, section fifteen ninety five by plaintiff
• 35:54
  Speaker 1: who is a victim of their violations. Eighty eight. Defendant Buying,
• 35:58
  Speaker 1: through its management and personnel, participated in a venture with
• 36:02
  Speaker 1: Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and maintaining plaintiff,
• 36:09
  Speaker 1: knowing that fraud or coercion would be used to cause
• 36:12
  Speaker 1: plaintiff to commit a commercial sex act eighty nine As
• 36:16
  Speaker 1: a direct and proximate result of defendants corporation, commission of
• 36:20
  Speaker 1: the aforementioned criminal offenses enumerated in US Code eighteen, section
• 36:25
  Speaker 1: fifteen ninety one, fifteen ninety three A, and fifteen ninety four,
• 36:29
  Speaker 1: and the associated civil remedies provided in section fifteen ninety five,
• 36:34
  Speaker 1: Plaintiff has in the past suffered and will continue to
• 36:36
  Speaker 1: suffer injury and pain, emotional distress, psychological and psychiatric trauma,
• 36:42
  Speaker 1: mental anguish, humiliation, confusion, embarrassment, loss of self esteem, loss
• 36:47
  Speaker 1: of dignity, loss of enjoyment, of life, invasion of privacy,
• 36:51
  Speaker 1: and other damages associated with the defendant's actions. Ninety Plaintiff
• 36:56
  Speaker 1: will incur further medical and psychological expenses. These injuries are
• 37:01
  Speaker 1: permanent in nature, and plaintiff will continue to suffer from
• 37:04
  Speaker 1: them in the future. In addition to these losses, Plaintiff
• 37:08
  Speaker 1: has incurred attorney's fees and will continue to do so
• 37:11
  Speaker 1: in the future for which defendant is liable pursuant to
• 37:14
  Speaker 1: US Code eighteen, section fifteen ninety five. Wherefore, Plaintiff demands
• 37:19
  Speaker 1: judgment against Laurel Incorporated for compensatory and general damages, attorney
• 37:24
  Speaker 1: fees pursuant to US Code eighteen, fifteen ninety five, forfeiture
• 37:29
  Speaker 1: of defendants assets, punitive damages, and such other and further
• 37:33
  Speaker 1: relief as this Court deems just and proper. Plaintiff hereby
• 37:37
  Speaker 1: demands trial by jury on all issues triable as of
• 37:40
  Speaker 1: the right by a jury. Count number six Cause of
• 37:44
  Speaker 1: Action against Financial Trust Company Incorporated, pursuant to US Code eighteen,
• 37:50
  Speaker 1: section fifteen ninety five. Ninety one. Plaintiff adopts and re
• 37:54
  Speaker 1: alleges Paragraphs one through fifty seven above. Ninety two. Defendant,
• 37:59
  Speaker 1: by and through its management and personnel within the special
• 38:02
  Speaker 1: maritime and territorial jurisdiction of the United States, an interstate
• 38:07
  Speaker 1: and foreign commerce and or affecting interstate and foreign commerce,
• 38:11
  Speaker 1: knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized, solicited
• 38:18
  Speaker 1: by any means the plaintiff. Ninety three. Defendant Buying through
• 38:22
  Speaker 1: its management and personnel knew that means of fraud or coercion,
• 38:27
  Speaker 1: and or a combination of such means would be used,
• 38:30
  Speaker 1: and were in fact used, in order to cause Plaintiff
• 38:32
  Speaker 1: to engage in commercial sex acts. In doing so, Defendant
• 38:36
  Speaker 1: Corporation violated US Code eighteen, section fifteen ninety one. Ninety four.
• 38:43
  Speaker 1: Defendant Buying through its management and personnel knowingly benefited financially
• 38:48
  Speaker 1: and by receiving things of value from participating in a
• 38:51
  Speaker 1: venture with Epstein sex Trafficking Venture Enterprise which had engage
• 38:55
  Speaker 1: in acts of violation of US Code eighteen, section fifteen
• 38:58
  Speaker 1: ninety two and fifteen ninety five A, knowing that the
• 39:02
  Speaker 1: venture had engaged in such violations. In doing so, Defendant
• 39:05
  Speaker 1: Corporations violated US Code eighteen, section fifteen ninety three A
• 39:11
  Speaker 1: ninety five. Furthermore, Defendant corporation attempted to violate US Code
• 39:15
  Speaker 1: eighteen fifteen ninety one. In so doing, violated US Code
• 39:19
  Speaker 1: eighteen section fifteen ninety four A. Ninety six. Defendant buy And,
• 39:25
  Speaker 1: through its management and personnel, conspired with other members of
• 39:28
  Speaker 1: the enterprise and with other persons and companies known and unknown,
• 39:32
  Speaker 1: to violate US Code eighteen, section fifteen ninety one. In
• 39:37
  Speaker 1: doing so, Defendant violated US Code eighteen fifteen ninety four C.
• 39:41
  Speaker 1: Ninety seven. By virtue of their violations of US Code
• 39:45
  Speaker 1: eighteen section fifteen ninety one, fifteen ninety three A, and
• 39:49
  Speaker 1: fifteen ninety four, Defendant is subject to civil causes of
• 39:53
  Speaker 1: action under US Code eighteen fifteen ninety five by plaintiff
• 39:57
  Speaker 1: who was a victim of their violations. Number ninety eight.
