Beyond The Horizon
The Lawsuit Filed By The Epstein Survivors Against The USVI: The Complaint (Part 3) (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:
- 12m
- Broadcast on:
- 09 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 a complaint by the survivors against the USVI. B, the payoffs, 60. To support and expand this sex trafficking empire, Epstein gave payments advice and other benefits to the highest USVI government officials. 61, 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 USVI's First Lady Dajang, a USVI government official, and bought Epstein's loyalty and access among USVI politicians. 62, Governor Kenneth Map, USVI's governor, from 2015 to 2019 asked Epstein to advise him on how to increase USVI's business investments and deal with the USVI's structural fiscal imbalance. He specifically asked Epstein to spread the word that USVI was pushing for business investment and requested Epstein's input on issuing critically needed bonds to finance USVI's operations. 63, Governor Map 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 proposed legislation for the governor. As per USVI's own legislation, the EDC's board is under the general supervision and direction of the governor. Virgin Island Code 29, Section 1101B. As such, actions of the EDC are done of and by the USVI government, 64. On one occasion, when the 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 cash by extending it, a $50 million loan collateralized by USVI's islands. 65, First Lady, Dijang suggested that Epstein put Senators Elastino 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 Virgin Island candidates. 66, 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. 67, Epstein and his colleagues loaned Stacey Plaskit $30,000 to support her political campaign. Plaskit was the attorney for the EDC when it approved the $300,000 in tax breaks to Epstein's companies and had worked for Epstein's attorney. 68, by the way of example only, a USVI customs agent and/or border control worker was compensated by Epstein under the guise of playing Caribbean drums for him on his island. C, the quid pro quo, defendants assisted Epstein in operating and expanding his criminal enterprise. 69, 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. 70, in exchange for his pay off, Epstein received one influence over the very laws that were supposed to constrain him. Two, waivers of his sex offender monitoring requirements, three, 300 million in subsidies, to the allegedly sham companies he used for sex trafficking, four, facilitation of visas, licenses, and/or ignoring requirements for same and other forms of governmental assistance that enabled his criminal conduct, and five, immunity from investigation and scrutiny. One, Epstein provides input into USVI's proposed sex offender monitoring legislation and is given a waiver of compliance from it. 71, in 2011, 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, 72. 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. 73, 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 government, or governor, would be traveling for a week, and the Attorney General, had to submit the proposed legislation during that timeframe. 74, Epstein and his lawyer, continued 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, 75. When Epstein's preferred language was omitted from the final bill, the First Lady assured Epstein that we will work with Vincent Frazier, the Attorney General, to give the discretion for status quo for you, that's the least he can do. 76, 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. 77, 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. 78, Epstein was thus allowed to circumvent a recently passed legislation with assistance of Senator Colton Dow, Senator Celestine O'White, and Attorney General Vincent Frazier, 79. Had his 21-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. Two, the USVI gave Epstein's enterprise $300 million in tax breaks, 80. 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. 81, the ultimate decision to provide such tax breaks was made by the USVI governor. Plasket 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. 82, these tax breaks amounted to $300 million in direct benefits to Epstein and his companies and enterprise. Three, government officials and workers gave Epstein free rein in the country bypassing customs laws, enforcement, airport, and coast guard security, and were instructed to disregard any pleas for help from the victims. 83, with the help of First Lady Dijang and other government officials and staff, Epstein traveled through the USVI airports, accompanied by young sex trafficked women and girls. 84, 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. 85, 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. 86, 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, his clients and the victims were never mandated to enter through customs. They complained from the private jet before boarding Epstein's helicopter or boat. 87, upon information and belief, Epstein and his assistants, agents, and others sees victims' passports with a full knowledge and consent of defendants who are directed not to assist the victims if they complained of their virtual captivity. 88, 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 wouldn't happen again by calling the head of customs. 89, USVI, its officials, and law enforcement never investigated Epstein, even after Florida law enforcement, faxed Epstein sexual predator registration information to USVI, Department of Justice officials, in July of 2010, with which they included a news article confirming his status as a sex offender. 90, upon information and belief, USVI officials directed law enforcement, officers, airport personnel, customs officials, and any other government employees to extend any courtesy or assistance to Epstein and as affluent customers and guests as part of their official duties. 91, 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 survivors, such as securing a return for the passports from Epstein and to report any pleas for help directly to Epstein. Four, defendants secured visas so that Epstein could transport his victims into USVI. 92, First Lady Dijang, who was employed by Epstein as his office manager, facilitated him in obtaining travel documents, including visas, to bring minor women from other countries to the USVI. First Lady Dijang earned $200,000 in annual salary in addition to the payment of her children's private school and college tuition, among other perks. 93, upon information and belief, First Lady Dijang also arranged for three young European women to secure student visas to enroll at the University of the Virgin Islands to attend a 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. 94, Epstein corresponded with First Lady Dijang and other high-level government officials about securing visas and setting up ESL classes for as many 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 coordinated with Epstein on how an individual could obtain an I-20 through the university of the Virgin Islands, 95. The First Lady 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 government for letters of support for visa applications. But for defendants above described negligent and/or reckless acts and/or emissions, plaintiff would not have suffered the mental and physical anguish she endures to date. All right, folks, we're gonna wrap up this episode right here and in the next episode, we're gonna pick up with five, the class action allegations. All of the information that goes with this episode can be found in the description box.