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Lisa Doe And Her Allegations Against Jeffrey Epstein And His Estate (Part 1) · The Vault: The Epstein Files

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  Speaker 1: What's up everyone, and welcome back to the Epstein Chronicles.
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  In this episode, we're going to start taking a look
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  at the complaint made by Lisa Doe against the Epstein Estate.
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  Lisa Doe plaintiff versus Darren k Endyke and Richard D.
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  Con as joint personal representatives of the Estate of Jeffrey E. Epstein.
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  Plaintiff Lisa Doe by and through her undersigned council for
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  her claims against defendants alleges as follows. One, This action
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  is brought pursuant to US Code eighteen, section fifteen ninety
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  one through fifteen ninety five. Therefore, jurisdiction is proper under
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  US Code twenty eight, section thirteen thirty one. Two. Plaintiff
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  files this complaint under a pseudonym in order to protect
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  her identity, because this complaint makes allegations of a sensitive
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  sexual nature, the disclosure of which, in association with her name,
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  would cause further harm to her. Three. Plaintiff is currently
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  a resident of and domiciled in the state of New York. Four.
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  At all times material, Jeffrey Epstein was a citizen of
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  the United States and a resident of the US Virgin Islands.
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  Five Jeffrey Epstein was a man of extraordinary wealth who
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  traveled between and state regularly in multiple residences, including in
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  New York, New York, Palm Beach, Florida, New Mexico, and
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  in the United States Virgin Islands. Six. At all times
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  material to this cause of action. Jeffrey Epstein was an
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  adult male born in nineteen fifty three who died on
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  August tenth, twenty nineteen seven. Defendant Defendant Darren ky Endyke
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  and Richard D. kN as joint personal representatives of the
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  Estate of Jeffrey e Epstein. The Estate of Jeffrey e
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  Epstein was opened and domiciled in the United States Virgin Islands,
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  Saint Thomas Division, and is the legal entity responsible for intentional, criminal,
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  or tortious conduct committed by Jeffrey Epstein as described in
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  this conplat eight. At all times material here too. Defendant
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  ninety seventy First Street Corporation was a domestic business corporation
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  conducting business in New York, with its principal place of
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  business located at five seventy five Lexington Avenue, fourth floor,
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  New York, New York. Nine. At all times material here too.
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  Defendant Financial Trust Company Incorporated was and is the US
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  Virgin Islands corporation conducting business in multiple locations, including New York.
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  Ten at all times material here too. Defendant NESLLC NES
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  was and is a domestic limited liability company registered in
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  and conducting business in multiple locations including New York eleven
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  at all times material here too. Defendant. HBRK Associates Incorporated.
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  HBRK is and was a domestic business corporation registered in
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  and conducting business in multiple locations, including New York, with
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  a registered agent located at thirteen sixty five York Avenue,
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  Apartment twenty eight, New York, New York, one zero zero
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  two one Twelve Corporate defendants NESLLC Financial Trust Company Incorporated,
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  ninety seventy first Street and HBRK Associates Incorporated, referred to
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  as corporate defendants, each performed business and whole or part
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  in New York. Thirteen. Plaintiff intends to amend this complaint
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  to add or substitute additional parties as discovery reveals the
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  identities of other tortious corporate or individual actors. Fourteen. Jeffrey
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  Epstein is the leader of a complex commercial sex trafficking
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  and abuse ring. Was an officer, director, or employer of
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  many corporate entities registered in various states throughout the United States,
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  one or more of which may also be legally responsible
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  for the crimes he committed against young females, including miners
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  such as the plaintiff. Fifteen. Additionally, individuals who worked at
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  residences where sexual criminal acts were committed, or friends or
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  acquaintances who assisted Jeffrey Epstein in committing such violations, or
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  who were employed, through, or worked for numerous other corporate
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  entities whose participation caused or contributed to causing the sexual
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  violations that caused harm to plaintiff may additionally be added
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  as defendants once their identities are revealed. Sixteen. A substantial
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  part of the acts, events, and omissions giving rise to
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  this cause of action occurred in the Southern District of
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  New York. Venue is proper in this district US Code
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  twenty eight, Section thirteen ninety one B and two seventeen
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  at all times material to this cause of action. Jeffrey
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  Epstein legally represented now through Darren k Endyke and Richard D.
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  kN as joint personal representatives of the estate of Jeffrey E. Epstein,
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  and referred to herein as a state of Jeffrey E.
