Beyond The Horizon
The Lawsuit Filed By The Epstein Survivors Against The USVI: The Complaint (Part 4) (7/9/24)
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:
- 09 Jul 2024
- Audio Format:
- mp3
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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 Jane Doe lawsuit against the U.S. Virgin Islands. 5. Class Action Allegations. 96. Plaint of Jane Doe 1, Jane Doe 2, Jane Doe 3, Jane Doe 4, and Jane Doe 5. Bring this action pursuant to Federal Rule of Civil Procedure 23(b)(3) and 23(c)(4) on behalf of themselves and the following class. All women who are sexually trafficked to and through the United States Virgin Islands by Jeffrey Epstein between the years 2001 through 2019 both dates inclusive the class period. 97. Plaintiffs reserve the right to seek leave to modify this definition, including the addition of one or more subclasses, after having the opportunity to conduct discovery. 98. Nomerosity. The class consists of dozens of women making Joinder impracticable in satisfaction of Fedarsiv P23A1. The exact size of the class and the identities of the individual class members are ascertainable through records maintained by the Epstein Estate Executors and the defendants, including but not limited to defendants and other records related to Epstein and his sex trafficking to and through the United States Virgin Islands. 99. Typicality. Plaintives claims are typical of the claims of the other class members that they seek to represent. The claims of plaintiffs and other class members are based on the same legal theories and arise from the same unlawful pattern and practices of defendant's participation in and funding of Epstein's sex abuse and Epstein's sex trafficking venture, as set forth above and otherwise discovered. 100. Commonality. There are many questions of law and, in fact, common to the claims of plaintiffs and the other class members and those questions predominate over any questions that may affect only individual class members within the meaning of Fedarsiv P23A2 and B3. Class treatment of common issues under Fedarsiv P23C4 will materially advance the litigation. 101. Common questions of fact and law affecting class members include but are not limited to the following. A. Whether the Epstein Sex Trafficking Venture caused its victims to engage in commercial sex acts and violation of Trafficking Victims Protection Act, U.S. Code 18, Section 1591, A1. B. Whether the Epstein Sex Trafficking Venture recruited in ties solicited Harvard, provided obtained and transported victims in ways that were in or affecting interstate or foreign commerce. C. Whether Epstein and his co-conspirators use means of force, fraud, coercion, and abuse of legal process or a combination of such means to sexually abuse the victims and to cause victims to engage in commercial sex acts. D. Whether defendant knowingly assisted, facilitated, and supported the Epstein Sex Trafficking Venture's pattern and practice of course of divorcing victims to engage in commercial sex acts. E. Whether defendants benefited financially or by receiving things of value from its participation in a venture which has engaged in sex trafficking and violation of TVPA, U.S. Code 18, Section 1591, A1. F. Whether defendants knew or should have known that the Epstein Sex Trafficking Venture had engaged in violations of the TVPA, U.S. Code 18, Section 1591, A. And G. Whether defendants committed negligent acts or omissions that facilitated sexual abuse which would constitute a sexual offense as defined in Article 1, 130 of the penal law committed against such persons who were 18 years of age or older, 102, absent a class action most of the class members would find the cost of litigating their claims to be cost prohibitive and will have no effective remedy. The class treatment of common questions of law and fact is also superior to multiple individual actions or a piecemeal litigation and that it conserves the resources of the courts and the litigants and promotes consistency and efficiency of adjudication. 103. Adequacy. The Jane Doe plaintiffs will fairly and adequately represent and protect the interests of the other class members she seeks to represent. The Jane Doe plaintiffs have retained counsel with substantial experience in prosecuting complex litigation and large-scale high-profile sexual abuse-related litigation. Plaintiffs and their counsel are committed to vigorously prosecuting this action on behalf of the other class members and have financial resources to do so. Neither plaintiffs nor the council have any interests adverse to those of the other class members. 104. This action has been brought and may properly be maintained as a class action against defendants pursuant to Rule 23 of the federal rules of civil procedure because there is a well-defined community of interest in the litigation and the proposed class is easily ascertainable from defendant's records. 