Beyond The Horizon

The Epstein Survivors And Their Amended Complaint Against The USVI (Part 2) (7/16/24)

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 8:35)

to contact me:

bobbycapucci@protonmail.com

source:

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

Duration:: 16m
Broadcast on:: 16 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 amended complaint filed by the survivors against the USVI. Four, facts of the case. A) Epstein's sex trafficking ring and defendant's knowledge, assistance, and facilitation of the criminal enterprise. 45) The Epstein's sex trafficking venture originated in the early 1990s. From its inception until Jeffrey Epstein's arrest by the FBI for sex trafficking in 2019 and his subsequent death on August 10, 2019, by apparent suicide, the venture operated primarily for the purpose of learning young women and girls, including plaintiffs into a position where Jeffrey Epstein and his co-conspirators could coerce them to engage in commercial sex acts and commit sexual offenses against them. His venture provided financial and other benefits to those who assisted and enabled the venture. 46) The Epstein's sex trafficking venture was well-structured and grew increasingly more complex and powerful as it victimized more young women and as its relationships with the USVI and many government officials grew. 47) The Epstein's sex trafficking venture purpose included enticing, obtaining, harboring, transporting the young women, including plaintiffs to numerous places, including but not limited to the USVI, where they would be removed from their families, friends, and loved ones, and be completely isolated. The venture had everything a sex trafficking organization needed, funding, infrastructure, a place to operate, set an organization openly and without fear of interference or oversight, and complicit laws, employees, and government. It was by many accounts the most powerful and wealthiest sex trafficking venture ever created. Once in Epstein's clutches, each victim was taught and understood that she must completely be compliant with every demand Epstein or his clients made, otherwise she would certainly suffer serious reputational financial and psychological harm. 48) In creating and maintaining this network of victims worldwide, whom they could force to engage in commercial sex acts, Epstein conspired with others, including defendants and others, who facilitated his conduct by, among other things, recruiting victims, coercing victims, and scheduling their sexual abuse by Epstein at his New York mansion, his Palm Beach mansion, and his island in the USVI. Epstein's victims were young women and girls, like plaintiffs, who suffered severe abuse as Epstein's sex trafficking victims, and who believed that they had to remain loyal to the venture at all costs to survive. Epstein victimized hundreds of young women and girls, with the assistance of a wide network of co-conspirators, including the USVI and its many government officials and staff. 49) The sex trafficking venture knowingly used means a force, threats of force, fraud, coercion, including threats of serious harm or physical restraint, and abuse of law, and the legal process to cause Jane Doe's 1-6, and many dozens of others, similarly situated to engage in commercial sex acts. Epstein fraudulently represented to the victims, including plaintiffs, that he would take care of them in various ways, which ultimately allowed Epstein to cause them to engage in commercial sex acts with himself, and on occasions select others, as well as to create the opportunity for Epstein to sexually abuse them. 50) Among other things, Epstein causes victims to engage in commercial sex acts, 51, as one means of causing victims to engage in commercial sex acts, Epstein and his co-conspirators threatened that harm would come to victims if they did not comply with their demands, that they performed commercial sex acts. 52) As another means of causing victims to engage in commercial sex acts, Epstein and his co-conspirators fraudulently promised a further victim's educational or career aspirations if they would comply with his sexual demands. 53) Epstein and his co-conspirators also cause victims to engage in commercial sex acts, Epstein and his co-conspirators would gift his victims money and provide them with living accommodations, clothing, education, or other necessities. Epstein and his co-conspirators would then force them to pay off the debt by complying with Epstein's sexual demands. 54) Epstein recruited, solicited, enticed, harbored, obtained, provided, and transported his victims to cause them to engage in commercial sex acts in ways that were in and affecting interstate and foreign commerce, including using means of interstate communications such as cellular telephones and means of interstate and foreign travel such as aircraft that he owned and controlled, 55. Epstein transported his victims in interstate and foreign commerce, including transportation to and from his mansion, in this district, 56. The Epstein's sex trafficking venture transported victims across state boundaries between New York, Florida, and the USVI and elsewhere. 