• 40:01
  Speaker 1: Defendant buy And, through its management and personnel, participated in
• 40:04
  Speaker 1: a venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining,
• 40:10
  Speaker 1: and maintaining plaintiff, knowing that fraud or coercion would be
• 40:14
  Speaker 1: used to cause plaintiff to commit a commercial sex Act
• 40:17
  Speaker 1: ninety nine. As a direct and proximate result of defendants
• 40:21
  Speaker 1: corporation commission of the aforementioned criminal offenses enumerated in US
• 40:27
  Speaker 1: Code eighteen, section fifteen ninety one, fifteen ninety three A,
• 40:31
  Speaker 1: and fifteen ninety four, and the associated civil remedies provided
• 40:35
  Speaker 1: in fifteen ninety five. Plaintiff has in the past suffered
• 40:39
  Speaker 1: and will continue to suffer injury and pain, emotional distress,
• 40:43
  Speaker 1: psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss
• 40:50
  Speaker 1: of self esteem, loss of dignity, loss of enjoyment of life,
• 40:53
  Speaker 1: invasion of privacy, and other damages associated with the defendant's actions.
• 40:58
  Speaker 1: One hundred stiff will incur further medical and psychological expenses.
• 41:03
  Speaker 1: These injuries are permanent in nature, and plaintiff will continue
• 41:07
  Speaker 1: to suffer from them in the future. In addition to
• 41:10
  Speaker 1: these losses, Plaintiff has incurred attorney's fees and will continue
• 41:14
  Speaker 1: to do so in the future, for which defendant is
• 41:17
  Speaker 1: liable pursue it to US Code eighteen, section fifteen ninety five, Wherefore,
• 41:22
  Speaker 1: Plaintiff demands judgment against defendant Financial Trust Company, Incorporated, for
• 41:28
  Speaker 1: compensatory in general damages attorney fees pursu into US Code
• 41:32
  Speaker 1: eighteen fifteen ninety five forfeiture of the defendants assets, punitive damages,
• 41:37
  Speaker 1: and other such and further relief as this Court deems
• 41:40
  Speaker 1: just and proper. Plaintiff hereby demands trial by jury on
• 41:44
  Speaker 1: all issues triable as of right by a jury. Count
• 41:48
  Speaker 1: number seven. Cause of Action against nes LLC. Pursu into
• 41:52
  Speaker 1: US Code eighteen, Section fifteen ninety five, Sec. One oh one.
• 41:58
  Speaker 1: Plaintiff adopts and reallegeswer Paragraphs one through fifty seven above.
• 42:02
  Speaker 1: One oh two. Defendant buy And, through its management and personnel,
• 42:06
  Speaker 1: within the special maritime and territorial jurisdiction of the United States,
• 42:11
  Speaker 1: an interstate and foreign commerce, and or affecting interstate and
• 42:15
  Speaker 1: foreign commerce, knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
• 42:23
  Speaker 1: solicited by any means the plaintiff. One O three. Defendant
• 42:27
  Speaker 1: buy And, through its management and personnel, knew that means
• 42:30
  Speaker 1: of fraud or coercion, and or a combination of such
• 42:34
  Speaker 1: means would be used, and were in fact used, in
• 42:36
  Speaker 1: order to cause Plaintiff to engage in commercial sex acts.
• 42:40
  Speaker 1: In doing so, Defendant Corporation violated US Code eighteen, Section
• 42:45
  Speaker 1: fifteen ninety one one oh four. Furthermore, Defendant Corporation attempted
• 42:50
  Speaker 1: to violate US Code eighteen, section fifteen ninety one. In
• 42:54
  Speaker 1: so doing, violated US Code eighteen fifteen ninety four A.
• 42:58
  Speaker 1: One oh five. Buying, through its management and personnel, conspired
• 43:03
  Speaker 1: with other members of the enterprise and with other persons
• 43:06
  Speaker 1: and companies known and unknown, to violate US Code eighteen,
• 43:11
  Speaker 1: section fifteen ninety one. In doing so, Defendant violated US
• 43:15
  Speaker 1: Code eighteen section fifteen ninety four C. One O six.
• 43:20
  Speaker 1: By virtue of their violations of US Code eighteen section
• 43:23
  Speaker 1: fifteen ninety one, fifteen ninety three A, and fifteen ninety four,
• 43:28
  Speaker 1: Defendant is subject to civil causes of action under US
• 43:31
  Speaker 1: Code eighteen fifteen ninety five by plaintiff who is a
• 43:34
  Speaker 1: victim of their violations. One oh seven. Defendant, buy And,
• 43:39
  Speaker 1: through its management and personnel, participated in a venture with
• 43:43
  Speaker 1: Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and maintaining plaintiff,
• 43:49
  Speaker 1: knowing that fraud or coercion would be used to cause
• 43:52
  Speaker 1: plaintiff to commit a commercial sex act one O eight.
• 43:56
  Speaker 1: As a direct and proximate result of defendants corporation commission
• 44:00
  Speaker 1: of the aforementioned criminal offenses, enumerated in US Code eighteen,
• 44:04
  Speaker 1: section fifteen ninety one, fifteen ninety three A, and fifteen
• 44:08
  Speaker 1: ninety four, and the associated civil remedies provided in section
• 44:12
  Speaker 1: fifteen ninety five. Plaintiff has in the past suffered and
• 44:16
  Speaker 1: will continue to suffer injury and pain, emotional distress, psychological
• 44:21
  Speaker 1: and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of
• 44:26
  Speaker 1: self esteem, loss of dignity, loss of enjoyment of life,
• 44:29
  Speaker 1: invasion of privacy, and other damages associated with the defendant's actions.
