Beyond The Horizon
The Lawsuit Filed By The Epstein Survivors Against The USVI: The Complaint (Part 2) (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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EGW Group, where prohibited by law, 18 plus terms and conditions apply. - 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 made by Jane Doe's one through five against the USVI. Three, the parties, 22. Jane Doe is a US citizen and was at all relevant times, a resident of and domiciled in the state of New York, New York County, 23. Jane Doe 2 is a US citizen and was at all relevant times, a resident of and domiciled in the state of New York, New York County, 24. Jane Doe 3 is a US citizen and was at all relevant times, a resident of and domiciled in New York County, 25. Jane Doe 4 is a US citizen and was at all relevant times, a resident of and domiciled in the state of New York, New York County, 26. Jane Doe 5 is a US citizen and was at all relevant times, a resident of and domiciled in the state of New York, New York County, 27. The Jane Doe plaintiffs are using pseudonyms to protect their identity because of the sensitive and highly personal nature of this matter, which involves sexual assault, 28. The Jane Doe plaintiffs are also at serious risk of retaliatory harm because the conspirators who participated in the Epstein sex trafficking venture had and continue to possess tremendous wealth and power and have demonstrated a clear ability to cause their serious harm, 29. The Jane Doe plaintiffs safety, right to privacy and security outweigh the public interest for their identification, 30. The Jane Doe plaintiffs legitimate concerns outweigh any prejudice to defendants by allowing them to proceed anonymously. Accordingly, the Jane Doe plaintiffs will be filing a motion to proceed anonymously, 31. As discussed below, many other women who are victims and survivors of sexual abuse and trafficking are similarly situated to the Jane Doe plaintiffs and also need to proceed anonymously for the same reason. The identities of most of these women are known to defendants, 32. plaintiffs bring this action against the attorney general pursuant to its authority to represent the government of the United States Virgin Islands, 33. plaintiffs bring this action against the attorney general as representative of the USVI, which is vicariously liable for the negligent acts of its employees, including John Doe's one through 25, pursuant to VI code, title 33, section 3411 and 3414A, 34. Defendant, First Lady Cecile Dijang was at all relevant times the First Lady of the USVI, 35. Defendant Governor Kenneth Mapp was at all relevant times the governor of the USVI, 36. Defendant, Senator Celestine O'White was at all relevant times a senator of the USVI, 37. Defendant Attorney General Vincent Frazier was at all relevant times the Attorney General of the USVI, 38. Defendant, Governor John Dijang was at all relevant times the governor of the USVI, 39. Defendant Senator Carlton Dow was at all relevant times a senator of the USVI, 40. Defendant Stacy Plaskett was at all relevant times an attorney with Epstein's long-time law firm Keller Hells, Ferguson-Kroblin, PLLC. The attorney for the USVI's EDC, when it approved over $300 million in tax breaks for Epstein's companies and a delegate to the US House of Representatives from the US Virgin Islands at large district, 41. Defendant John Doe's one through 10 and 51 through 100 were employees of the USVI, working four and of the USVI as their agents, employees and/or officers acting in the scope of their employment as USVI custom agents, 42. Defendant John Doe's 10 through 20 were employees of the USVI, working four and of the USVI as their agents, employees and/or officers acting in the scope of their employment as USVI or traffic controllers, 43. Defendant John Doe's 20 through 30 were employees of the USVI working four and of the USVI as their agents, employees and/or officers acting in the scope of their employment as USVI airport baggage check agents, 44. Defendant John Doe's 30 through 40 were employees of the USVI, working four and of the USVI as their agents, employees and/or officers acting in the scope of their employment as USVI police officers, 45. Defendant John Doe's 40 through 50 were employees of the USVI, working four and of the USVI as their agents, employees and/or officers acting in the scope of their employment as USVI Coast Guard agents, 46. The USVI is responsible under United States law and otherwise for the acts of its officers, directors, employees and agents, including the acts described in this complaint, 47. The acts alleged were committed by USVI's officers, directors, employees and agents were within actual and apparent scope of their employment and with the intention, at least in part, to benefit the USVI. 48. USVI's governmental activities, including the events alleged here in, were in and affecting interstate and foreign commerce, in connection with the acts alleged in this complaint, defendant directly or indirectly used means and instrumentalities of interstate commerce, including but not limited to airports, ports and territories. Four, facts of the case. A. Epstein's sex trafficking ring and defendant's knowledge of it, 49. 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 10th, 2019 by apparent suicide. The venture operated primarily for the purpose of luring 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. 50. 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. 51. The Epstein's sex trafficking venture's purpose included enticing, obtaining, harboring and transporting the young victims, including plaintiffs to numerous places, including but not limited to 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 said 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 be completely compliant with every demand Epstein or his clients made. Otherwise, she would certainly suffer a serious reputational, financial and psychological harm. 52. Epstein, fraudionally represented to 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 occasion select others, as well as to create the opportunity for Epstein to sexually abuse them. 53. Epstein's victims were young women and girls like plaintiff who suffered severe abuse as Epstein's sex trafficking victims and who believed they had to remain loyal to the venture at all cost of 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. 54. Epstein did not act alone. He created and maintained his sex trafficking venture with the assistance of other influential individuals and entities who know or should have known that he was sexually abusing and sexually trafficking young women and girls, but nevertheless supported the sex trafficking enterprise. - We all have somewhere we're trying to get to as the largest energy producer in Colorado. Chevron is helping meet rising demand and we're working to do it responsibly. 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VGW group, void where prohibited by law, 18 plus terms and conditions apply. 55, the USVI negligently and/or intentionally provided special treatment to Jeffrey 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 government inclusive of defendants, Epstein's sex trafficking scheme could not have existed and flourished, undisturbed in the USVI. 56, 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 dozens of others, similarly situated women to engage in commercial sex acts and remain in the USVI until Epstein permitted them to leave, as explained herein, 57. The Epstein's sex trafficking venture operated in and affected interstate and foreign commerce. Epstein 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. 58, 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, 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. 59, in approximately 2003 or 2004, Epstein brought Jane Doe IV to his office in Red Hook on St. Thomas. 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 position to Jason 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 10 minutes. When Epstein was finished, they exited through the door where defendants sealed the Zhang was sitting. Given her proximity, the Zhang heard the sexual assault, yet she looked at Jane Doe IV, straightened to her eyes from her desk and did nothing at that time or any time afterward. 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