Beyond The Horizon
The Epstein Survivors And Their Amended Complaint Against The USVI (Part 3) (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.
- 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.
- 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 8:48)
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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Go to ssa.gov/extrahelp paid for by the US Department of Health and Human Services. What's up, everyone, and welcome back to the Epstein Chronicles. In this episode, we're picking up where we left off, with the amended complaint, filed by Epstein survivors against the USVI, be the pay-offs. 71. To support and expand this extravagant empire, Epstein gave payments and other benefits to the highest USVI government officials. 72. Epstein paid hundreds of thousands of dollars to USVI government entities, and officials for over two decades, including paying school tuition for Governor Dajang's children. Many of Epstein's payments to politicians were advised and directed by the USVI's First Lady Dajang. A USVI government official, and bought Epstein's loyalty and access among USVI politicians. 73. Governor Kenneth Mapp, USVI's Governor, from 2015 to 2018, asked Epstein to advise him on how to increase the USVI's business investments in deal with the USVI's structural fiscal imbalance. He specifically asked Epstein to spread word that USVI was pushing for business investments and requested Epstein's input on issuing critically needed bonds to finance USVI's operations. 74. Governor Mapp also asked Epstein to assist him in developing a means for Economic Development Commission, hereafter as EDC, beneficiaries to repatriate their income to make USVI's EDC program more attractive, and one of Epstein's lawyers drafted a proposed legislation for the Governor. As per the USVI's own legislation, the EDC Board is under the general supervision and direction of the Governor. Virgin Island Code 29, Section 1101(b) As such, actions of the EDC are done of and by the USVI government, 75. On one occasion when USVI government was desperate for money, USVI officials affirmatively and directly solicited Epstein's assistance. Epstein worked with both a sitting and former USVI Governor on a plan to secure a cash by extending it a $50 million loan collateralized by the USVI islands. 76. First Lady Dijang suggested that Epstein put Senator Salistino White on a monthly retainer to obtain government loyalty and access. First Lady Dijang also directed payments from Epstein's companies to political action committees for the Virgin Island candidates. 77. Epstein also freely loaned the Dijang family money in 2015 former Governor Dijang was arrested on charges of using $500,000 of public money to improve his private home. Former Governor Dijang resolved the criminal case by paying a settlement of $380,000 without admitting wrongdoing by successfully borrowing $215,000 from Epstein to pay the settlement. 78. Epstein and his colleagues loaned Stacey Plaskit $30,000 to support her political campaign. It was the attorney for the EDC when it approved the $300 million in tax breaks to Epstein's companies and had worked for Epstein's attorney. 79. By way of example only, Epstein compensated a USVI customs agent and/or a border control worker under the guise of playing Caribbean drums for him on his island. See the Quid Pro quote. Defendants assisted Epstein in operating and expanding his criminal enterprise. 80. In exchange for Epstein's payments to defendants and various officials and agents within the USVI government, they provided him with special treatment in order to facilitate his crimes. 81. In exchange for his payoffs, Epstein received one influence over the very laws that were supposed to constrain them. 2. Wavers of sex offender monitoring requirements. 3. 300 million in subsidies to the allegedly sham companies he used for sex trafficking. 4. Facilitation of visas, licenses, and/or ignoring requirements for same and other forms of government assistance that enabled criminal conduct. 5. Immunity from investigation and scrutiny. I. Epstein provides input to USVI's proposed sex offender monitoring legislation and is given a waiver of compliance from it. 82. In 2002, the USVI First Lady solicited Epstein's input on USVI's pending sex offender monitoring legislation and shared draft language from the DOJ with Epstein, writing, "This is the suggested language. Will it work for you?" Epstein responded with directions on how to loosen the restrictions. 83. In particular, Epstein was concerned that the proposed bill included a 21-day notice requirement, which would prevent him and others from coming and going as freely as he wanted. 84. The First Lady responded that, as Attorney General Vincent Frazier had a deadline to submit the legislation, they had to develop the language that would address Epstein's concerns by Thursday because the governor would be traveling for a week and the Attorney General had to submit the proposed legislation during that time frame. 85. Epstein and his lawyers continue to stay in touch with the USVI Justice Department attorneys and various senators in order to influence the text of the sex offender monitoring bill. 86. When Epstein's preferred language was admitted from the final bill, the First Lady assured Epstein that we will work with Vincent Frazier, then Attorney General, to give the discretion for status quo for you, that's the least he can do. 87. With the assistance of First Lady Dajang, the Attorney General Vincent Frazier promptly provided Epstein with special treatment, a waiver of the 21-day prior notice requirement for Epstein when traveling out of the Virgin Islands. 