105. Superiority. A class action is superior to all other available methods for the fair and efficient adjudication of this controversy because, A. Joinder of all class members is "inpracticable." B. The prosecution of individual remedies by members of the class will tend to establish inconsistent standards of conduct for defendants and result in the impairment of class members' rights and the disposition of their interests through actions to which they were not parties. C. Class action treatment will permit a large number of similarly situated persons to prosecute their common claims in a single forum simultaneously, efficiently, and without unnecessary duplication of effort and expense that numerous individual actions could engender. D. Apps in a class action, class members will continue to suffer losses and be aggrieved and defendants will continue to violate New York and federal law without remedy. E. Class treatment of this action will cause an orderly and expeditious administration of class claims, economies of time, effort and expense will be fostered, and uniformity of decisions will be fostered. F. plaintiff and her counsel are unaware of any class action brought against any defendant for the violations alleged in this action. G. The forum is desirable because the defendants conducted the subject business with Jeffrey Epstein and the district and class members were consequently trafficked in this district, and H. This action represents no difficulty that would impede its management by the court as a class claim. 6. Causes of Action As in 4, a first cause of action has to participation in a sex trafficking venture and violation of Trafficking Victims Protection Act under U.S. Code 18, Section 1591, A2, 1595, D. We're the Lucky Land Sluts. You can get lucky just about anywhere. This is your captain speaking. We've got clear runway and the weather's fine, but we're just going to circle up here a while and get lucky. No, no, nothing like that. It's just these cash prizes out of quick, so I suggest you sit back, keep your tray table upright, and start getting lucky. 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As to all defendants, 106, plaintiffs incorporate the foregoing paragraphs here in as if set forth at length, 107, defendants knowingly and intentionally through various means participated in, perpetrated, assisted, supported, facilitated, a sex trafficking venture that was in and affecting interstate and foreign commerce together with others in violation of U.S. Code 18, Section 1591, A&1. 108, defendants knowingly benefited from their participation in Epstein's enterprise. 109, defendants knowingly and intentionally participated in an Epstein sex trafficking venture that was in and affecting interstate and foreign commerce together and with others in violation of U.S. Code 18, Section 1591, A&1. 110, among other things defendants knowingly and intentionally through various means recruited and types provided facilitated, obtained, advertised, and solicited by various means plaintiffs knowing that Epstein would use means of force, threats of force, fraud, coercion, and a combination of such means to cause plaintiffs to engage in commercial sex acts. 111, defendants and their officers and employees had actual knowledge that they were perpetrating and facilitating Epstein sexual abuse and sex trafficking conspiracy to recruit, solicit, entice, coerce, harbor, transport, facilitate, obtain, and provide plaintiffs into commercial sex acts through the means of force, threats of force, fraud, abuse of process, and coercion. 112, despite such knowledge defendants intentionally accepted payment for, facilitated, perpetrated, and participated in Epstein's violations of U.S. Code 18, Section 1591, A&1, which defendants knew and were in reckless disregard of the fact that Epstein would coerce the fraud and force plaintiffs as well as other young women to engage in commercial sex acts. 113, as part of perpetrating TVPA violations, USVI concealed its extensive involvement and efforts and furtherance of Epstein's sex trafficking ventures, Epstein, and his associates. 114, defendants conduct was committed knowing and an reckless disregard of the facts that Epstein would use said government support provided by defendants as a means of defrauding, forcing, and coercing sex acts from plaintiffs. Defendants conduct was outrageous and intentional. 115, defendants intentional and/or negligent conduct has caused plaintiffs and many other young women's serious harm, including without limitation, physical, psychological, emotional, financial, and reputational harm. 116, defendants conduct and perpetrating TVPA violations was outrageous and intentional because it was in deliberate furtherance of widespread and dangerous criminal sex trafficking organization. 117, by virtue of its knowing and intentional violations of U.S. Code 18, Section 1591, A&1, 1595, defendants are liable to plaintiffs for the damages that they sustained and reasonable attorney fees by virtue of these intentional and outrageous violations. U.S. Code 18, Section 1591, A&1, and 1595. 118, defendants are liable to plaintiffs for punitive damages for their aforementioned conduct. 119, the amount of damages sought exceeds the jurisdiction of all lower courts which would otherwise have jurisdiction. 120, this action falls within exceptions of Article 16 of the CPLR. Alright folks, we're gonna wrap up right here, and in the next episode we're gonna pick up where we left off, and that's with, as and 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, A&1, and 2, and 1595. All of the information that goes with this episode can be found in the description box. 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. 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