Case 5:16-cv-00797-DMG-KS Document1 Filed 04/26/16 Pagelof6 Page ID#:1
< @, 8 ao GN 1 ll Name: KATIE JOHNSON 20 = ) = mo “Tj 2 || Address: 6634 DESERT QUEEN AVE. Bie = > = foe en rr} 3 || TWENTYNINE PALMS, CA. 92277 fT Ass 2B cj f C77* ae 4 || Phone: (760) 401-0192 | mo 5 Ss 5 || Fax: NO FAX OR E-MAIL | = 6 || In Pro Per 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 CASE NUMBER: | CG ,IPe 797 We Us 11 || KATIE JOHNSON } n C \/ \ ‘3 Plaintiff o be supplied by the Clerk of The United States District Court 13 V. COMPLAINT FOR CLAIM RELIEF DUE TO: 14 ||DONALD J. TRUMP and 1. SEXUAL ABUSE UNDER THREAT OF HARM [5 | JEFFREY E. EPSTEIN 2. CONSPIRACY TO DEPRIVE CIVIL RIGHTS 16 Defendant(s). 17 18 Plaintiff Katie Johnson, for causes of actions against Defendants Donald J. Trump and
19 || Jeffrey E. Epstein, alleges as follows: JURISDICTION
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21 1. Jurisdiction is pursuant to the law of Diversity, 28 U.S.C. ; 1332, as plaintiff resides in the state 97 || of California while defendants reside in the state of New York and the action is for damages above 23 || $75,000.
24 VENUE
25 2. The venue is established as the Eastern Division of the United States Court Central District 96 || of California because the plaintiff resides in San Bernadino County, State of California
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28 :
PLEADING PAGE FOR A COMPLAINT aL
CV-126 (09/09)
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PARTIES
3. The Plaintiff, Katie Johnson, resides in the State of California.
4, The Defendants, Donald J. Trump and Jeffrey E. Epstein, each reside in the State of New York.
FACTUAL ALLEGATIONS
5. The Plaintiff, Katie Johnson, alleges that the Defendants, Donald J. Trump and Jeffrey E. Epstein, did willfully and with extreme malice violate her Civil Rights under 18 U.S.C. ; 2241 by sexually and physically abusing Plaintiff Johnson by forcing her to engage in various perverted and — depraved sex acts by threatening physical harm to Plaintiff Johnson and also her family.
6. The Plaintiff, Katie Johnson, alleges that the Defendants, Donald J. Trump and Jeffrey E. Epstein, also did willfully and with extreme malice violate her Civil Rights under 42 U.S.C. ; 1985 b conspiring to deny Plaintiff Johnson her Civil Rights by making her their sex slave.
7. The Plaintiff, Katie Johnson, alleges she was subject to extreme sexual and physical abuse by
the Defendants, Donald J. Trump and Jeffrey E. Epstein, including forcible rape during a four month time span covering the months of June-September 1994 when Plaintiff Johnson was still onl a minor of age 13.
8. The Plaintiff, Katie Johnson, alleges she was enticed by promises of money and a modeling career to attend a series of underage sex parties held at the New York City residence of Defendant Jeffrey E. Epstein and attended by Defendant Donald J. Trump.
9. On the first occasion involving the Defendant, Donald J. Trump, the Plaintiff, Katie Johnson, was forced to manually stimulate Defendant Trump with the use of her hand upon Defendant Trump's erect penis until he reached sexual orgasm.
10. On the second occasion involving the Defendant, Donald J. Trump, the Plaintiff, Katie Johnson, was forced to orally copulate Defendant Trump by placing her mouth upon Defendant
Trump's erect penis until he reached sexual orgasm.
CV-126 (09/09) PLEADING PAGE FOR A COMPLAINT
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11. On the third occasion involving the Defendant, Donald J. Trump, the Plaintiff, Katie Johnson was forced to engage in an unnatural lesbian sex act with her fellow minor and sex slave, Maria Doe age 12, for the sexual enjoyment of Defendant Trump. After this sex act, both minors were forced to orally copulate Defendant Trump by placing their mouths simultaneously on his erect penis until he achieved sexual orgasm. After zipping up his pants, Defendant Trump physically pushed both minors away while angrily berating them for the "poor" quality of their sexual performance.