• 44:35
  Speaker 1: Se one oh nine, Plaintiff will incur further medical and
• 44:38
  Speaker 1: psychological expenses. These injuries are permanent in nature, and plaintiff
• 44:42
  Speaker 1: will continue to suffer them in the future. In addition
• 44:46
  Speaker 1: to these losses, Plaintiff has incurred attorney's fees and will
• 44:49
  Speaker 1: continue to do so in the future for which defendant
• 44:52
  Speaker 1: is liable pursue it to US Code eighteen, section fifteen
• 44:56
  Speaker 1: ninety five, wherefore, plaintiff demands judgment against the f defendant,
• 45:00
  Speaker 1: and he has incorporated for compensatory in general damages attorney
• 45:04
  Speaker 1: fees pursu into US Code eighteen, section fifteen ninety five
• 45:09
  Speaker 1: forfeiture of defendant's assets punitive damages, and such other and
• 45:13
  Speaker 1: further relief as this Court deems just and proper. Plaintiff
• 45:17
  Speaker 1: hereby demands trial by jury on all issues triable as
• 45:21
  Speaker 1: a right by a jury. All right, folks, that's gonna
• 45:24
  Speaker 1: do it for this one. In the next episode, we're
• 45:26
  Speaker 1: gonna pick up where we left off and continue on
• 45:29
  Speaker 1: with Jane Doe seventeen and her allegations against Jeffrey Epstein's estate.
• 45:35
  Speaker 1: All of the information that goes with this episode can
• 45:38
  Speaker 1: be found in the description box. What's up everyone, and
• 45:42
  Speaker 1: welcome back to the Epstein Chronicles. We're gonna pick right
• 45:45
  Speaker 1: back up where we left off with Jane Doe and
• 45:49
  Speaker 1: her complaints against Jeffrey Epstein and his a State count
• 45:53
  Speaker 1: Number eight Cause of Action against Maple Incorporated, pursu into
• 45:57
  Speaker 1: US Code eighteen, Section fifty feteen ninety five, Number one ten.
• 46:03
  Speaker 1: Plaintiff adopts and re alleges Paragraphs one through fifty seven
• 46:07
  Speaker 1: above one eleven. Defendant buy and through its management and
• 46:11
  Speaker 1: personnel within the special maritime and territorial jurisdiction of the
• 46:15
  Speaker 1: United States and interstate and foreign commerce, and or affecting
• 46:19
  Speaker 1: interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
• 46:27
  Speaker 1: solicited by any means Plaintiff from two thousand and one
• 46:31
  Speaker 1: through two thousand and six one twelve, Defendant buy And,
• 46:34
  Speaker 1: through its management and personnel, knew that means of fraud
• 46:38
  Speaker 1: or coercion, and or a combination of such means would
• 46:41
  Speaker 1: be used and were in fact used in order to
• 46:44
  Speaker 1: cause plaintiff to engage in commercial sex acts. In doing so,
• 46:48
  Speaker 1: Defendant Corporation violated US Code eighteen, section fifteen ninety one
• 46:53
  Speaker 1: one thirteen. Furthermore, Defendant Corporation attempted to violate US Code eighteen,
• 46:59
  Speaker 1: section fifteen ninety In doing so, violated US Code eighteen
• 47:03
  Speaker 1: section fifteen ninety four A one fourteen. Defendant Buying, through
• 47:08
  Speaker 1: its management and personnel, conspired with other members of the
• 47:11
  Speaker 1: enterprise and with other persons and companies known and unknown,
• 47:16
  Speaker 1: to violate US Code eighteen section fifteen ninety one. In
• 47:20
  Speaker 1: doing so, Defendant violated eighteen US Code section fifteen ninety
• 47:24
  Speaker 1: four C one fifteen by virtue of its violations of
• 47:29
  Speaker 1: US Code eighteen section fifteen ninety one, section fifteen ninety
• 47:33
  Speaker 1: three A and fifteen ninety four. Defendant is subject to
• 47:37
  Speaker 1: civil causes of action under US Code eighteen, Section fifteen
• 47:41
  Speaker 1: ninety five by plaintiff who is a victim of their violations.
