Dershowitz, defends Israeli war criminals, accused/convicted rapists, is accused of raping Virginia Roberts,
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDACASE NO. 08-80736-CIV-MARRA
JANE DOE #1 and JANE DOE #2,Petitioners,vs.UNITED STATES OF AMERICA,Respondent. _______________________________/
DECLARATION OF VIRGINIA ROBERTS
1.My name is Virginia Roberts and I was born in August, 1983.2.I am currently 31years old. 3.I grew up in Palm Beach, Florida. When I was little, I loved animals and wanted to be a veterinarian. But my life took a very different turn when adults began to be interested in having sex with me. 4.In approximately 1999,when I was 15years old, I met Ghislaine Maxwell. She is the daughter of Robert Maxwell, who had been a wealthy publisher in Britain. Maxwell asked that I come with her to Jeffrey Epstein’s mansion for the purposes of teaching me how to perform “massages” and to train me professionally in that area. Soon after that I went to Epstein’s home in Palm Beach on El Brillo Way.5.From the first time I was taken to Epstein’s mansion that day, his motivations and actions were sexual, as were Maxwell’s. My father was not allowed inside. I was brought up some stairs. There was a naked guy, Epstein, on the table in the room. Epstein and Maxwell forced me into sexual activity with Epstein. I was 15 years old at the time. He seemed to be in his 40s or 50s. I was paid $200. I was driven home by one of Epstein’s employees
6.I came back for several days following and did the same sorts of sexual things for Epstein.7.After I did those things for Epstein, he and Maxwell said they were going to have me travel and were going to get an education for me. They were promising me the world, that I would travel with Epstein on his private jet and have a well-paid profession. Epstein said he would eventually match me up with a wealthy person so that I would be “set up” for life.8.So I started “working” exclusively for Epstein. He took me to New York on his big, private jet. We went to his mansion in New York City. I was shown to my room, a very luxurious room. The mansion was huge. I got scared because it was so big. Epstein brought me to a room with a massage parlor. To me, it looked like an S&M parlor. Epstein made me engage in sexual activities with himthere.9.You can see how young I looked in the photograph below.
10.Epstein took me on a ferry boat on one of the trips to New York City and there he tookthe picture above. I was approximately 15 or 16 years old at the time.11.Over the next few weeks, Jeffrey Epstein and Ghislaine Maxwell trained me to do what they wanted, including sexual activities and the use of sexual toys. The training was in New Yorkand Florida, at Epstein’s mansions. It was basically every day and was like going to school. I also had to have sex with Epstein many times. 12.I was trained to be “everything a man wanted me to be.” It wasn’t just sexual training -they wanted me to be able to cater to all the needs of the men they were going to send me to. They said that they loved that I was very compliant and knew how to keep my mouth shut. 13.Epstein and Maxwell also told me that they wanted me to produce things for them in addition to performing sex on the men. They told to me to pay attention to the details about what the men wanted, so I could report back to them. 14.From very early on I was fearful of Epstein. Epstein told me he was a billionaire. I told my mother that I was working for this rich guy, and she said “go, go far away.” Epstein had promised me a lot, and I knew if I left I would be in big trouble. I also knew that I was a witness to a lot of illegal and very bad behavior by Epstein and his friends. If I left Epstein, he knew all kinds of powerful people. He could have had me killed or abducted, and I always knew he was capable of that if I did not obey him. He let me know that he knew many people in high places. Speaking about himself, he said “I can get away” with things. I was very scared, particularly since I was a teenager.