88. After Epstein's attorneys complained again, the Attorney General loosened it further, offering that Epstein be allowed to notify the USVI Justice Department of his intention to travel out of the USVI 24 hours prior to his departure. 89. Epstein was thus allowed to circumvent the recently passed legislation with assistance of Senator Carlton Dow, Senator Celestino White, and Attorney General Vincent Frazier. 90. Had his 91-day notice requirement been enforced, Epstein would not have been able to freely traffic young women and girls to the USVI as he did for years. 2. The USVI gave Epstein Enterprise 300 million in tax breaks, 91. For 20 years, USVI subsidized the operation of Epstein's two USVI-based companies that were fronts for his sex trafficking enterprise by granting them and by extension Epstein between 100% and 90% reductions in income taxes. 92. The ultimate decision to provide such tax breaks was made by the USVI governor. Plaskett was the attorney on the EDC responsible for, upon information and belief, recommending that the EDC provides these benefits to Epstein and his companies and enterprise. 93. These tax breaks amounted to 300 million in direct benefits to Epstein and his companies and enterprise. 3. Government officials and workers gave Epstein free rein in the country, bypassing customs, law enforcement, airport and coast guard security and were instructed to disregard any pleas for help from the victims. 94. With the help of First Lady Dijang and other government officials and staff, Epstein traveled openly through USVI airports, accompanied by young sex trafficked women and girls. 95. Defendants were responsible for monitoring Epstein's movements after his release from Palm Beach County Jail in 2009 for procuring a minor for prostitution and felony solicitation, but admittedly took no steps to ensure that he was no longer harming minors. 96. Defendant, First Lady Dijang was an active player in providing Epstein with numerous opportunities to influence government for the benefit of Epstein and his companies. Throughout their relationship, the First Lady, often facilitated gifts from Epstein to airport personnel and 78 customs employees. 97. Despite Epstein's status as a sex offender, US customs officials on the USVI never examined either the passports or luggage of anyone arriving on Epstein's private jet. In fact, Epstein's clients and his victims were never mandated to enter through customs. They complained from the private jet before boarding Epstein's helicopter or boat. 98. On information and belief, Epstein and/or his assistants, agents and others, seized victims passports with a full knowledge and consent of defendants who were directed not to assist the victims if they complained of their virtual captivity. 99. Indeed, Epstein complained by email to First Lady Dijang in 2010 because the US customs official caused him difficulty. And First Lady Dijang promised that she would ensure this would not happen again by calling the head of customs. 100. USVI, its officials and law enforcement never investigated Epstein even after Florida law enforcement faxed Epstein's sexual predator registration information to USVI's Department of Justice officials in July of 2010 with which they included a news article confirming his status as a sex offender. 101. Upon information and belief, USVI officials directed law enforcement officers, airport personnel, customs officials, and other government employees to extend any courtesy or assistance to Epstein and as affluent customers and guests as part of their official duties. 102. Upon information and belief, USVI officials directed law enforcement officers, airport personnel, customs officials, and any other government employees to disregard or refuse any requests for assistance by any of Epstein's female victims, such as securing a return of the passports from Epstein and to report any pleas for help directly to Epstein. 4. Defendant secured visas so that Epstein could transport his victims into the USVI. 103. First Lady Dijang, who was employed by Epstein at his office as his manager, facilitated him in obtaining travel documents, including visas, to bring minor women from other countries to the USVI. Epstein's Lady Dijang earned $200,000 in annual salary, in addition to payment of her children's private school and college tuition, among other perks. 104. Upon information and belief, USVI also arranged for three young European women to secure student visas to enroll at the University of the Virgin Islands to attend the custom tailored class to provide cover for the virtual enslavement of these women. Epstein's quid pro quo was a 20,000 donation to the University through one of his companies. 105. Epstein corresponded with First Lady Dijang and other high-level government officials about securing visas and setting up ESL classes for many of his female victims in USVI. On one occasion when Ms. Dijang became aware that at least one of Epstein's young female associates had only a B1 temporary business visitor visa, she worked with Epstein to contrive a means for an individual to obtain an I-20 through the University of the Virgin Islands. 106. The First Lady also frequently assisted on immigration matters related to Epstein's foreign female associates by speaking with immigration attorneys on Epstein's behalf and by coordinating with members of the USVI's government for letters of support for visa applications. But for defendants above described negligent and/or reckless acts and/or emissions, plaintiff and other similarly situated would not have suffered the mental and physical anguish she endures to date. A new law is helping me save more money on prescription drug costs. You may be able to save too. With Medicare's extra help program, my premium is zero and my out-of-pocket costs are low. Who should apply? 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