Beyond The Horizon
The Lawsuit Filed By The Epstein Survivors Against The USVI: The Complaint (Part 6) (7/10/24)
The case Doe 1 et al v. Government of the United States Virgin Islands et al involves multiple plaintiffs, identified as Jane Does 1 through 6, filing a lawsuit against various defendants including the Government of the United States Virgin Islands, former and current government officials, and other individuals.
The plaintiffs are represented by Merson Law, PLLC, and other legal representatives, and they have been granted the right to proceed under pseudonyms to protect their identities. The nature of the suit is categorized under personal injury, specifically other personal injuries. The case was filed on November 22, 2023, and is being heard in the Southern District of New York by Judge Arun Subramanian.
Significant developments in the case include the granting of the plaintiffs' motion to proceed anonymously and the filing of an amended complaint. Defendants have filed motions to dismiss, citing issues such as improper service, lack of personal jurisdiction, improper venue, and failure to state a claim. The court has granted the plaintiffs leave to file a second amended complaint, and the defendants' deadlines to respond have been updated accordingly.
In this episode, we begin our look at the complaint filed by the survivors.
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to contact me:
bobbycapucci@protonmail.com
source:
gov.uscourts.nysd.610915.1.0.pdf (courtlistener.com)
- Duration:
- 14m
- Broadcast on:
- 10 Jul 2024
- Audio Format:
- mp3
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 and their lawsuit against the US Virgin Islands 155. Defendants actions and furtherance of Epstein's conspiracy were intertwined with Epstein's sex trafficking venture as providing a place, protection, favorable laws and beneficial treatment for the sex trafficking venture were essential tools for Epstein to commit coercive commercial sex acts 156. It was part of the conspiracy that defendants would financially benefit from providing financial support for the Epstein's sex trafficking venture. Defendants did financially benefit from its participation in the venture including receiving valuable donations and business opportunities from Epstein 157. Defendants participation and furthering Epstein's sex trafficking venture was intentional and willful and therefore defendants intentionally and willfully caused Epstein's commission of the forcible commercial sex acts with plaintiffs as well as many other young women to engage in commercial sex acts 158. Defendant knew and acted in reckless disregard of the fact and should have known that its conspiracy would directly and approximately lead to unlawful coercive commercial sex acts by Epstein with young women and girls including plaintiffs as well as many other young women. The conspiracy that defendants joined had specific knowledge that plaintiffs as well as many other young women were being coercively sex trafficked by Epstein. The conspiracy's knowledge extended to meeting and knowing Epstein's victims because Epstein and his co-conspirators met some of the victims including Jane Doe. Specifically First Lady Dijang met new many of Epstein's victims 160. Defendants conspired to violate US code 18 section 1591A with Epstein and through its affirmative acts and substantial support to Epstein committed perpetrated and directly and approximately caused plaintiffs as well as many other young women to engage in commercial sex acts through means of force, threats of force, fraud, coercion and a combination of such means 161. Defendants benefited financially from conspiring to participate in the Epstein's sex trafficking venture which defendants knew and should have known that had engaged in coercive sex trafficking and violation of US code 18 section 1591A1 and A2 as well as obstruction of the enforcement of the TVPA and violation of US code 18 section 1591D 162. Defendants conspiracy is caused plaintiffs as well as many other young women serious harm including without limitation, physical, psychological, financial and reputational harm. That harm was directly and proximately caused by the conspiracy and the harm resulting from conspiracy was foreseeable. 163. Defendants conspiracy has caused plaintiffs harm 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. 164. By virtue of these violations of US code 18 section 1594C defendants are liable to plaintiffs for the damages she sustained and reasonable attorney fees under US code 18 section 1595 451. 