15.I visited and traveled with Jeffrey Epstein from 1999 through the summer of 2002, and during that time I stayed with him, as his sex slave, at each of his houses (really more like mansions) in locations including New York City, New York; the area of Santa Fe, New Mexico; Palm Beach, Florida; an island in the U.S. Virgin Islands; and Paris, France. I had sex with him often in these places and also with the various people he demanded that I have sex with. Epstein paid me for many of these sexual encounters. In fact, my only purpose for Epstein, Maxwell and their friends was to be used for sex. 16.To illustrate my connection to these places, I include fourphotographs taken of me in New Mexico (shown below). The firstone is a museum in Santa Fe, New Mexico. We had gone sightseeing for the day. Epstein took this picture of me. I was approximately 17 at the time, judging from the looks of it. At the endof the day we returnedto Epstein’s Zorro Ranch. The second picture is me on one of Epstein’s horses on the ranch in New Mexico.The following two are from wintertime in New Mexico
17.When I was with him, Epstein had sex with underage girls on a daily basis. His interest in this kind of sex was obvious to the people around him.The activities were so obvious
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and boldthat anyone spending any significant time at one of Epstein’s residences would have clearly been aware of what was going on.18.Epstein’s code word for sexual encounters was that it was a “massage”. At times the interaction between Epstein and the girls would start in a massage room setting, it was always a sexual encounter and never just a massage. 19.In addition to constantly finding underage girls to satisfy their personal desires,Epstein and Maxwellalso got girls for Epstein’s friends and acquaintances. Epstein specifically told me that the reason for him doing this was so that they would “owe him,” they would “be in his pocket,” and he would “have something on them.” I understood him to mean thatwhen someone was in his pocket, they owed him favors. I also understood that Epstein thought he could get leniency if he was ever caught doing anything illegal, or more so that he could escape trouble altogether. 20.Ghislaine Maxwell was heavily involved in the illegal sex. I understood her to be a very powerful person. She used Epstein’s money and he used her name and connections to gain power and prestige.21.One way to describe Maxwell’s role was as the “madame.” She assumed a positionof trust for all the girls, including me. She got me to trust her and Epstein. It turned out that Maxwell was all about sex all the time. She had sex with underage girls virtually every day when I was around her, and she was very forceful.22.I first had sexual activities with her when I was approximately 15 at the Palm Beach mansion. I had many sexual activities with her over the next several years in Epstein’s various residences plus other exotic locations. I had sex with Maxwell in the Virgin Islands,
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New Mexico, New York, as well as France and many other locations. I also observed Maxwell have sex with dozens of underage girls. 23.Maxwell took pictures of many of the underage girls. These pictures were sexually explicit. Maxwell kept the pictures on the computers in the various houses. She also made hard copies of these images and displayed them in the various houses. Maxwell had large amounts of child pornography that she personally made. Many times she made me sleep with other girls, some of whom were very young,for purposes of taking sexual pictures. 24.Harvard law professor Alan Dershowitz was around Epstein frequently. Dershowitz was so comfortable with the sex that was going on that he would even come and chat with Epstein while I was giving oral sex to Epstein.25.I had sexual intercourse with Dershowitz at least six times. The first time was when I was about 16, early on in my servitude to Epstein, and it continued until I was 19. 26.The first time we had sex took place in New York in Epstein’s home. It was in Epstein’s room (not the massage room).I was approximately16years old at the time. I called Dershowitz “Alan.” I knew he was a famous professor.27.The second time that I had sex with Dershowitz was at Epstein’s house in Palm Beach. During thisencounter, Dershowitz instructed me to both perform oral sex and have sexual intercourse.28.I also had sex with Dershowitzat Epstein’s Zorro Ranch in New Mexico in the massage room off of the indoor pool area, which was still being painted. 29.We also hadsex at Little SaintJames Island in the U.S. Virgin Islands.I was asked to give Dershowitz a massage on the beach. Dershowitz then asked me to take him somewhere more private,where we proceeded to have intercourse.
