Beyond The Horizon

The Epstein Survivors And Their Amended Complaint Against The USVI (Part 5) (7/17/24)

An amended complaint is a formal legal document that revises and updates the original complaint filed in a court case. It serves several key purposes and can be used in various situations to ensure that the legal proceedings are based on the most accurate and complete information available.Purposes of an Amended Complaint

Correcting Errors: If the original complaint contains typographical errors, inaccuracies, or other mistakes, an amended complaint can be filed to correct these issues. This ensures that the document is accurate and clear.
Adding New Information: As a case progresses, new facts or evidence might come to light. An amended complaint can include this new information to reflect the most current understanding of the situation.
Changing Legal Claims: Sometimes, the legal strategy may change, requiring adjustments to the claims or causes of action presented in the complaint. An amended complaint allows the plaintiff to modify their legal arguments.
Addressing Defenses: If the defendant raises specific defenses in their response to the original complaint, the plaintiff might need to amend the complaint to address these defenses or to clarify certain points.
Including Additional Parties: In some cases, new parties (either plaintiffs or defendants) may need to be added to the lawsuit. An amended complaint can be used to include these additional parties.

Procedure for Amending a ComplaintThe process for filing an amended complaint can vary depending on the jurisdiction and the specific rules of the court. However, some general steps and considerations typically apply:

Filing the Amendment: The plaintiff drafts the amended complaint, making the necessary changes and including any new information. This document is then filed with the court.
Serving the Defendant: The amended complaint must be served on the defendant, just like the original complaint. This gives the defendant an opportunity to respond to the new allegations or claims.
Court Approval: In some cases, especially if the amendment is made after certain deadlines, the plaintiff may need to seek the court's approval to file the amended complaint. This usually involves filing a motion to amend and explaining the reasons for the changes.
Response from Defendant: Once the amended complaint is served, the defendant has the right to respond, either by filing an answer or a motion to dismiss, depending on their legal strategy and the nature of the amendments.

Considerations and Limitations

Timing: The timing of the amendment is crucial. Early amendments (e.g., before the defendant has responded) are generally easier to make and often do not require court approval. Later amendments might be subject to stricter scrutiny and require a stronger justification.
Scope: The scope of the amendments can also be a factor. Minor corrections are typically less contentious, while significant changes to the claims or parties involved might require more detailed justification and may be more likely to face opposition from the defendant.
Strategic Use: Amending a complaint is a strategic tool that can strengthen a plaintiff's case. However, it must be used carefully to avoid unnecessary complications or delays in the proceedings.

(commercial at 8:51)

to contact me:

bobbycapucci@protonmail.com

source:

gov.uscourts.nysd.610915.6.0.pdf (courtlistener.com)