• 47:45
  Speaker 1: One sixteen. Defendant Buying, through its management and personnel, participated
• 47:50
  Speaker 1: in a venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining,
• 47:55
  Speaker 1: and maintaining plaintiff, knowing that fraud and or coercion would
• 47:59
  Speaker 1: be used to cause plaintiff to commit a commercial sex
• 48:02
  Speaker 1: act one seventeen. As a direct and proximate result of
• 48:07
  Speaker 1: defendants corporations commission of the aforementioned criminal offenses enumerated in
• 48:13
  Speaker 1: US Code eighteen, Section fifteen ninety one, fifteen ninety three A,
• 48:17
  Speaker 1: and fifteen ninety four, and the associated civil remedies provided
• 48:21
  Speaker 1: in section fifteen ninety five. Plaintiff has in the past
• 48:24
  Speaker 1: suffered and will continue to suffer injury and pain, emotional distress,
• 48:29
  Speaker 1: psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss
• 48:35
  Speaker 1: of self esteem, loss of enjoyment of life, invasion of privacy,
• 48:39
  Speaker 1: and other damages associated with the defendant's actions. One eighteen,
• 48:44
  Speaker 1: Plaintiff will incur further medical and psychological expenses. These injuries
• 48:50
  Speaker 1: are permanent in nature, and Plaintiff will continue to suffer
• 48:53
  Speaker 1: from them in the future. In addition to these losses,
• 48:56
  Speaker 1: Plaintiff has incurred attorney's fees and will continue to douce
• 49:00
  Speaker 1: z in the future for which Defendant is liable pursuing
• 49:03
  Speaker 1: to US Code eighteen, section fifteen ninety five. Wherefore, Plaintiff
• 49:07
  Speaker 1: demands judgment against Maple Incorporated for competsentory and general damages,
• 49:12
  Speaker 1: attorney fees pursuing to US Code eighteen, section fifteen ninety five,
• 49:17
  Speaker 1: forfeiture of defendants assets, punitive damages, and such other and
• 49:21
  Speaker 1: further relief as this Court deems justin proper. Plaintiff hereby
• 49:25
  Speaker 1: demands trial by jury on all issues triable as of
• 49:29
  Speaker 1: right by a jury. Count nine Cause of action against
• 49:32
  Speaker 1: eld sje Llc pursuing to US Code eighteen, section fifteen
• 49:37
  Speaker 1: ninety five one nineteen. Plaintiff adopts and re alleges Paragraphs
• 49:42
  Speaker 1: one through fifty seven above. One twenty Defendant buying through
• 49:46
  Speaker 1: its management and personnel within the special maritime and territorial
• 49:50
  Speaker 1: jurisdiction of the United States in interstate and foreign commerce
• 49:55
  Speaker 1: and or affecting interstate and foreign commerce knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
• 50:04
  Speaker 1: solicited by any means. Plaintiff from two thousand and one
• 50:08
  Speaker 1: through two thousand and six one twenty one, Defendant buy And,
• 50:12
  Speaker 1: through its management and personnel, knew that means of fraud
• 50:16
  Speaker 1: or coercion, and or combinations of such means would be used,
• 50:19
  Speaker 1: and were in fact used, in order to cause Plaintiff
• 50:22
  Speaker 1: to engage in commercial sex acts. In doing so, Defendant
• 50:26
  Speaker 1: Corporation violated US Code eighteen, section fifteen ninety one one
• 50:31
  Speaker 1: twenty two. Furthermore, Defendant Corporation attempted to violate US Code eighteen,
• 50:36
  Speaker 1: section fifteen ninety one. In so doing, violated US Code
• 50:40
  Speaker 1: eighteen section fifteen ninety four A one twenty three. Defendant
• 50:45
  Speaker 1: buy And, through its management and personnel, conspired with other
• 50:49
  Speaker 1: members of the enterprise and with other persons and companies
• 50:52
  Speaker 1: known and unknown, to violate US Code eighteen section fifteen
• 50:57
  Speaker 1: ninety one. In doing so, Defendant violated US Code eighteen
• 51:01
  Speaker 1: section fifteen ninety four C. One twenty four by virtue
• 51:05
  Speaker 1: of its violations of US Code eighteen section fifteen ninety one,
• 51:09
  Speaker 1: fifteen ninety three A, and fifteen ninety four. Defendant is
• 51:13
  Speaker 1: subject to civil causes of action under US Code eighteen,
• 51:17
  Speaker 1: section fifteen ninety five by plaintiff who is a victim
• 51:21
  Speaker 1: of their violations. One twenty five. Defendant buy And, through
• 51:25
  Speaker 1: its management and personnel, participated in a venture with Epstein's
• 51:29
  Speaker 1: enterprise by knowingly recruiting, transporting, soliciting, obtaining, and maintaining plaintiff,
• 51:35
  Speaker 1: knowing that fraud or coercion would be used to cause
• 51:38
  Speaker 1: plaintiff to commit a commercial sex act one twenty six.
• 51:43
  Speaker 1: As a direct and proximate result of defendants corporation, commission
• 51:46
  Speaker 1: of the aforementioned criminal offenses enumerated in US Code eighteen,
• 51:51
  Speaker 1: Section fifteen ninety one, fifteen ninety three a n. Fifteen
• 51:55
  Speaker 1: ninety four, and the associated civil remedies provided in section
• 51:59
  Speaker 1: fifteen ninety five, Plaintiff has in the past suffered and
• 52:03
  Speaker 1: will continue to suffer injury and pain, emotional distress, psychological
• 52:08
  Speaker 1: and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of
• 52:13
  Speaker 1: self esteem, loss of enjoyment of life, invasion of privacy,
• 52:17
  Speaker 1: and other damages associated with the defendant's actions. One twenty seven,
• 52:22
  Speaker 1: Plaintiff will incur further medical and psychological expenses. These injuries
• 52:27
  Speaker 1: are permanent in nature, and Plaintiff will continue to suffer
• 52:30
  Speaker 1: from them in the future. In addition to these losses,
• 52:33
  Speaker 1: Plaintiff has incurred attorney fees and will continue to do
• 52:37
  Speaker 1: so in the future for which Defendant is liable pursu
• 52:40
  Speaker 1: into US Code eighteen, section fifteen ninety five, wherefore, Plaintiff
• 52:45
  Speaker 1: demands judgment against LSJE Llc for compensatory and general damages,
• 52:51
  Speaker 1: attorney fees, pursue it to US Code eighteen, section fifteen
• 52:55
  Speaker 1: ninety five forfeiture of Defendant's assets, punitive damages, and such
• 53:00
  Speaker 1: other and further relief as this Court deems just and proper.