12. On the fourth and final sexual encounter with the Defendant, Donald J. Trump, the Plaintiff, Katie Johnson, was tied to a bed by Defendant Trump who then proceeded to forcibly rape Plaintiff Johnson. During the course of this savage sexual attack, Plaintiff Johnson loudly pleaded with Defendant Trump to "please wear a condom". Defendant Trump responded by violently striking Plaintiff Johnson in the face with his open hand and screaming that "he would do whatever he wanted" as he refused to wear protection. After achieving sexual orgasm, the Defendant, Donald J. Trump put his suit back on and when the Plaintiff, Katie Johnson, in tears asked Defendant Trump what would happen if he had impregnated her, Defendant Trump grabbed his wallet and threw some money at her and screamed that she should use the money "to get a fucking abortion".
13. On the first occasion involving the Defendant, Jeffrey E. Epstein, the Plaintiff, Katie Johnson, was forced to disrobe into her bra and panties and to give a full body massage to Defendant Epstein while he was completely naked. During the massage, Defendant Epstein physically forced Plaintiff Johnson to touch his erect penis with her bare hands and to clean up his ejaculated semen after he — achieved sexual orgasm.
14. On the second occasion involving the Defendant, Jeffrey Epstein, the Plaintiff, Katie Johnson] was again forced to disrobe into her bra and panties while giving Defendant Epstein a full body massage while he was completely naked. The Defendant, Donald J. Trump, was also present as he | was getting his own massage from another minor, Jane Doe, age 13. Defendant Epstein forced Plaintiff Johnson to touch his erect penis by physically placing her bare hands upon his sex organ
and again forced Plaintiff Johnson to clean up his ejaculated semen after he achieved sexual orgasm.
CV-126 (09/09) PLEADING PAGE FOR A COMPLAINT
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15. Shortly after this sexual assault by the Defendant, Jeffrey E. Epstein, on the Plaintiff, Katie Johnson, Plaintiff Johnson was still present while the two Defendants were arguing over who would be the one to take Plaintiff Johnson's virginity. The Defendant, Donald J. Trump, was clearly heard referring to Defendant, Jeffrey E. Epstein, as a "Jew Bastard" as he yelled at Defendant Epstein, that clearly, he, Defendant Trump, should be the lucky one to "pop the cherry" of Plaintiff Johnson.
16. The third and final sexual assault by the Defendant, Jeffrey E. Epstein, on the Plaintiff, Kati Johnson, took place after Plaintiff Johnson had been brutally and savagely raped by Defendant Trump. While receiving another full body massage from Plaintiff Johnson, while in the nude, Defendant Epstein became so enraged after finding out that Defendant Trump had been the one to take Plaintiff Johnson's virginity, that Defendant Epstein also violently raped Plaintiff Johnson. After forcing Plaintiff Johnson to disrobe into her bra and panties, while receiving a massage from the Plaintiff, Defendant Epstein attempted to enter Plaintiff Johnson's anal cavity with his erect penis while trying to restrain her. Plaintiff Johnson attempted to push Defendant Epstein away, at which time Defendant Epstein attempted to enter Plaintiff Johnson's vagina with his erect penis. This attempt to brutally sodomize and rape Plaintiff Johnson by Defendant Epstein was finally repelled by Plaintiff Johnson but not before Defendant Epstein was able to achieve sexual orgasm. After perversely sodomizing and raping the Plaintiff, Katie Johnson, the Defendant, Jeffrey E. Epstein, attempted to strike her about the head with his closed fists while he angrily screamed at Plaintiff Johnson that he, Defendant Epstein, should have been the one who "took her cherry, not Mr. Trump", before she finally managed to break away from Defendant Epstein.
17. The Plaintiff, Katie Johnson, was fully warned on more than one occasion by both Defendants, Donald J. Trump and Jeffrey E. Epstein, that were she ever to reveal any of the details of the sexual and physical abuse that she had suffered as a sex slave for Defendant Trump and Defendant Epstein, that Plaintiff Johnson and her family would be in mortal danger. Plaintiff Johnson was warned that this would mean certain death for herself and Plaintiff Johnson's family unless she remained silent forever on the exact details of the depraved and perverted sexual and physical abuse she had been forced to endure from the Defendants.
4
CV-126 (09/09) PLEADING PAGE FOR A COMPLAINT
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MATERIAL WITNESSES
18. Tiffany Doe, a former trusted employee of the Defendant, Jeffrey E. Epstein, has agreed to provide sworn testimony in this civil case and any other future civil or criminal proceedings, fully verifying the authenticity of the claims of the Plaintiff, Katie Johnson. Witness Tiffany Doe was employed by the Defendant, Jeffrey E. Epstein, for more than 10 years as a party planner for his underage sex parties. Despite being subject to constant terroristic threats by Defendants Epstein and Trump to never reveal the details of these underage sex parties at which scores of teenagers, and pre-teen girls were used as sex slaves by Defendant Epstein and Defendant Trump, witness
Tiffany Doe refuses to be silent any longer. She has agreed to fully reveal the extent of the sexual
perversion and physical cruelty that she personally witnessed at these parties by Defendants Epstein and Trump.