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There was a lot of legal discussion about Andy and his ex-wife (“Fergie”). Then the discussion turned to me. Maxwell said “guess how old she is.” Prince Andrew guessed 17. 35.Then we all went to a Chinese restaurant for dinner and then to Club Tramp, a fancy “members only” night club in central London. Andy arranged for alcohol to be provided to me at the club.Eventually we left. I rode with Epstein and Maxwell back to the townhouse. On the way there, Epstein and Maxwell informed me that the Prince wanted to see “more of me” that night. Andy traveled in a separate car with his guards. 36.We all arrived back at the townhome and went upstairs.Epstein took a picture of me and Andy with my own camera. The picture aboveis thatpicture, whichhas been widely circulated on the internet. Andy has his left arm around my waist and is smiling. The picture was developed on March 13,2001,and was taken sometime shortlybefore I had it developed.I was 17 years old at the time. 37.I wanted a picture with the prince because I was keeping in contact with my family. I had told my mom and my grandma that I was meeting Prince Andrew and that I’d take a picture for them. They told me to “be careful.” 38.After the picture, Epstein and Maxwell kissed me and said to “have fun.” They left Andy and me alone upstairs. We went to the bathroom and bedroom, which were just steps away from where the picture was taken. We engaged in sexual activities there. Afterwards, Andy left quickly with his security.39.I chatted with Epstein about this the next day. I told him,“it went great.” Epstein saidsomething to the effect of,“You did well. The Prince had fun.” I felt like I was being graded.It was horrible to have to recount all these events and have to try to meet all these needs
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and wants. I told Epstein about Andy’s sexual interests in feet. Epstein thought it was very funny.Epstein appeared to becollecting private information about Andy. 40.When I got back from my trip, Epstein paid me more than he had paid me to be with anyone else –approximately$15,000. That money was for what I had done and to keep my mouth shut about “working” with the Prince. 41.The second time I had sex with Prince Andrew was in Epstein’s New York mansion in spring 2001. I was 17 at time. Epstein called me down to his office. When I got there, Epstein was there, along with Maxwell, Johanna Sjoberg, and Andy. I was very surprised to see him again. Epstein and Maxwell were making lewd jokes about “Randy Andy”. 42.I had the impression that Andy had come there to see Epstein and to have sex me with. There was no other apparent purpose for Andy to be there. 43.I was told to go upstairs with Andy and to go to the room I thought of as the “dungeon” (the massage room, but it is really scary looking).Ihad sex with Andy there. I was only paid $400 from Epstein for servicing Andy that time. 44.The third time I had sex with Andy was in an orgy on Epstein’s private island in the U.S. Virgin Islands. I was around 18 at the time. Epstein, Andy, approximately eight other young girls, and Ihad sex together. The other girls all seemed and appeared to be under the age of 18 and didn’t really speak English. Epstein laughed about the fact they couldn’t really communicate, saying that they are the “easiest” girls to get along with. My assumption was that Jean Luc Brunel got the girls from Eastern Europe (as he procured many young foreign girls for Epstein). They were young and European lookingand sounding.45.Afterwards we all had dinner by the cabanas. The other girls were chatting away among themselves, and Epstein and the Prince chatted together. I felt disgusted, and went
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quickly to my own cabana that night and went to sleep. Prince Andrew must have flown out early the next morning, as I did not see him when I got up. 46.I have seen Buckingham Palace’s recent “emphatic” denial that Prince Andrew had sexual contact with me. That denial is falseand hurtful to me. I did have sexual contact with him as I have described here –under oath. Given what he knows and has seen, I was hoping that he would simply voluntarily tell the truth about everything.I hope my attorneys can interview Prince Andrew under oath about the contacts and that he willtell the truth. 47.Ialso had sexual intercourse with Jean Luc Brunelmany times when I was 16 through 19 years old. He was another of Epstein’s powerful friends who had many contacts with young girls throughout the world. In fact, his only similarity with Epstein and the only link to their friendship appeared to be that Brunelcould get dozensof underage girls and feed Epstein’s(and Maxwell’s)strong appetite for sex with minors. 48.Brunelran some kind of modeling agency and appeared to have an arrangement with the U.S. Government where he could get passports or other travel documents for young girls. He would then bring these young girls (girls ranging in age from 12 to 24) to the United States for sexual purposes and farm them out to his friends, including Epstein. 49.Brunelwould offer the girls “modeling” jobs. A lot of the girls came from poor countries or poor backgrounds, and he lured them in with a promise of making good money. 50.I had to have sex with Brunelat Little St. James (orgies), Palm Beach, New York City, New Mexico, Paris, the south of France, and California.He did not care about conversation, just sex. 51.Jeffrey Epstein has told me that he has slept with over 1,000 of Brunel’s girls, and everything that I have seen confirms this claim. Epstein, Brunel, and Maxwell loved orgies w