57) Epstein did not act alone. He created and maintained his sex trafficking venture with the assistance of other influential individuals and entities who knew or should have known that he was sexually abusing and sexually trafficking young women and girls but nevertheless supported the sex trafficking enterprise. Epstein's sex trafficking venture was not possible without the assistance and complicity of defendants who provided his operation with an appearance of legitimacy and special treatment to the sex trafficking venture, thereby ensuring its continued operation and sexual abuse and sex trafficking of young women and girls. Without defendants' participation, Epstein's sex trafficking scheme could not have existed nor flourished. 58) The USVI negligently and/or intentionally provided special treatment to Epstein and the sex trafficking venture through their territories, laws, employees, staff, airports, ports, and government staff and officials, thereby ensuring Epstein's sex trafficking ventures continued operation and sexual abuse and sex trafficking of young women and girls. Without the USVI's government inclusive of defendants, Epstein's sex trafficking scheme could not have existed and flourished undisturbed in the USVI. 59) defendants' USVI negligently hired, supervised, and retained defendants' John Those 1-100, 60. The victims, including plaintiff, could not escape from Epstein's enterprise because the Epstein's sex trafficking venture used the USVI laws and agencies, defendants and others to cause plaintiffs and many others, of similarly situated women to engage in commercial sex acts and remain in the USVI until Epstein permitted them to leave, as explained here in. 61) The Epstein's sex trafficking venture operated in and affected interstate and foreign commerce. In recruited, solicited, coerced, harbored, transported, and enticed some of his victims, including plaintiffs and others similarly situated to engage in commercial sex acts in, among other places, New York, including the Southern District of New York, Florida, and the USVI. 62) plaintiffs were injured as a result of the existence and success of the sex trafficking ring. For instance, Epstein arranged with defendants and/or their agents, servants, and/or employees to allow Jane Doe II and Jane Doe III into the USVI for the purpose of sexually abusing them, even though their visas were expired, which caused them to be sexually trafficked, abused, assaulted, and battered by Epstein in the USVI. Epstein could not and would not have sexually trafficked, abused, assaulted, and battered Jane Doe II and Jane Doe III in the USVI without the unlawful conduct of defendants and/or their agents, servants, and/or employees. 63) In approximately 2003 or 2004, Epstein brought Jane Doe IV to his office in Red Hook on saying Thomas for the purpose of sexually abusing her. Epstein's office had two doors, one that led out to an open courtyard, and the other to an area where defendants sealed a Zhang sat with her desk positioned adjacent against the exterior wall of Epstein's office. There, Epstein grabbed Jane Doe IV into his office from the courtyard entrance and raped her over his desk. The brutal assault lasted about ten minutes. When Epstein was finished, they exited through the other door where defendants sealed the Zhang was sitting. Given her proximity, the Zhang heard the sexual assault, yet she looked at Jane Doe IV straight into the eyes from her desk and did nothing at that time or at any time afterwards. Given her proximity, it would be impossible for her to have not heard the sexual assault, and yet she did nothing with that information at the time. We all have somewhere we're trying to get to. As the largest energy producer in Colorado, Chevron is working to responsibly meet rising energy demand. So everyone can get to where they want to be. You've arrived. That's Energy in Progress. Visit chevron.com/tankless. It's time for today's Lucky Land horoscope with Victoria Cash. Life's gotten mundane, so shake up the daily routine and be adventurous with a trip to Lucky Land. You know what they say, your chance to win starts with a spin. So go to luckylandslots.com to play over a hundred social casino style games for free for your chance to redeem some serious prizes. Get Lucky today at luckylandslots.com. Available to players in the US, excluding Washington and Michigan, no purchase necessary. VGW group void repurhibited by law, 18 plus turns in condition supply. 