• 53:04
  Speaker 1: Plaintiff hereby demands trial by jury on all issues triable
• 53:08
  Speaker 1: as of a right by a jury. Count ten Cause
• 53:13
  Speaker 1: of action against HBRK Associates, Incorporated. Pursuing the US Code eighteen,
• 53:18
  Speaker 1: section fifteen ninety five. One twenty eight. Plaintiff adopts and
• 53:22
  Speaker 1: realleges Paragraphs one through fifty seven above. One twenty nine.
• 53:27
  Speaker 1: Defendant buying through its management and personnel within the special
• 53:30
  Speaker 1: Maritime and Territorial jurisdiction of the United States in interstate
• 53:35
  Speaker 1: and foreign commerce and or affecting interstate and foreign commerce,
• 53:39
  Speaker 1: knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized, solicited
• 53:47
  Speaker 1: by any means the plaintiff one thirty Defendant Buying, through
• 53:51
  Speaker 1: its management and personnel, knew that means of fraud and
• 53:55
  Speaker 1: or coercion, and or combinations of such means would be used,
• 53:59
  Speaker 1: and were in fact used, in order to cause Plaintiff
• 54:01
  Speaker 1: to engage in commercial sex acts. In doing so, Defendant
• 54:05
  Speaker 1: Corporation violated US Code eighteen, section fifteen ninety one. One
• 54:10
  Speaker 1: thirty one. Defendant Buying, through its management and personnel, knowingly
• 54:14
  Speaker 1: benefited financially and by receiving things of value from participating
• 54:18
  Speaker 1: in a venture with Epstein sex trafficking Venture Enterprise which
• 54:22
  Speaker 1: had engaged in acts of violation of US Code eighteen,
• 54:26
  Speaker 1: section fifteen ninety two and fifteen ninety five, knowing that
• 54:30
  Speaker 1: the venture had engaged in such violations. In doing so,
• 54:33
  Speaker 1: Defendant Corporation violated US Code eighteen, section fifteen ninety three
• 54:38
  Speaker 1: A one thirty two. Furthermore, Defendant Corporation attempted to violate
• 54:43
  Speaker 1: US Code eighteen, section fifteen ninety one. In so doing,
• 54:48
  Speaker 1: defendant violated US Code eighteen, section fifteen ninety four A.
• 54:53
  Speaker 1: One thirty three. Defendant Buying, through its management and personnel,
• 54:57
  Speaker 1: conspired with other members of the enterprise and with other
• 55:00
  Speaker 1: persons and companies known and unknown to violate US Code eighteen,
• 55:05
  Speaker 1: section fifteen ninety one. In doing so, Defendant violated US
• 55:09
  Speaker 1: Code eighteen fifteen ninety four C. One thirty four. By
• 55:13
  Speaker 1: virtue of their violations of US Code eighteen fifteen ninety one,
• 55:17
  Speaker 1: fifteen ninety three A, and fifteen ninety four, Defendant is
• 55:21
  Speaker 1: subject to civil causes of action under US Code eighteen,
• 55:25
  Speaker 1: section fifteen ninety five by plaintiff who is a victim
• 55:28
  Speaker 1: of their violations. One thirty five. Defendant buy And, through
• 55:32
  Speaker 1: its management and personnel, participated in a venture with Epstein's
• 55:36
  Speaker 1: enterprise by knowingly recruiting, transporting, soliciting, obtaining, and maintaining plaintiff,
• 55:42
  Speaker 1: knowing that fraud or coercion would be used to cause
• 55:45
  Speaker 1: plaintiff to commit a commercial sex act one thirty six.
• 55:49
  Speaker 1: As a direct and proximate result of defendant corporations commission
• 55:53
  Speaker 1: of the aforementioned criminal offenses, enumerated in US Code eighteen
• 55:57
  Speaker 1: sections fifteen ninety one, fifteen ninety three A, and fifteen
• 56:01
  Speaker 1: ninety four, and the associated civil remedies provided in section
• 56:06
  Speaker 1: fifteen ninety five. Plaintiff has in the past suffered and
• 56:09
  Speaker 1: will continue to suffer injury and pain, emotional distress, psychological
• 56:14
  Speaker 1: and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of
• 56:20
  Speaker 1: self esteem, loss of enjoyment of life, invasion of privacy,
• 56:23
  Speaker 1: and other damages associated with defendant's actions. One thirty seven.
• 56:28
  Speaker 1: Plaintiff will incur further medical and psychological expenses. These injuries
• 56:33
  Speaker 1: are permanent in nature, and Plaintiff will continue to suffer
• 56:36
  Speaker 1: from them in the future. In addition to the losses,
• 56:40
  Speaker 1: Plaintiff has incurred attorney's fees and will continue to do
• 56:43
  Speaker 1: so in the future for which Defendant is liable pursuant
• 56:47
  Speaker 1: to US Code eighteen, Section fifteen ninety five one thirty eight. Wherefore,
• 56:53
  Speaker 1: Plaintiff demands judgment against Defendant HBRK Associates, Incorporated for compensentory
• 57:00
  Speaker 1: and general damages attorney fees pursuant to US Code eighteen,
• 57:04
  Speaker 1: Section fifteen ninety five forfeiture of defendant's assets, punitive damages,
• 57:09
  Speaker 1: and such other and further relief as this Court deems
• 57:13
  Speaker 1: just and proper. Plaintiff hereby demands trial by jury on
• 57:16
  Speaker 1: all issues triable as of a right by a jury.