quickly to my own cabana that night and went to sleep. Prince Andrew must have flown out early the next morning, as I did not see him when I got up. 46.I have seen Buckingham Palace’s recent “emphatic” denial that Prince Andrew had sexual contact with me. That denial is falseand hurtful to me. I did have sexual contact with him as I have described here –under oath. Given what he knows and has seen, I was hoping that he would simply voluntarily tell the truth about everything.I hope my attorneys can interview Prince Andrew under oath about the contacts and that he willtell the truth. 47.Ialso had sexual intercourse with Jean Luc Brunelmany times when I was 16 through 19 years old. He was another of Epstein’s powerful friends who had many contacts with young girls throughout the world. In fact, his only similarity with Epstein and the only link to their friendship appeared to be that Brunelcould get dozensof underage girls and feed Epstein’s(and Maxwell’s)strong appetite for sex with minors. 48.Brunelran some kind of modeling agency and appeared to have an arrangement with the U.S. Government where he could get passports or other travel documents for young girls. He would then bring these young girls (girls ranging in age from 12 to 24) to the United States for sexual purposes and farm them out to his friends, including Epstein. 49.Brunelwould offer the girls “modeling” jobs. A lot of the girls came from poor countries or poor backgrounds, and he lured them in with a promise of making good money. 50.I had to have sex with Brunelat Little St. James (orgies), Palm Beach, New York City, New Mexico, Paris, the south of France, and California.He did not care about conversation, just sex. 51.Jeffrey Epstein has told me that he has slept with over 1,000 of Brunel’s girls, and everything that I have seen confirms this claim. Epstein, Brunel, and Maxwell loved orgies with
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sexual abuse. The letter also said that the federal government was going to “defer federal prosecution.” No one had told me about deferring federal prosecution before this.56.In 2011,two FBI agents, called me in Australia and then came to meet me. They met me at the U.S. Consulate in Sidney. They seemed to be very professional and hard working. I thought to myself, “Wow, these people will dothe right thing against the bad guys and protect me.”57.The agents were mainly focused on Epstein but while there I provided them some information about others who were involved in illegal acts as well. I was aware that a false statement to these law enforcement officers was a crime and Itold the truth –giving them the information that I could recallabout the individuals they inquired about.58.Epstein also trafficked me for sexual purposes to many other powerful men, including politicians andpowerful business executives. Epstein required meto describe the sexual eventsthat Ihad with these men presumably so that he could potentially blackmail them.I am still very fearful of these men today.59.Iwill continue to cooperate fully in the investigation and prosecution of Epstein, Maxwell, or any of their friendswho participated in the sexual abuse of minors. I also hope that this information is treated in a way that will keep me safe from Epstein and others criminals identified here so as to encourage more victims of similar crimes to come forward. If these crimes are not prosecuted, despite my volunteering this information and cooperation, then it may deter other similar victims from coming forward.60.In this affidavit, I have tried to focus on how I was trafficked for sexual purposes. I have not described all of the details of the sexual activities Epstein forced me to have. Also, I have not described all of the details of the other events discussed here. If a judge wants me
IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------------------- JANE DOE, proceeding under a pseudonym, Plaintiff, v. DONALD J. TRUMP and JEFFREY E. EPSTEIN, Defendants. ))))))))) Case No.: JURY TRIAL DEMANDED ---------------------------------------------------------------
COMPLAINT FOR RAPE, SEXUAL MISCONDUCT, CRIMINAL SEXUAL ACTS, SEXUAL ABUSE, FORCIBLE TOUCHING, ASSAULT, BATTERY, INTENTIONAL AND RECKLESS INFLICTION OF EMOTIONAL DISTRESS, DURESS, FALSE IMPRISONMENT, AND DEFAMATION
______________________________________________________________________________ Plaintiff Jane Doe, proceeding under a pseudonym, brings this action against Donald J. Trump and Jeffrey E. Epstein, and alleges that:
Plaintiff is an individual residing in and a citizen of the State of California. 2.