64. In 2002, Epstein took Jane Doe I to his office in Red Hook on St. Thomas. When they entered the office, defended the Zhang was sitting behind the desk. Epstein set a low tour and immediately took Jane Doe I down the short hallway into his office and immediately thruster against the wall trapping her. Epstein aggressively pulled down Jane Doe I's pants, ripped her panties to the side, and orally copulated her. In that moment, Jane Doe I was petrified, shocked, and didn't know what to do. The only word that was spoken was a soft no, but that did not even phase him as he proceeded to rape her. Knowing there were others in the office nearby, made Jane Doe I even more petrified, and in shock knowing others could hear what was happening. Defendant De Zhang was in very close proximity during this sexual attack, and heard the vicious assault, yet did nothing to stop it. Epstein was not phased in the slightest by De Zhang's close proximity. Jane Doe I came out disheveled and was seen by De Zhang. Given that De Zhang was in close physical proximity to the attack, could hear the attack, and did nothing to help Jane Doe I, Jane Doe I felt she had nowhere to go. After that experience, Jane Doe I knew she could not tell anyone as she began to fear this network behind the enterprise. Epstein continued to sexually assault her for years after, on the island. 65, in approximately 2004, even though Epstein knew that Jane Doe VI did not have a passport, Epstein arranged with defendants, their agents, servants, and/or employees for Jane Doe VI to be brought into the USVI and in the USVI Island residence for the purpose of sexually abusing her without question or hindrance, an arrangement that was executed successfully solely because of the help provided to Epstein by the defendants. Soon after Jane Doe VI arrived on Epstein's private USVI Island, he sexually assaulted and raped her in his bed. The next day he ordered Jane Doe VI to go with his staff to secure temporary travel documents from USVI officials. 66 On one occasion after already in the USVI, Jane Doe III's travel documents had expired. Epstein ordered Jane Doe III to take one of his boats to go to the main USVI island to specific USVI customs agent who would extender stay in the USVI. After Jane Doe III attempted to obtain travel documents from USVI officials without Epstein present, Jane Doe III returned to a state unsuccessful. Jane appeared annoyed and angry and escorted her down to the USVI office to the same designated USVI official who did not provide the documents requested on her earlier attempt. With Epstein present and without Jane Doe saying a word to the USVI customs agent, quickly provided Jane Doe III with the travel documents required. 67 The responses and reactions by the USVI customs agents indicated that USVI regularly and routinely provided Epstein with visas, passports and other travel documents to enable him to traffic his victims internationally including to the USVI. Jane Doe VI was escorted by Epstein's co-conspirators, a government to a government building on the main USVI island where two USVI custom agents and/or government officials chatted and laughed with the two Epstein associates while Jane Doe VI stood silent. After once asking Jane Doe VI any questions without Jane Doe VI providing any documentation supporting her identity or citizenship, without Jane Doe signing anything and without Jane Doe saying one word, the USVI officials gave Jane Doe VI documents authorizing her travel back into the US from the USVI. 68 Epstein could not and would not have sexually trafficked, abused, assaulted and battered Jane Doe VI in the USVI without the unlawful conduct of defendants and/or their agents servants and/or employees. 69 Epstein could not have sexually trafficked, abused, assaulted and battered, plaintiffs and other class members in the USVI without the unlawful conduct of defendants and/or their agents servants and/or employees. 70 In this complaint Jane Doe's 1-6 and other members of the class alleged defendants acted outrageously and intentionally but in addition wherever Jane Doe's 1-6 and other members of the class alleged that defendants acted with actual knowledge or in reckless disregard of the fact that the Epstein sex trafficking venture used means of force, threats of force, fraud, coercion, abuse of process or some combination thereof to cause a person to engage in commercial sex acts. Jane Doe's 1-6 and other members of the class also alleged that at a bare minimum the defendant should have known that Epstein's sex trafficking venture had used such means to engage in illegal sex trafficking in violation of US Code Section 1591-94 that they had constructive knowledge of Epstein's sex trafficking. Alright we're going to wrap up this episode right here and in the next episode we're going to pick up with B, the payoffs. All of the information that goes with this episode can be found in the description box. An official message from Medicare "A new law is helping me save more money on prescription drug costs. Maybe you can save too. With Medicare's extra help program my premium is zero and my out-of-pocket costs are low. Who should apply? Single people making less than $23,000 a year or married couples who make less than $31,000 a year. Even if you don't think you qualify it pays to find out go to ssa.gov/extrahelp. 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