• 57:20
  Speaker 1: All right, folks, we're going to wrap up there, and
• 57:22
  Speaker 1: in the next episode we're going to finish off Jane
• 57:25
  Speaker 1: Doe seventeen and the allegations that she's making or made,
• 57:29
  Speaker 1: i should say, against the estate. All of the information
• 57:33
  Speaker 1: that goes with this episode can be found in the
• 57:36
  Speaker 1: description box. What's up, everyone, and welcome back to the
• 57:40
  Speaker 1: Epstein Chronicles. In this episode, we're going to finish off
• 57:44
  Speaker 1: with Jane Doe seventeen and her allegations against Jeffrey Epstein
• 57:49
  Speaker 1: and the Jeffrey Epstein Estate. So let's get right back
• 57:53
  Speaker 1: to it. Count number eleven Cause of Action against Nautilus Incorporated.
• 57:57
  Speaker 1: Pursuant to US Code eighteen, Section fifteen ninety five one
• 58:02
  Speaker 1: thirty nine. Plaintiff adopts and realleges Paragraphs one through fifty
• 58:06
  Speaker 1: seven above one for defendant buy and through its management
• 58:10
  Speaker 1: and personnel within the special maritime and territorial jurisdiction of
• 58:15
  Speaker 1: the United States in interstate and foreign commerce and or
• 58:19
  Speaker 1: affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
• 58:28
  Speaker 1: solicited by any means the plaintiff. One forty one. Defendant
• 58:33
  Speaker 1: buy And, through its management and personnel, knew that means
• 58:36
  Speaker 1: of fraud or coercion, and or combinations of such means
• 58:39
  Speaker 1: would be used, and were in fact used, in order
• 58:43
  Speaker 1: to cause Plaintiff to engage in commercial sex acts. In
• 58:46
  Speaker 1: doing so, Defendant Corporation violated US Code eighteen, section fifteen
• 58:52
  Speaker 1: ninety one. One forty two. Defendant buy And, through its
• 58:56
  Speaker 1: management and personnel, knowingly benefited financially and receiving things of
• 59:00
  Speaker 1: value from participating in a venture the Epstein sex Trafficking
• 59:04
  Speaker 1: Venture Enterprise, which had engaged in acts in violation of
• 59:09
  Speaker 1: US Code eighteen, section fifteen ninety two and fifteen ninety
• 59:13
  Speaker 1: five A, knowing that the venture had engaged in such violations.
• 59:18
  Speaker 1: In so doing, defending Corporation violated US Code eighteen, section
• 59:23
  Speaker 1: fifteen ninety three A one forty three. Furthermore, Defendant Corporation
• 59:29
  Speaker 1: attempted to violate US Code eighteen, fifteen ninety one. In
• 59:33
  Speaker 1: so doing, Defendant violated US Code eighteen, section fifteen ninety
• 59:37
  Speaker 1: four A. One forty four. Defendant buy And, through its
• 59:41
  Speaker 1: management and personnel, conspired with other members of the enterprise
• 59:46
  Speaker 1: and with other persons and companies known and unknown, to
• 59:49
  Speaker 1: violate US Code eighteen, section fifteen ninety one. In doing so,
• 59:54
  Speaker 1: defendant violated US Code eighteen section fifteen ninety four C.
• 1:00:00
  Speaker 1: One forty five. By virtue of their violations of US
• 1:00:04
  Speaker 1: Code eighteen section fifteen ninety one, fifteen ninety three A,
• 1:00:08
  Speaker 1: and fifteen ninety four, defendant is subject to civil causes
• 1:00:11
  Speaker 1: of action under US Code eighteen, section fifteen ninety five
• 1:00:16
  Speaker 1: by plaintiff who is a victim of their violations. One
• 1:00:20
  Speaker 1: forty six. Defendant buy And, through its management and personnel,
• 1:00:24
  Speaker 1: participated in a venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining,
• 1:00:31
  Speaker 1: and maintaining plaintiff, knowing that fraud or coercion would be
• 1:00:35
  Speaker 1: used to cause plaintiff to commit a commercial sex act
• 1:00:39
  Speaker 1: one forty seven. As a direct and proximate result of
• 1:00:42
  Speaker 1: defendants corporations commission of the aforementioned criminal offenses enumerated in
• 1:00:48
  Speaker 1: US Code eighteen sections fifteen ninety one, fifteen ninety three A,
• 1:00:53
  Speaker 1: and fifteen ninety four, and the associates civil remedies provided
• 1:00:58
  Speaker 1: in section fifteen ninety five. Plaintiff has in the past
• 1:01:01
  Speaker 1: suffered and will continue to suffer injury and pain, emotional distress,
• 1:01:05
  Speaker 1: psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss
• 1:01:12
  Speaker 1: of self esteem, loss of dignity, loss of enjoyment of life,
• 1:01:16
  Speaker 1: invasion of privacy, and other damages associated with the defendant's actions.
• 1:01:21
  Speaker 1: One eight. Plaintiff will incur further medical fees and psychological expenses.
• 1:01:27
  Speaker 1: These injuries are permanent in nature, and plaintiff will continue
• 1:01:31
  Speaker 1: to suffer from them in the future. In addition to
• 1:01:34
  Speaker 1: these losses, Plaintiff has incurred attorney's fees and will continue
• 1:01:38
  Speaker 1: to do so in the future for which defendant is
• 1:01:41
  Speaker 1: liable pursuant to US Code eighteen, section fifteen ninety five.