Upon information and belief, Defendants Donald J. Trump and Jeffrey E. Epstein each reside in this District and are citizens of the State of New York.
JURISDICTION AND VENUE
Plaintiff is a citizen of the State of California for purposes of diversity jurisdiction under 28 U.S.C. § 1332. 4.
Defendants are citizens of the State of New York for purposes of diversity jurisdiction under 28 U.S.C. § 1332.
Case 1:16-cv-07673 Document 1 Filed 09/30/16 Page 1 of 10
This Court has original subject matter jurisdiction with respect to this action pursuant to 28 U.S.C. § 1332 as there exists complete diversity of citizenship between Plaintiff and Defendants and the amount in controversy exceeds Seventy Five Thousand Dollars ($75,000.00), exclusive of interest and costs. 6.
Defendants are each subject to the jurisdiction of this Court pursuant to 28 U.S.C. § 1332 with proper venue pursuant to 28 U.S.C. § 1391 as both defendants are residents of and/or are domiciled in this district and the events giving rise to the claims occurred in this district.
RAPE, SEXUAL MISCONDUCT, CRIMINAL SEXUAL ACTS, SEXUAL ABUSE, FORCIBLE TOUCHING, ASSAULT, BATTERY, INTENTIONAL AND RECKLESS INFLICTION OF EMOTIONAL DISTRESS, DURESS, AND FALSE IMPRISONMENT
Plaintiff was subject to acts of rape, sexual misconduct, criminal sexual acts, sexual abuse, forcible touching, assault, battery, intentional and reckless infliction of emotional distress, duress, false imprisonment, and threats of death and/or serious bodily injury by the Defendants that took place at several parties during the summer months of 1994. The parties were held by Defendant Epstein at a New York City residence that was being used by Defendant Epstein at 9 E. 71st St. in Manhattan. During this period, Plaintiff was a minor of age 13 and was legally incapable under New York law of consenting to sexual intercourse and the other sexual contacts detailed herein. NY Penal L § 130.05(3)(a). The rapes in the first, second, and third degrees; sexual misconduct; criminal sexual acts in the first, second, and third degrees; sexual abuse in the first, second, and third degrees; and forcible touching (and, on information
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3 and belief, predatory sexual assault) detailed herein are unlawful under New York law, e.g., NY Penal L § 130.20-130.52, and 130.55-130.65 (and, on information and belief, 130.95) and constitute the torts of,
, assault, battery, false imprisonment, and intentional or reckless infliction of emotional distress, including threats of force and serious bodily harm, under New York law. In addition, 18 U.S. Code § 2255 provides Plaintiff with a civil remedy for personal injuries because Plaintiff, while a minor, was a victim of violations of 18 U.S.C. §§ 1591, 2421, 2422(b), and 2423(a) and she suffered personal injury as a result of such violations. Declaration of Plaintiff Jane Doe, Exhibit A hereto; Declaration of Tiffany Doe, Exhibit B hereto; Declaration of Joan Doe, Exhibit C hereto; Jane Doe, Tiffany Doe, and Joan Doe are each pseudonyms as each woman wishes anonymity. Tiffany Doe, a witness, was an employee of Defendant Epstein. Exh. B. Joan Doe, a witness, was a childhood classmate of Plaintiff who, in the 1994-95 school year, was told by Plaintiff that Plaintiff was subject to sexual contact by the Defendants at parties in New York City during the summer of 1994. Exh. C. 8.
Courts have discretion to allow proceeding anonymously where the need for
privacy outweighs the public’s interest in knowing their identity and any prejudice to the
Sealed Plaintiff v. Sealed Defendant
, 537 F.3d 185, 189 (2d Cir. 2008). This litigation involves matters that are highly sensitive and of a personal nature, and identification of Plaintiff would pose a risk of retaliatory physical harm to her and to others. Exh. A. All of the ten factors that the Second Circuit articulated as relevant to this analysis favor anonymity, especially factors 1-4, 7, and 10 (e.g.,
factors one and two: “whether the litigation involves matters that are ‘highly sensitive and [of a] personal nature,’” and “’whether identification poses
a risk of retaliatory physical or mental harm to the ... party [seeking to proceed anonymously] or
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4 even more critically, to innocent non-
), or are neutral with respect to anonymity. Protecting Pl
aintiff’s anonymity is
also appropriate as she is a rape victim. 9.
