Beyond The Horizon
The Lawsuit Filed By The Epstein Survivors Against The USVI: The Complaint (Part 1) (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:
- 15m
- Broadcast on:
- 09 Jul 2024
- Audio Format:
- mp3
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Since November of last year, we've been talking about the lawsuit that's been filed by the survivors against the US Virgin Islands. And in this episode, we're gonna keep that conversation going by taking a look at the original complaint that was filed against the Virgin Islands by the Epstein accusers. And then over the next coming weeks, we're gonna be adding all of these court documents from the US Virgin Islands and the lawsuit with the survivors to the catalog. That way, all of you have the receipts for what we talk about here on the podcast. So with that said, let's get right into these documents and let's get started. The United States District Court for the Southern District of New York. Individual and class action complaint. Jane Doe won individually and on behalf of all others, similarly situated, Jane Doe 2, individually, and on behalf of all others, similarly situated, Jane Doe 3, individually, and on behalf of all others, similarly situated, Jane Doe 4, individually, and on behalf of all others, similarly situated, and Jane Doe 5, individually, and on behalf of all others, similarly situated. Versus the government of the United States Virgin Islands, First Lady Cecile Dajang, Governor Kenneth Map, Senator Salestino White, Attorney General Vincent Frazier, Governor John Dajang, Senator Colton Dow, Delegate Stacey Plaskett, and John Doves, one through 100. Complaint and demand for trial. One, plaintiff's Jane Doe 1, Jane Doe 2, Jane Doe 3, Jane Doe 4, and Jane Doe 5, individually, and on behalf of all others, similarly situated, file this complaint against the government of the United States Virgin Islands. Hereafter, USVI. First Lady Cecile Dajang, Governor Kenneth Map, Senator Salestino White, Attorney General Vincent Frazier, Governor John Dajang, Senator Colton Dow, Delegate Stacey Plaskett, and John Doves, one through 100. For violations of the Trafficking Victims Protection Act, TVPA, US Code 18, Section 1591 to 1595, and of negligence and didn't support thereof, alleges as follows. One, jurisdiction, venue, and timelines. Two, this action is brought pursuant to various federal and US territorial statutes, including the Federal Trafficking Victims Protective Act, US Code 18, Section 1589, through Section 1595. This court has federal question, subject matter, jurisdiction pursuant to US Code 28, Section 1331, because Jane Doe 1, Jane Doe 2, Jane Doe 3, Jane Doe 4, and Jane Doe 5, each individually, and on behalf of all others, similarly situated, proceed under the federal TVPA statute. Three, this court also has supplemental jurisdiction of the state law claims recounted below, pursuant to US Code 28, Section 1367A, because all claims alleged herein are part of a uniform pattern and practice and form part of the same case, or controversy. Four, venue is proper in the United States District Court of the Southern District of New York, pursuant to US Code 28, 1391B&2, because substantial activities occurred in this district, including but not limited to the following. One, Epstein's sex trafficking operation was based, managed, and operated out of New York in this district. Two, defendants, their officers, agencies, agents, servants, and/or employees, regularly communicated with Epstein about the formation, operation, and maintenance of Epstein's sex trafficking ring by electronic means, including voice telephone, text message, video telephone, or meeting, while Epstein was in his New York office and/or residence in this district. Three, Epstein and his co-conspirators, including defendants, knowingly aided and abetted, facilitated, and directly participated in Epstein's illegal venture through financial and non-financial transactions that originated in this district. Four, the acts of sexual abuse committed by Epstein and certain select friends took place in Jeffrey Epstein's New York mansion, located within this district at 9E-71st Street, New York City. Epstein used his New York mansion to harbor his victims and as a base, from which to transport them to other locations outside of New York. Five, defendants received numerous substantial payments from Epstein's JP Morgan Chase New York accounts, as demonstrated below, and set forth in the various filings of both parties in government of the U.S. Virgin Islands versus JP Morgan Chase Bank. Case number one, 22-CV-10904-JSR-SDNY-2023. Six, on at least one occasion, first lady, Cecile Dajang, stayed in one of Epstein's apartments in New York for a month in 2017, nearly a decade after Epstein completed his prison sentence for soliciting minors for prostitution in order to advise and assist him in securing the U.S. V.I.'s cooperation as a safe harbor for his sex trafficking ring. Seven, Stacey Plaskit, delegate to the U.S. House of Representatives from the U.S. V.I.s at large district, visited Epstein at his New York mansion to request that he contribute to her political campaigns and Epstein and his colleagues paid her campaign's $30,000. Plaskit also visited Epstein at his New York mansion to request $30,000 in contributions to the Democratic National Committee, which was ultimately declined because Plaskit knew Epstein failed their vetting. Eight, the transportation for the Epstein's sex trafficking ring was owned, stored, and maintained in New York state, in particular, and Epstein's clients or purchased, owned, stored, and maintained in New York. Nine, many of the traffic women, including plaintiffs herein, were solicited by Epstein while he was in New York and then transported from New York to the U.S. V.I. and held captive and abused in the U.S. Virgin Islands at Epstein's U.S. V.I. estate. Ten, at the time of the events at issue, plaintiffs resided in New York, New York, in this district. Eleven, likewise Epstein solicited many of his co-conspirators for his sex trafficking ring during meetings held in New York, seeking out their interest in engaging in sex crimes before extending invitations to the island inclusive of his private transportation to avoid publicity. Twelve, Epstein