• 1:01:48
  Speaker 1: One nine. Wherefore, a plaintiff demands judgment against defendant Nautilus
• 1:01:53
  Speaker 1: Incorporated for a compensatory and general damages, attorney fees pursuant
• 1:01:58
  Speaker 1: to US Code eighteen, section fifteen ninety five, forfeiture of
• 1:02:02
  Speaker 1: defendant's assets, punitive damages, and such other and further relief
• 1:02:07
  Speaker 1: as this Court deems just and proper. Plaintiff hereby demands
• 1:02:11
  Speaker 1: trial by jury on all issues triable as of right
• 1:02:15
  Speaker 1: by a jury. Count number twelve. Cause of Action against
• 1:02:18
  Speaker 1: Cyprus Incorporated. Pursue into US Code eighteen, Section fifteen ninety five,
• 1:02:25
  Speaker 1: Plaintiff adopts and re alleges Paragraphs one through fifty seven above.
• 1:02:30
  Speaker 1: One fifty one. Defendant buy And, through its management and
• 1:02:34
  Speaker 1: personnel within the special maritime and territorial jurisdiction of the
• 1:02:38
  Speaker 1: United States in interstate and foreign commerce and or affecting
• 1:02:43
  Speaker 1: interstate and foreign commerce, knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
• 1:02:52
  Speaker 1: solicited by any means the plaintiff. One fifty two. Defendant
• 1:02:58
  Speaker 1: buy And, through its management and personnel, knew that means
• 1:03:01
  Speaker 1: of fraud or coercion, and or a combination of such
• 1:03:04
  Speaker 1: means would be used, and were in fact used, in
• 1:03:07
  Speaker 1: order to cause Plaintiff to engage in commercial sex acts.
• 1:03:11
  Speaker 1: In doing so, defending corporation violated US Code eighteen, Section
• 1:03:16
  Speaker 1: fifteen ninety one. One fifty three Defendant buy And, through
• 1:03:20
  Speaker 1: its management and personnel, knowingly benefited financially and by receiving
• 1:03:26
  Speaker 1: things of value from participating in a venture the Epstein
• 1:03:30
  Speaker 1: Sex Trafficking Venture Enterprise, which had engaged in acts in
• 1:03:34
  Speaker 1: violation of US Code eighteen, section fifteen ninety two and
• 1:03:38
  Speaker 1: fifteen ninety five A. Knowing that the venture had engaged
• 1:03:42
  Speaker 1: in such violations. In doing so, Defending Corporation violated US
• 1:03:46
  Speaker 1: Code eighteen, section fifteen ninety three A one fifty four. Furthermore,
• 1:03:52
  Speaker 1: Defending Corporation attempted to violate US Code eighteen, section fifteen
• 1:03:57
  Speaker 1: ninety one. In doing so, Defendant biolated US Code eighteen
• 1:04:01
  Speaker 1: section fifteen ninety four A one fifty five. Defendant buy And,
• 1:04:06
  Speaker 1: through its management and personnel, conspired with other members of
• 1:04:10
  Speaker 1: the enterprise and with other persons and companies known and unknown,
• 1:04:14
  Speaker 1: to violate US Code eighteen, section fifteen ninety one. In
• 1:04:18
  Speaker 1: doing so, Defendant violated US Code eighteen section fifteen ninety
• 1:04:23
  Speaker 1: four C. One fifty six. By virtue of their violations
• 1:04:27
  Speaker 1: of US Code eighteen fifteen ninety one, fifteen ninety three A,
• 1:04:32
  Speaker 1: and fifteen ninety four, Defendant is subject to civil causes
• 1:04:36
  Speaker 1: of action under US Code eighteen, section fifteen ninety five
• 1:04:40
  Speaker 1: by plaintiff who is a victim of their violations. One
• 1:04:44
  Speaker 1: fifty seven. Defendant buy And, through its management and personnel,
• 1:04:48
  Speaker 1: participated in a venture with Epstein's enterprise, knowingly recruiting, transporting, soliciting, obtaining,
• 1:04:55
  Speaker 1: and maintaining plaintiff, knowing that fraud or coercion would be
• 1:04:59
  Speaker 1: used to call plaintiff to commit a commercial sex act
• 1:05:03
  Speaker 1: one fifty eight. As a direct and proximate result of
• 1:05:06
  Speaker 1: defendants corporations commission of aforementioned criminal offenses enumerated in US
• 1:05:12
  Speaker 1: Code eighteen, Section fifteen ninety one and fifteen ninety three
• 1:05:16
  Speaker 1: A and fifteen ninety four, and the associated civil remedies
• 1:05:21
  Speaker 1: provided in section fifteen ninety five. Plaintiff has in the
• 1:05:25
  Speaker 1: past suffered and will continue to suffer injury and pain,
• 1:05:28
  Speaker 1: emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
• 1:05:37
  Speaker 1: loss of self esteem, loss of dignity, loss of enjoyment
• 1:05:40
  Speaker 1: of life, invasion of privacy, and other damages associated with
• 1:05:44
  Speaker 1: the defendant's actions. One fifty nine, Plaintiff will incur further
• 1:05:49
  Speaker 1: medical and psychological expenses. These injuries are permanent in nature,
• 1:05:54
  Speaker 1: and plaintiff will continue to suffer from them in the future.