Plaintiff was enticed by promises of money and a modeling career to attend a series of parties, with other similarly situated minor females, held at a New York City residence that was being used by Defendant Jeffrey Epstein. At least four of the parties were attended by Defendant Trump. Exhs. A and B. On information and belief, by this time in 1994, Defendant Trump had known Defendant Epstein for seven years (
I've known Jeff for fifteen years. Terrific guy,
' Trump booms from a speakerphone.
He's a lot of fun to be with. It is even said that he likes beautiful women as much as I do, and many of them are on the younger side. No doubt about it -- Jeffrey enjoys his social life.
), and knew that Plaintiff was then just 13 years old. Exhs. A and B. 10.
Defendant Trump initiated sexual contact with Plaintiff at four different parties. On the fourth and final sexual encounter with Defendant Trump, Defendant Trump tied Plaintiff to a bed, exposed himself to Plaintiff, and then proceeded to forcibly rape Plaintiff. During the course of this savage sexual attack, Plaintiff loudly pleaded with Defendant Trump to stop but with no effect. Defendant Trump responded to Plaintif
pleas by violently striking Plaintiff in the face with his open hand and screaming that he would do whatever he wanted. Exhs. A and B. 11.
Immediately following this rape, Defendant Trump threatened Plaintiff that, were she ever to reveal any of the details of the sexual and physical abuse of her by Defendant Trump, Plaintiff and her family would be physically harmed if not killed. Exhs. A and B. 12.
Defendant Epstein had sexual contact with Plaintiff at two of the parties. The second sexual encounter with Defendant Epstein took place after Plaintiff had been raped by
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5 Defendant Trump. Defendant Epstein forced himself upon Plaintiff and proceeded to rape her anally and vaginally despite her loud pleas to stop. Defendant Epstein then attempted to strike Plaintiff about the head with his closed fists while he angrily screamed at Plaintiff that he, Defendant Epstein, rather than Defendant Trump, should have been the one who took
virginity, before Plaintiff finally managed to break away from Defendant Epstein. Exhs. A and B. 13.
The threats of violence against Plaintiff and her family continued, this time from Defendant Epstein, who again reiterated that Plaintiff was not to reveal any of the details of his sexual and physical abuse of her or else, specifically, Plaintiff and her family would be seriously physically harmed, if not killed. Exhs. A and B. 14.
While still under threats of physical harm by coming forward and having no reason to believe that the threats have ever been lifted or would ever be lifted, Plaintiff, who has suffered from stress, emotional distress, mental pain and suffering, among other problems, ever since the assaults, was subjected to daily painful reminders of the horrific acts of one of the perpetrators, Defendant Trump, via mass media coverage of him starting on or about June 16, 2015 that, over a short period of time, became continuous and unavoidable. Exh. A. 15.
As a direct and proximate result of the sexual assaults and rapes perpetrated by Defendants upon her, Plaintiff has suffered stress, emotional distress, and mental pain and suffering, as well as adverse physical consequences. 16.
As a direct and proximate result of the sexual assaults and rapes perpetrated by Defendants upon her, Plaintiff has suffered physical pain and suffering.
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7 and her family would be physically harmed if not killed. The duress has not terminated and the fear has not subsided. The duress is an element of or inherent in the underlying causes of action complained of herein. The duress and coercion exerted by Defendants has been such as to have actually deprived Plaintiff of her freedom of will to institute suit earlier in time, and it rose to such a level that a person of reasonable firmness in Plaintiff's situation would have been unable to resist. Exhs. A and B. 23.