165. By virtue of defendants conspiracy to violate US code 18 section 1594C defendants are liable to plaintiffs for punitive damages under US code 18 section 1595 166. The amount of damages sought exceeds the jurisdiction of all lower courts which would otherwise have jurisdiction 167. This action falls with an exception to Article 16 of the CPLR. As in for a fourth cause of action as to negligence 168. Representatives incorporate the foregoing paragraphs to set forth herein at length 169. At all times mentioned herein defendants, owed a duty of care including but not limited to ensuring the citizens, aliens and travelers to USVI are protected by the USVI government uniformly under the federal law including US code 18 section 1591 1594 and 1595 prohibiting the facilitation and promotion of sex trafficking and the profiting thereof 170. At all times mentioned herein defendants, owed a duty of care including but not limited to ensuring its citizens, aliens, the travelers to USVI are reasonably protected by the USVI government under the federal law prohibiting sex trafficking and in the promotion of sex trafficking and facilitating of sex trafficking when on USVI's territories. Section 71, defendants acted under the complete supervision and control of the USVI. 172, USVI had a duty to supervise their government employees such as defendants to ensure that the actions and following government directed orders do not promote, encourage or facilitate sex trafficking within the USVI from the USVI or to the USVI. 173, USVI had a duty to supervise their government employees defendants to ensure their actions and following government directed orders enforce the law reasonably and equally within the USVI. 174, at all times mentioned herein defendants and/or their agents served and/or employees breached the above stated duty in a negligent manner and enabled facilitated and allowed Epstein sex trafficking to continue unfettered. 175, defendants were negligent in their failure to carry out their jobs, positions and duties as government employees to their fullest extent and instead following orders from others, directing them to ignore Epstein's enterprise of continuous and open sex trafficking of young women and/or directing them to provide specialized services to Epstein a civilian in furtherance of Epstein's sex trafficking scheme. 176, defendants as USVI custom agents facilitated Epstein's, his associates and many female victims being trafficked by Epstein, including plaintiffs, by failing to check and/or inspect plaintiffs and Epstein's guests for legally valid travel documents, including custom forms, passports and/or visas, by failing to inquire as to Jane Doe and Epstein's guests legally valid travel documents, including custom forms, passports and/or visas, by failing to require plaintiffs and Epstein's guests to provide and/or present the agents with legally valid and require travel documents, including customs forms, passports and/or visas, by allowing plaintiffs Epstein and his associates to enter and remain on USVI territory without the proper travel documentation, by failing to ensure plaintiffs, Epstein and his associates were entering the USVI legally, by failing to ensure plaintiffs Epstein and his associates did not remain in the USVI illegally, by failing to question and/or investigate plaintiffs, and the other sex trafficking victims to ensure that they were in the USVI legally on their own accord and not being sex trafficked, by failing to ensure plaintiffs Epstein and his associates were leaving the USVI legally and of their own accord, by in accordance with government orders, not conducting searches, nor questioning of Epstein and his female guests, by in accordance with government orders not detaining under any circumstances Epstein and his female guests, by in accordance with government orders not questioning Epstein and any of his female guests, providing any and all courtesies to Epstein and by failing to perform the proper checks when granting plaintiff Epstein and his associates entry into the USVI, 177, defendants as USVI air traffic controllers, facilitated Epstein and his associates, and many female victims being trafficked by Epstein, including plaintiffs, by allowing Epstein to land his plane, at the USVI airports without entering the plane, providing and and any and all courtesies to Epstein, by allowing Epstein to land his plane at USVI airports, without inspecting the plane, by allowing and ensuring Epstein could at all times land his plane in isolated areas to protect his sex trafficking enterprise, to allowing Epstein to land his plane and disembark without any government oversight or inquiry, by allowing plaintiffs Epstein and his associates to enter and remain on USVI territory without checking them for the proper travel documentation, by failing to ensure plaintiffs Epstein and his associates were entering the USVI legally, and by failing to perform the proper checks when granting plaintiffs Epstein and his associates entry into the USVI, 178, defendants as USVI airport baggage check agents, facilitated Epstein's his associates, and many female victims being trafficked by Epstein, including plaintiffs, by allowing Epstein to land his plane at the USVI airports, without entering the plane, by allowing Epstein to land his plane at the USVI airports without inspecting the plane, by allowing and ensuring Epstein could at all times land his plane in isolated areas to protect his sex trafficking enterprise, providing any and all courtesy to Epstein, by in accordance with government orders, not conducting searches of Epstein and his female guests, by failing to question and/or investigate plaintiffs, and other sex trafficking victims, to ensure that they