Duration:: 14m
Broadcast on:: 17 Jul 2024
Audio Format:: mp3

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See terms at racing.fanduel.com, gambling problem, call 1-800-Gambler. What's up, everyone, and welcome back to the Epstein Chronicles. In this episode, we're picking up where we left off with the survivors of mended complaint against the USVI. As in for a second cause of action, as to aiding, abetting, and inducing a sex-trafficking venture in violation of the Trafficking Victims Protection Act under US Code 18, Section 2, 1591, A1, N2, and 1595, 138. plaintiff's incorporate the foregoing paragraphs herein, as if set forth at length, 139, defendants and their officers, agents, and employees aided, abetted, and induced Epstein's sex-trafficking venture that was in and affecting interstate and foreign commerce together and with others in violation of US Code 18, Section 2, 1591, A1, and A2, 140. Under US Code 18, Section 2, defendants are punishable as a principle under US Code 18, Section 1591, A1, and A2, and thereby committed and perpetrated violations of Chapter 77, Title 18, US Code, when it aided, abetted, procured, and induced Epstein's sex-trafficking venture and sex-trafficking of plaintiffs, as well as many other young women, 141. Under US Code 18, Section 2, defendants committed and perpetrated crimes and violation of US Code 18, Section 1591, A1, and A2, by aiding, abetting, and inducing Epstein and his conspirators sex-trafficking venture and sex-trafficking of plaintiffs, as well as many other young women. As a consequence, plaintiffs, as well as many other young women, are victims of defendants criminally aiding, abetting, and inducing Epstein's violations of US Code 18, Section 1591, A1, and A2. These actions were in and affecting interstate and foreign commerce, 142. The crimes, the defendants aided and abetted R1, Epstein's, perpetrating of coercive sex-trafficking, in violation of US Code 18, Section 1591, A1, and 2, Epstein's co-conspirators knowingly benefiting from coercive sex-trafficking, in violation of US Code 18, Section 1591, A2. These crimes were in and affecting interstate and foreign commerce. On 43, defendants benefited financially and received things of value from their participation in the Epstein's sex-trafficking venture, including payments and other compensation from Epstein. On 44, acting through its officers and employees, the USVI itself perpetrated violations of Chapter 77, Title 18, US Code, including US Code 18, Section 1591, A1, and A2, by aiding, and inducing, a sex-trafficking venture and the sex-trafficking of plaintiffs as well as many other young women. Defendant directly violated Chapter 77 by committing and perpetrating these violations. 145, among other things, defendants aided, abetted, facilitated, and induced Epstein's sex-trafficking venture and sex-trafficking of plaintiffs, as well as many other young women, knowing that Epstein would use means of force, threats of force, fraud, coercion, and the combination of such means to cause plaintiffs as well as many other young women, some of whom were under the age of 18, to engage in commercial sex acts. 146, by aiding, abetting, and inducing Epstein's sex-trafficking venture and sex-trafficking of plaintiffs, as well as many other young women, defendants knowingly benefited both financially and by receiving things of value from participating in Epstein's sex-trafficking venture. 147, defendants and their officers and employees had actual knowledge that they were aiding, abetting, and inducing Epstein's sexual abuse and sex-trafficking conspiracy to recruit, solicit, entice, coerce, harbor, transport, obtain, and provide plaintiffs, as well as many other young women, into commercial sex acts, through the means of force, threats of force, fraud, abuse of process, and coercion. 148, defendants knew and should have known that Epstein had engaged in acts in violation of the TVPA, 149, despite such knowledge defendants intentionally aided, abetted, procured and induced Epstein and his co-conspirators violations of US Code 18, Section 1591, A&1, and A&2, which constituted perpetrating violations of those laws under US Code 18, Section 2. defendants knew and acted in reckless disregard of the fact that Epstein would coerce the fraud and force plaintiffs as well as many other young women to engage in commercial sex acts. 150, defendants' affirmative conduct of aiding, abetting, facilitating, procuring, and inducing Epstein and his co-conspirators violations was committed knowingly and in reckless disregard of the fact that Epstein would use governmental support provided by defendants as a means of defrauding, forcing, and coercing sex acts from plaintiffs as well as many other young women. defendants' conduct was outrageous and intentional. 151, defendants knowing and intentional conduct of aiding, abetting, and inducing Epstein's violations has caused plaintiffs as well as many other young women serious harm, including without limitation, physical, psychological, emotional, financial, and reputational harm. 152, defendants knowing and intentional conduct of aiding, abetting, and inducing Epstein's violations has caused plaintiffs as well as many other young women harmed that is sufficiently serious under all the surrounding circumstances to compel a reasonable person of the same background and in the same circumstances to perform or to continue performing commercial sexual activity in order to avoid incurring that harm. 153, defendants' criminal conduct and aiding, abetting, and inducing Epstein's TVPA violations was outrageous and intentional because it was deliberate, furtherance of a widespread and dangerous criminal sex trafficking organization. 