Both Defendants let Plaintiff know that each was a very wealthy, powerful man and indicated that they had the power, ability and means to carry out their threats. Indeed, Defendant Trump stated that Plaintiff
shouldn’t ever say anything if
didn’t want to disappear
like Maria, a 12-year-old female that was forced to be involved in the third incident with Defendant Trump and that Plaintiff had not seen since that third incident, and that he was capable of having her whole family killed. Exhs. A and B. 24.
The duress had prevented Plaintiff from starting litigation before this year. However, as soon as she surfaced, she received threats. More specifically, shortly after her first complaint was filed in California on April 26, 2016, she started receiving threatening phone calls on her cell phone. Exh. A. 25.
Defendants are equitably estopped from arguing that any statute of limitations has not been tolled as Defendants wrongfully forced Plaintiff to refrain from timely commencing this action by threats, duress, and other misconduct. Exhs. A and B.
Zimmerman v. Poly Prep Country Day School
, ___ F.Supp.2d ___ (2012), 2012 WL 3683393;
General Stencils, Inc. v. Chippa
, 18 N.Y.2d 125, 127 (1966)(
“a wrongdoer should not be able to take refuge behind the shield of his own wrongdoing.”
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Moreover, this action has been brought before the facts giving rise to the estoppel have ceased to be operational (i.e., while still under threats of physical harm by coming forward and having no reason to believe that the threats have ever been lifted or would ever be lifted) and since Plaintiff has decided to seek redress at this time, Plaintiff seeks an order of protection in favor of Plaintiff and all associated with her so as to protect them from harm and harassment from Defendants and their agents and associates. Exh. A.
On information and belief, on or about April 28, 2016, Defendant Trump provided the following statement to American Media, Inc. and/or Radar Online LLC for publication on at least their website RadarOnline.com regarding Pl
ED CV 16-797-DMG (KSx) filed in the United States District Court for the Central District of California:
“The allegations are not only categorically false, but disgusting at the highest level and clearly
framed to solicit media attention or, perhaps, are simply politically motivated. There is
absolutely no merit to these allegations. Period.”
The statement provided for publication by Defendant Trump was published by said website and has been republished elsewhere in whole or in part numerous times (and similar statements of an attorney for Defendant Trump were also published, including on September 22, 2016 by Courthouse News Service). The statements provided for publication by Defendant Trump and his agent and that were published by said websites are false as they pertain to Plaintiff. 28.
The published statements are libelous on their face, and clearly expose Plaintiff to hatred, contempt, ridicule and obloquy.
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As a proximate result of the above-described publications, Plaintiff has suffered loss of her reputation, shame, mortification, and injury to her feelings, all to her damage in an amount to be established by proof at trial. 30.
The above-described publications were not privileged because they were published by Defendant Trump and his agent with malice, hatred and ill will toward Plaintiff and the desire to injure her. 31.
As a direct and proximate result of
Defendant Trump’s defamation of Plaintiff
, Plaintiff has been subjected to public scorn, hatred, and ridicule and has suffered other injury.
PRAYER FOR RELIEF WHEREFORE
, Plaintiff prays for judgment against Defendants and for the following relief: A. That judgment be entered against Defendants for special damages, compensatory damages, and punitive damages in an amount which shall be shown to be reasonable and just by the evidence and in excess of Seventy Five Thousand Dollars ($75,000.00), exclusive of interests and costs; B. That all costs of this action be assessed against Defendants, including all re
asonable attorney’s fees, costs and expenses of this action
; C. That an order of protection in favor of Plaintiff and all associated with her be issued so as to protect them from harm and harassment from Defendants and their agents and associates; and D. Such other and further relief as the Court may deem just and proper.
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Plaintiff demands a trial by jury of all issues properly triable by jury in this action. Dated: September 30, 2016 Respectfully submitted, /
s/ Thomas Francis Meagher
: J. Cheney Mason Law Office of J. Cheney Mason, P.A. 250 Park Avenue South, Suite 200 Winter Park, Florida 32789 Thomas Francis Meagher SDNY Bar Code TM6707 One Palmer Square Princeton, New Jersey 08542 Telephone: (609) 558-1500 firstname.lastname@example.org