also facilitated entry into the United States Virgin Islands for the procurement of travel documents while he was in New York office and/or residence. Five, all causes of action arose no later than 2001 and continuing until 2019. Six, plaintiff Jane Doe One was sexually abused and trafficked by Epstein and his co-conspirators from 2001 to 2019 in New York, Florida, U.S. V.I. and around the world. Seven, plaintiff Jane Doe Two was sexually abused and trafficked by Epstein and his co-conspirators from 2015 to 2019 in New York, Florida, U.S. V.I. and around the world. Eight, plaintiff Jane Doe Three was sexually abused and trafficked by Epstein and his co-conspirators from 2015 to 2019 in New York, Florida, U.S. V.I. and around the world. Nine, plaintiff Jane Doe Four was sexually abused and trafficked by Epstein and his co-conspirators from 2001 to 2009 in New York, Florida, U.S. V.I. and around the world. Ten, plaintiff Jane Doe Five was sexually abused and trafficked by Epstein and his co-conspirators from 2001 to 2009 in New York, Florida, U.S. V.I. and around the world. Eleven, this action has been timely filed pursuant to U.S. Code 18, Section 1595C. One, which provides that a plaintiff shall have 10 years after the cause of action or rose to file suit against any person who knowingly benefits financially or by receiving anything of value from participation in a venture which that person knew or should have known violated the laws against sex trafficking. As the conspiracy continued until 2019, this action is timely. This action is also timely under New York's Adult Survivors Act. - 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. Our next-gen, tankless facilities reduce the greenhouse gas emissions of our operations by more than 90% compared to our older designs. 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It was not until the recent case, US Virgin Islands versus JP Morgan Chase Bank, NA, US District Court SDNY number 22-10-904, where JP Morgan members depose members of the US BI government that the plaintiffs and public learned of the many acts committed by defendants, which contributed to and caused plaintiff's injuries under federal statutes set forth below. See US Virgin Islands versus JP Morgan Chase, US District Court SDNY number 22-10-904, 13. In addition, New York Adult Survivors Act created a one year window for adult sexual abuse victims to bring their negligence claims, making this action timely under CPLR 214J2. Introduction 14. Plaintives Jane Doe 1, Jane Doe 2, Jane Doe 3, Jane Doe 4 and Jane Doe 5 on their behalf and on behalf of others, similarly situated, filed this complaint for damages and other relief under, among other provisions of the law, the United States Federal Anti-Sex Trafficking Statute, US Code 18, Section 1591, the Trafficking Victim Protection Act, and for aiding and abetting and negligence. 15. The suit arises from the US VIs participation and involvement in Jeffrey Epstein's widespread and well-publicized sex trafficking operation, as well as the many individuals representatives of the government who gave orders to provide preferential treatment to Epstein, which allowed, collaborated and encouraged him to continue his sex trafficking enterprise. In order to continue to receive the benefits it derived from its relationship with him, 16. The US VIs government's actions actively facilitated Epstein's crimes and is misconduct. 17. The government officials, including but not limited to, defendants, First Lady Cecile Dajang, Governor Kenneth Mapp, Senator Salistino White, Attorney General Vincent Frazier, Governor Jean Dajang, Stacey Plaskett, and Senator Carlton Dow, facilitated Epstein in his ongoing sex trafficking operation by ensuring that Epstein received preferential treatment and unfettered, unmonitored freedom while in the US VI, and by providing Epstein and/or his company's instruments, which further enabled his sex trafficking ring and related crimes. 18. Upon information and belief, government employees, John Doe's one through 25, followed the orders of the aforementioned government officials, the US VI and others, further enabling Epstein and his crimes. 19. Defendant US VI knew or should have known that it was providing Epstein with a safe haven to create, operate, maintain, and expand his sex trafficking ring. The protection of the government to run set operation and the willful ignorance that such operations were occurring and continuing to occur at the behest of the US VI government. 20. Government officials and employees were given orders to carry out said government-sanctioned priorities, privileges, and benefits, negligently allowing Epstein to continue with his operations uninterrupted and without fear of police, airport, coast guard, or customs intervention. In exchange, the US VI government leaders, staff, and officials benefited by receiving generous financial donations, financial advice, support, loans, access to lines of credit from Epstein and his entities, and that crucial financial support allowed Epstein to successfully rape, sexually assault, coercively sex-traffic plaintiffs, and numerous other women freely and openly, access to underage and other women, and to haven to act without government scrutiny by customs, police, or airport personnel, or public knowledge. 21. Other government staff and officials, including John Doe's one through 50, followed the orders of these officials, and in turn, maintained their government employment. All right, we're gonna wrap up this episode here and in the next episode we're gonna pick up with the parties. All of the information that goes with this episode can be found in the description box. An official message from Medicare. A new law is helping me save more money on prescription drug costs. Maybe you can save too. With Medicare's extra help program, my premium is zero and my out-of-pocket costs are low. Who should apply? Single people making less than $23,000 a year, or married couples who make less than $31,000 a year. Even if you don't think you qualify, it pays to find out. Go to ssa.gov/extrahelp. Paid for by the U.S. Department of Health and Human Services. - Okay, round two. Name something that's not boring. - Laundry? Ooh, a book club. 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