• 1:05:58
  Speaker 1: In addition to these losses, Plaintiff has incurred attorney's fees
• 1:06:02
  Speaker 1: and will continue to do so in the future for
• 1:06:04
  Speaker 1: which Defendant is liable pursuant to US Code eighteen, Section
• 1:06:09
  Speaker 1: fifteen ninety five, one sixty Wherefore, Plaintiff demands judgment against
• 1:06:14
  Speaker 1: Defendant Cyprus Incorporated, for compensatory and general damages, attorney fees
• 1:06:20
  Speaker 1: pursuant to US Code eighteen, section fifteen ninety five, forfeiture
• 1:06:25
  Speaker 1: of Defendant's assets, punitive damages, and such other and further
• 1:06:30
  Speaker 1: relief as this Court deems just and proper. Plaintiff hereby
• 1:06:34
  Speaker 1: demands trial by jury on all issues triable as right
• 1:06:38
  Speaker 1: by a jury. Count thirteen. Cause of Action against Jege Incorporated,
• 1:06:44
  Speaker 1: pursu into US Code eighteen, Section fifteen ninety five, one
• 1:06:49
  Speaker 1: sixty one. Plaintiff adopts and re alleges paragraphs one through
• 1:06:53
  Speaker 1: fifty seven above. One sixty two. Defendant buy and, through
• 1:06:57
  Speaker 1: its management and personnel within the special maritime and territorial
• 1:07:00
  Speaker 1: jurisdiction of the United States, in interstate and foreign commerce
• 1:07:05
  Speaker 1: and or affecting interstate and foreign commerce, knowingly recruited, enticed harbored, transported, provided, obtained, maintained, patronized,
• 1:07:14
  Speaker 1: solicited by any means Plaintiff from two thousand and one
• 1:07:17
  Speaker 1: through two thousand and six one sixty three. Defendant Buying
• 1:07:21
  Speaker 1: through its management and personnel, knew that means of fraud
• 1:07:25
  Speaker 1: or coercion, and or a combination of such means would
• 1:07:28
  Speaker 1: be used, and were in fact used, in order to
• 1:07:31
  Speaker 1: cause plaintiff to engage in commercial sex acts. In doing so,
• 1:07:35
  Speaker 1: Defending Corporation violated US Code eighteen section fifteen ninety one
• 1:07:40
  Speaker 1: one sixty four. Furthermore, Defendant Corporation attempted to violate US
• 1:07:45
  Speaker 1: Code eighteen, section fifteen ninety one. In doing so, violated
• 1:07:49
  Speaker 1: US Code eighteen section fifteen ninety four A one sixty five.
• 1:07:54
  Speaker 1: Defendant Buying, through its management and personnel, conspired with other
• 1:07:58
  Speaker 1: members of the enterprise and with other persons and companies
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  Speaker 1: known and unknown, to violate US Code eighteen section fifteen
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  Speaker 1: ninety one. In doing so, Defendant violated US Code eighteen
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  Speaker 1: section fifteen ninety four C. One sixty six by virtue
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  Speaker 1: of its violations of US Code eighteen section fifteen ninety one,
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  Speaker 1: fifteen ninety three A, and fifteen ninety four defending his
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  Speaker 1: subject to civil causes of action under US Code eighteen,
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  Speaker 1: section fifteen ninety five by plaintiff who was a victim
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  Speaker 1: of their violations. One sixty seven. Defendant buy And, through
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  Speaker 1: its management and personnel, participated in a venture with Epstein's
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  Speaker 1: enterprise by knowingly recruiting, transporting, soliciting, obtaining, and maintaining plaintiff,
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  Speaker 1: knowing that fraud or coercion would be used to cause
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  Speaker 1: plaintiff to commit a commercial sex act one sixty eight.
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  Speaker 1: As a direct and proximate result of defendants Corporation's commission
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  Speaker 1: of the aforementioned midal offenses enumerated in US Code eighteen,
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  Speaker 1: Section fifteen ninety one, fifteen ninety three A, and fifteen
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  Speaker 1: ninety four, and the associated civil remedies provided in section
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  Speaker 1: fifteen ninety five, Plaintiff has in the past suffered and
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  Speaker 1: will continue to suffer injury and pain, emotional distress, psychological
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  Speaker 1: and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of
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  Speaker 1: self esteem, loss of dignity, loss of enjoyment of life,
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  Speaker 1: invasion of privacy, and other damages associated with the defendant's actions.
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  Speaker 1: One sixty nine, Plaintiff will incur further medical and psychological expenses.
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  Speaker 1: These injuries are permanent in nature, and plaintiff will continue
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  Speaker 1: to suffer from them in the future. In addition to
• 1:09:46
  Speaker 1: these losses, Plaintiff has incurred attorney fees and will continue
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  Speaker 1: to do so in the future for which defendant is
• 1:09:53
  Speaker 1: liable pursu into US Code eighteen, section fifteen ninety five. Wherefore,
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  Speaker 1: Plaintiff demands judgment against JEGE Incorporated for compensentory and general damages,
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  Speaker 1: attorney fees pursuant to US Code eighteen, section fifteen ninety five,
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  Speaker 1: forfeiture of defendants assets, punitive damages, and such other and
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  Speaker 1: further relief as this Court deems just and proper. Plaintiff
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  Speaker 1: hereby demands trial by jury on all issues triable as
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  Speaker 1: of right by a jury. All right, folks, Well, that's
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  Speaker 1: going to wrap up Jane Doe number seventeen and her
• 1:10:30
  Speaker 1: allegations against Jeffrey Epstein, and as a state, we have
• 1:10:34
  Speaker 1: plenty more where that came from as well, including the
• 1:10:37
  Speaker 1: Jeffrey Epstein deposition that we're going to get around to
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  Speaker 1: this weekend. So buckle up, get your bar bags ready,
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  Speaker 1: because the discuss bus is about to leave. The station.
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  Speaker 1: All of the information that goes with this episode can
• 1:10:52
  Speaker 1: be found in the description box