Beyond The Horizon

The Lawsuit Filed By The Epstein Survivors Against The USVI: The Complaint (Part 5) (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:: 11m
Broadcast on:: 10 Jul 2024
Audio Format:: mp3

How dangerous is it to unwrap a burger at 40 miles per hour? More so than you think. In a little over two seconds, your car can travel slightly more than 117 feet, which is the same length as 20 bicycles. Anything that distracts you while driving is dangerous. That's why driving while texting can be deadly, too. So put it down. It can wait. Don't drive distracted. Shift into safe. A message from the Colorado Department of Transportation. What's up, everyone? And welcome back to the Epstein Chronicles. In this episode, we're picking up where we left off, with the original complaint filed by the survivors of Jeffrey Epstein against the United States Virgin Islands. So let's dive back in. 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 U.S. Code 18, Section 2, 1591, A1 and 2, and 1595, as to all defendants. 121, plaintiff incorporates the foregoing paragraphs herein, as if set forth at length. 122, 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 U.S. Code 18, Section 2, 1591, A1, and A2. 123, under U.S. Code 18, Section 2, defendants are punishable as a principal under U.S. Code 18, Section 1591A, and 1, and A2, and thereby committed and perpetrated violations of Chapter 77, Title 18, U.S. 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. 124, under U.S. Code 18, Section 2, defendants committed and perpetrated crimes and violation of U.S. 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 U.S. Code 18, Section 1591, A1, and A1, and A2. These actions were in and affecting interstate and foreign commerce. 126, 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. 127, acting through its officers and employees, the USVI itself perpetrated violations of Chapter 77, Title 18, U.S. Code, including U.S. Code 18, Section 1591, A1, and A2, by aiding, abetting, and inducing a sex trafficking venture and the sex trafficking of plaintiffs, as well as many other young women, defendants directly violated Chapter 77, by committing and perpetrating these violations. 128, 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. 129, 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. 130, 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. 131, defendants knew and should have known that Epstein had engaged in acts of violations of the TVPA. 132, despite such knowledge, defendants intentionally aided, abetted, procured, and induced Epstein and its 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. 133, defendants affirmative conduct of aiding, abetting facilitated, 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. 134, 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. 135, defendants knowing and intentional conduct of aiding, abetting, and inducing Epstein's violations has caused plaintiffs as well as many other young women, 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. 136, defendants criminal conduct in aiding, abetting, and inducing Epstein's TVPA violations was outrageous and intentional, because it was in deliberate furtherance of a widespread and dangerous criminal sex trafficking organization. 137, 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. 138, defendants conduct in perpetrating TVPA violations was outrageous and intentional, because it was in deliberate furtherance of a widespread and dangerous criminal sex trafficking organization. 139, by virtue of its knowing and intentional violations of US Code 18, Section 1591, A&1, 1591, A&2, and 1595, defendants are liable to plaintiffs for the damages that they sustained and a reasonable attorney's fees. By virtue of these intentional and outrageous violations of US Code 18, Section 1591, A&1, 1591, A&2, and 1595. 140, defendants are liable to plaintiffs for punitive damages for the aforementioned conduct. 141, the amount of damages sought exceeds the jurisdiction of all lower courts, which would otherwise have jurisdiction. 142, this action falls within exceptions to Article 16 of the CPLR. As in four, the third cause of action has to conspiracy to commit violations of the Trafficking Victim Protection Act under US Code 18, Section 1594C, 1591, and 1595. 143, plaintiffs incorporate the foregoing paragraphs as set forth here in at length, 144. defendants intentionally conspired with others, including Epstein and his other co-conspirators, by agreement and understanding to violate US Code 18, Section 1591, A&1, and A&2, and 1591D, and a further Epstein sex trafficking venture to coerce commercial sex acts from plaintiffs and other young victims, all in violation of US Code 18, Section 1594C. defendants and their officers and employees directly conspired with Epstein himself to further the sex trafficking venture. 145, defendants conspiracy to violate US Code 18, Section 1591, A&1, and A&2, was forbidden by US Code 18, Section 1594C, and defendants thereby violated Chapter 77 Title 18. 146, defendants conspiracy directly, approximately, and foreseeably harm plaintiffs and other young victims by directly leading to their forcible being caused to engage in commercial sex acts and in other ways. defendants conspiracy, victimized plaintiffs, and other young victims, 147. defendants conspiracy to violate US Code 18, Section 1591D, was forbidden by US Code 18, Section 1594C, and defendants thereby violated Chapter 77 Title 18. 148, defendants conspiracy directly, approximately, 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. 149, defendants conspiracy, victimized plaintiffs, and other young victims, 150. 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 sex trafficking venture. defendants acted with the specific intent to violate US Code 18, Section 1591, A&1, and A&2. That is, with consciousness of nature of Epstein's sex trafficking venture and with the specific intent to further venture. defendants and Epstein had a meeting of the minds as to the essential nature of the plan, 151. defendants conspiracy with Epstein is part of its participation in his sex trafficking venture without defendants agreement to facilitate the venture. Epstein would not have been in a position to move forward with this sex trafficking venture on USVI and to recruit and entice victims of the venture there, 152. defendants also conspired with Epstein and his other co-conspirators to obstruct, to 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. 153, defendants intentionally committed overt acts in furtherance of the conspiracy agreement and understanding to violate US Code 18, Section 1591, A, by knowingly playing an active role in assisting supporting and facilitating the recruiting, enticing, coercing, harboring, transporting and inducing enforceably 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. All right, we're gonna wrap up right there. And in the next episode, we're gonna pick up with number 154, among the many overt acts intentionally committed by defendants. All of the information that goes with this episode can be found in the description box.