were in the USVI legally, on their own accord, and not being sex trafficked, by failing to question and/or investigate plaintiffs, and the other sex trafficking victims to ensure that they were in the USVI legally, on their own accord, and not being sex trafficked, by in accordance with the government's orders, not detaining, under any circumstances Epstein and his female guests, by in accordance with government orders, not questioning Epstein and any of his female guests, to allowing Epstein to land his plane and disembark without any government oversight or inquiry, by allowing plaintiff Epstein, and his associates were entering the USVI legally, and by failing to perform the proper checks when granting plaintiff Epstein and his associates entry into the USVI, 179, defendants, as USVI police officers facilitated Epstein, his associates, and many female victims being trafficked by Epstein, including plaintiffs, by when instructed providing Epstein with protection when traveling around USVI, by in accordance with government orders, not conducting searches of Epstein and his female guests, by failing to question and/or investigate plaintiffs, and the other sex trafficking victims to ensure that they were in the USVI legally, on their own accord, and not being trafficked, by in accordance with government orders, not detaining, under any circumstances Epstein and his female guests, by in accordance with government orders, not questioning Epstein and any of his female guests, and in providing any and all courtesy to Epstein when in USVI, 180, defendants as USVI Coast Guard agents facilitated Epstein as associates and many female victims being trafficked by Epstein, including Jane Doe, in providing any and all courtesy to Epstein on the USVI waterways, by in accordance with government orders, not conducting searches of Epstein and his female guests, by failing to question and/or investigate plaintiffs, and the other sex trafficking victims to ensure that they were in the USVI legally, on their own accord and not being sex trafficked, by in accordance with government orders, not detaining, under any circumstances Epstein and his female guests, by in accordance with government orders, not questioning Epstein and any of his female guests, by in accordance with government orders, not boarding, searching, and/or inspecting any of Epstein's watercrafts or boats, providing, and any and all courtesy to Epstein, by allowing and ensuring Epstein could travel and traffic females freely on the waves of the USVI, and by failing to perform the proper checks when granting plaintiff Epstein and his associates entry into the USVI. 181 As a result of defendants' acts and/or emissions, Epstein's sex trafficking enterprise was able to continue to traffic plaintiffs and as a result thereof, plaintiffs were continually and repeatedly sexually abused by Epstein and others within his sex trafficking venture and suffered severe and serious injuries. 182 As set forth above, defendants breach of their duty, two plaintiffs and others cause plaintiffs and others to suffer severe injuries and damages. 183 The amount of damages sought exceeds the jurisdiction of all lower courts which would otherwise have jurisdiction, 184 This action falls within exceptions to Article 16 of the CPLR. 7 Request for Relief 185 Jane Doe 1, Jane Doe 2, Jane Doe 3, Jane Doe 4, and Jane Doe 5 respectfully request that the court enter judgment in her favor and against Deutsche Bank as follows. A The court certify the class name Jane Doe 1, Jane Doe 2, Jane Doe 3, Jane Doe 4, and Jane Doe 5 as class representatives and appoint their lawyers as class counsel. B That the court award plaintiffs and other members of the class compensatory, consequential general and nominal damages against defendants in an amount to be determined at trial. C That the court award punitive and exemplary damages and treble damages against defendants in an amount to be determined at trial. D That the court award plaintiffs the cost and disinbursements of the action along with reasonable attorney fees, costs, and expenses. E That the court award pre-imposed judgment interest at the maximum legal rate and death that the court grant all such and further relief as it deems Justin proper. Jury Demand 186 Pursuant of FedRC Procedure 38B, plaintiffs hereby demand a trial by jury as to all issues. This was dated on November 22nd, 2023 and it was signed by Jordan K. Merson. Alright folks that's going to do it for the original complaint and we're just going to work our way through the whole entire docket now that I have my hands on it. That way we're up to date completely when it comes to this lawsuit that has to do with the USVI and the survivors. I feel like this is more relevant than us beating a dead horse and talking about topics we've discussed a million times over. So we're just going to keep diving into these court documents, we're going to keep on furling all this bullshit, and we're going to keep giving you a little look into the closed room. But for now that's going to do it for this one. All of the information that goes with this episode can be found in the description box.