154, defendants' intentional and/or negligent conduct has caused plaintiffs and many other young women serious harm, including without limitation, physical, psychological, emotional, financial, and reputational harm. 155, defendants' conduct and perpetrating TVPA violations was outrageous and intentional because it was in deliberate furtherance of a widespread and dangerous criminal sex trafficking organization, 156, by virtue of its knowing and intentional violations of U.S. code 18, section 1591, A&1, 1591, A&2, and 1595. Defenders are liable to plaintiffs for the damages that they sustained and reasonable attorney fees. By virtue of these intentional and outrageous violations of U.S. code 18, section 1591, A&1, 1591, A&2, and 1595. 157, defendants are liable to plaintiffs for punitive damages for their aforementioned conduct. 158, the amount of damages sought exceeds the jurisdiction of all lower courts which would otherwise have jurisdiction. 159, this action falls within exceptions to Article 16 of the CPLR. As for the third cause of action, as to conspiracy to commit violations of the trafficking victim Protection Act, under 18 U.S. code, section 1594, C, 1591, and 1595. 160, plaintiffs' incorporate the foregoing paragraphs as set forth herein at length. 161, defendants intentionally conspired with others, including Epstein and his other co-conspirators, by agreement and understanding to violate U.S. code 18, section 1591, A&1, and A&2, and 1591D, and the further Epstein's sex trafficking venture to coerce commercial sex acts from plaintiffs and other young victims, all in violation of U.S. code 18, section 1594C, defendants and their officers and employees directly conspired with Epstein himself to further the sex trafficking venture. 162, defendants conspiracy to violate U.S. code 18, section 1591, A&1, and A&2, was forbidden by U.S. code 18, section 1594C, and defendants thereby violated Chapter 77, Title 18. 163, defendants conspiracy directly, proximately, and foreseeably harm plaintiffs, and other young victims, by directly leading to their forcibly being caused to engage in commercial sex acts and, in other ways, defendants conspiracy victimize plaintiffs and other young victims. 164, defendants conspiracy to violate U.S. code 18, Section 1591D was forbidden by U.S. code 18, section 1594C, and defendants thereby violated Chapter 77, Title 18. You've heard of Pizza Hut's $7 deal lovers menu, right? All these delicious items for only $7 each when you buy two or more, but something's off. I mean, pizzas, melts, boneless wings, bacon, cheddar cheese, sticks, oven, big pastas, thin-abon mini rolls, and that's not even the whole menu. Product availability prices and participation may vary. Additional charges and exclusions may apply. Wings included are eight-count boneless. This summer, saddle up with the only sportsbook where you can bet on horse racing, FanDuel. Right now, new customers can get a no sweat first bet up to $500. Just download the app or go to fanduel.com/horses to score your no sweat bet up to $500. 21+ and present in Colorado offer valid on first real money wager of $5 or more, verified FD Racing account required, bonus issued in non-withdrawable racing site credit that expires seven days after issuance, max refund $500, restrictions apply, see terms at racing.fanduel.com, gambling problem, call 1-800-GAMBLER. 165. Defendants conspiracy directly, proximately, and foreseeably, harm plaintiffs and other young victims by directly leading to their forcibly being cause to engage in commercial sex acts and in other ways. 166. Defendants conspiracy, victimized plaintiffs, and other young victims. 167. Defendants conspired with Epstein and his other co-conspirators to further the Epstein sex trafficking venture and with the purpose of facilitating Epstein's illegal sex trafficking. Defendants had actual and/or constructive knowledge of Epstein's sex trafficking venture. Defendants acted with the specific intent to violate US Code 18, Section 1591A1, and A2, that is, with consciousness of the nature of Epstein's sex trafficking venture and with the specific intent to further the venture. Defendants and Epstein had a meeting of the minds as to the essential nature of the plan. 168. Defendants conspiracy with Epstein was part of its participation in his sex trafficking venture. Without defendant's agreement to facilitate the venture, Epstein would not have been in a position to move forward with his sex trafficking venture on the USVI and to recruit and entice victims of the venture there and transport them elsewhere to engage in commercial sex acts. 169. Defendants also conspired with Epstein and his other co-conspirators to obstruct, attempt to obstruct, to interfere with, and to prevent the enforcement of the TVPA, violating US Code 18, Section 1591D. The conspiracy included an agreement to keep Epstein's sex trafficking venture secret, or at least concealed, to the greatest extent possible. 4. Defendants intentionally committed overt acts in furtherance of the conspiracy agreement and understanding to violate US Code 18, Section 1591A by knowingly playing an active role in assisting supporting and facilitating the recruiting, enticing, coercing, harboring, transporting, and inducing, and forcibly causing plaintiffs and other young victims to engage in commercial sex acts through providing financial and other support for the Epstein's sex trafficking venture. A number of those acts were committed by First Lady Dijang, acting within the actual and apparent scope of her office to further USVI and Epstein's interests. We're going to wrap up right here, and in the next episode dealing with a topic we're going to pick up with 171, among the many overt acts intentionally committed. 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