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  Epstein and corporate defendants owed a duty to plaintiff to
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  treat her in a non negligent manner and not to
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  commit or conspire to commit, or cause to be committed intentional, criminal, fraudulent,
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  or tortious acts against plaintiff, including any acts that would
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  cause plaintiff to be harmed through conduct committed against her
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  in violation of US Code eighteen, section fifteen ninety one
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  through fifteen ninety five. The factual allegations eighteen at all
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  times material to this cause of action. Jeffrey Epstein was
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  an adult male over forty five years old. Epstein was
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  a tremendously wealthy individual, widely recognized as a billionaire who
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  used his wealth, power, resources, and connections to commit illegal
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  sexual crimes in violation of federal and state laws, and
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  who employed or conspired with other individuals and corporate entities
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  to assist them in committing those crimes or torts, or
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  who facilitated or enabled those acts to occur. Nineteen Epstein
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  displayed his enormous wealth power and influence to his employees,
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  to the employees of the corporate or company entities who
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  worked at his direction, to the victims procured for sexual purposes,
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  and to the public in order to advance, carry out
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  and conceal his crimes and his torts twenty. At all
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  relevant times, Epstein had access to numerous mansions, as well
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  as a fleet of airplanes, motor vehicles, boats, and one
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  or more helicopters. For example, he regularly traveled by private
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  jet aboard a Boeing aircraft of make and model B
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  seven twenty seven thirty one H with tail number and
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  nine zero eight JE, or a Gulfstream aircraft of make
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  and model G DASH one one five nine B with
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  tail number and nine zero nine JE twenty one. Jeffrey
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  Epstein also frequently inhabited and traveled between numerous properties and homes,
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  each of which admitted to being owned or controlled by him,
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  including a Manhattan Town home located at nine East seventy
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  first Street in New York, valued conservatively by Jeffrey Epstein's
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  owned admission at fifty five million, nine hundred and thirty
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  one thousand, A ranch located at forty nine Zoro Ranch Road, Stanley,
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  New Mexico, valued conservatively by Jeffrey Epstein's own admission at
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  seventeen million, two hundred and forty six thousand, two hundred
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  and eight dollars. A home located at three fifty eight
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  Lbrio Way, pom Beach, Florida, valued conservatively by Jeffrey Epstein's
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  own admission at twelve million, three hundred and eighty thousand,
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  two hundred and nine dollars. An apartment located at twenty
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  two Avenue Folk, Paris, France, valued conservatively by Jeffrey Epstein's
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  owned admission at eight million, six hundred and seventy two
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  thousand and eight hundred and twenty dollars. An island located
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  at Greater Saint James Island number six A USVII zero
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  zero eight zero two parcels A, B and C, and
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  an island Little Saint James Island number six B USVII
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  zero zero eight zero two, A, B and C. See
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  Jeffrey Epstein Asset Summary, June thirtieth, twenty nineteen twenty two.
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  Epstein controlled or was otherwise affiliated with, the corporation or
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  business entities that owned, managed, or maintained each of the
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  real properties listed in the preceding paragraph twenty three. The
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  allegations herein concerned Jeffrey Epstein's tortias conduct committed against plaintiff
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  while at the residence owned by the defendant nine East.
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  Many such acts were facilitated by defendant nes or defendant
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  HBRK twenty four. Epstein had a compulsive sexual preference for
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  young females, some as young as fourteen years old, and
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  acted on that sexual preference for decades. Twenty five. Epstein
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  enjoyed sexual contact with young females, including minor children, and
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  also took pleasure corrupting vulnerable and innocent young females, including
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  minor children, into engaging in sexual acts with them. Twenty six.
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  Epstein directed a complex system of individuals, including employees and
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  associates of defendant entities, to work in concert and at
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  his direction, for the purpose of harming teenage girls through
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  sexual exploitation, abuse, and trafficking. Twenty seven. It was widely
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  known among individuals regularly in Epstein's presence that he obtained
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  pleasure from corrupting and inducing vulnerable young females into engaging
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  and uncomfortable and unwanted sexual acts for his own gratification.
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  Twenty eight. Epstein's illegal sexual activities were investigated by law
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  enforcement on at least two occasions, once in two thousand
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  and five through two thousand and eight by the United
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  States Attorney for the Southern District of Florida, and more
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  recently by the United States Attorney for the Southern District
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  of New York twenty nine. On July second, twenty nineteen,
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  the United States Attorney's Office for the Southern District of
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  New York filed the sealed two account indictment, including one
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  count of sex trafficking conspira and one count of sex
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  trafficking for violation of US Code fifteen ninety one, in
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  part to Epstein's criminal activities against children in the New
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  York mansion located at ninety seventy first Street thirty. On
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  July eighth, twenty nineteen, Jeffrey Epstein was arrested pursuant to
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  the aforementioned indictment, which is attached here too as Exhibit
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  B thirty one. The indictment stated in part and plaintiff
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  herein adopts is true and relevant to her complaint that
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  Jeffrey Epstein, the defendant, entysedon, recruited, and caused to be
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  entysed in, recruited minor girls to visit his mansion in Manhattan,
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  New York and his estate in Palm Beach, Florida, to
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  engage in sex acts with them, after which the victims
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  were given hundreds of dollars in cash criminal indictment at
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  one thirty two. Moreover, and in order to maintain an
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  increase the supply of victims, Epstein also paid certain of
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  his victims to recruit additional girls to be similarly abused
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  by Epstein. In this way, Epstein created a vast network
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  of underage victims for him to sexually exploit in locations
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  including New York and Palm Beach thirty three. The victims
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  described herein were as young as fourteen years old at
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  the time they were abused by Jeffrey Epstein, and were
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  for various reasons, often particularly vulnerable to exploitation. Epstein intentionally
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  sought out miners and knew that many of his victims
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  were in fact under the age of eighteen, including because
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  in some instances minor victims expressly told them their age
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  thirty four. In creating and maintaining this network of minor
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  victims in multiple states to sexually abuse and exploit, Jeffrey
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  Epstein worked and conspired with others, including employees and dissociates
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  who facilitated his conduct by, among other things, contacting victims
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  and scheduling their sexual encounters with Epstein at the New
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  York residence and at the pom Beach residence. Criminal Indictment
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  at two five. The indictment further explained and plaintiff adopts
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  and alleges that victims were initially recruited to provide massages
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  to Epstein, which would be performed nude or partially nude,
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  would become increasingly sexual in nature, and would typically include
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  one or more sex acts. Criminal Indictment at three. All right, folks,
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  we're going to wrap up this episode here and in
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  the next episode we'll pick up where we left off.
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  All of the information that goes with this episode can
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  be found in the description box.