19. Material witness Tiffany Doe fully confirms all of Plaintiff Katie Johnson's allegations of physical and sexual abuse by Defendants Donald J. Trump and Jeffrey E. Epstein. Tiffany Doe was physically present at each of the four occasions of sexual abuse by Defendant Trump upon the person of Plaintiff Johnson, as it was her job to witness all of the sexual escapades of Defendant Epstein's guests at these underage sex parties and later reveal all of the sordid details directly to Defendant Epstein. Defendant Epstein also demanded that Tiffany Doe tell him personally everything she had overheard at these parties explaining to her that "knowledge was king" in the financial world. As a result of these underage sex parties, Defendant Epstein was able to accumulat inside business knowledge that he otherwise would never have been privy to in order to amass his huge personal fortune.
20. Material witness Tiffany Doe will testify that she was also present or had direct knowledge of each of the three instances on which Defendant Jeffrey E. Epstein physically and sexually abused the Plaintiff, Katie Johnson. Tiffany Doe will testify to the fact that the Plaintiff, Katie Johnson, was extremely fortunate to have survived all of the physical and sexual horrors inflicted upon her
by Defendants Epstein and Trump.
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CLAIM FOR RELIEF
21. The Plaintiff, Katie Johnson, asks the court for relief against the Defendants, Donald J. Trump and Jeffrey E. Epstein, in the amount of $100,000,000.00 (One Hundred Million Dollars) as a result of the Defendants aforementioned acts upon which they willfully and maliciously violated the Civil Rights of the Plaintiff as stated in 18 U.S.C. ; 2241 by sexually and physically abusing the then 13 year old Plaintiff Johnson under threat of harm to her and her family, and 42 U.S.C. ; 1985 by the Defendants conspiring to deny the Civil Rights of Plaintiff Johnson by making her their sex _
slave.
Dated: April 26, 2016 KATIE JOHNSON
Plaintiff Katie Jo dnson
Appearing In Pro Per
CV-126 (09/09) PLEADING PAGE FOR A COMPLAINT
Case 5:16-cv-00797-DMG-KS Document 2 Filed 04/26/16 Page1of1 Page ID #:11
NAME, ADDRESS, AND TELEPHONE NUMBER OF ATTORNEY(S) OR OF PARTY APPEARING IN PRO PER
KATIE JOHNSON
6634 DESERT QUEEN AVE. TWENTYNINE PALMS, CA. 92277 (760) 401-0192
NO E-MAIL OR FAX
Ag
ATTORNEY(S) FOR:
Bis - UNITED STATES DISTRICT COURT © CENTRAL DISTRICT OF CALIFORNIA
So > CASE NUMBER: | yi 2 on KATIE JOHNSON ——— NS ( IC Sx ) FE ms 6 = 0) 0 / 9 : Vv. y CERTIFICATION AND NOTICE
DONALD J. TRUMP and OF INTERESTED PARTIES JEFFREY E. EPSTEIN a (Local Rule 7.1-1)
HWY 92 Ud¥ 9102
TO: ©THE COURT AND ALL PARTIES OF RECORD:
The undersigned, counsel of record for KATIE JOHNSON or party appearing in pro per, certifies that the following listed party (or parties) may have a pecuniary interest in the outcome of this case. These representations are made to enable the Court to evaluate possible disqualification
or recusal.
(List the names of all such parties and identify their connection and interest. Use additional sheet if necessary.)
PARTY CONNECTION / INTEREST PLAINTIFF KATIE JOHNSON NO CONNECTION OR INTEREST TO ANY CORPORATE ENTITY OR ANY FOUNDATION.
DEFENDANT DONALD J. TRUMP CONNECTED TO THE TRUMP ORGANIZATION, TRUMP UNIVERSITY, DONALD J. TRUMP FOR PRESIDENT CAMPAIGN AND THE DONALD J. TRUMP FOUNDATION.
DEFENDANT JEFFREY E. EPSTEIN CONNECTED TO J. EPSTEIN AND COMPANY, THE FINANCIAL TRUST COMPANY AND THE JEFFREY EPSTEIN VI FOUNDATION.
Attorney of record for (or name of party appearing in pro per):
KATIE JOHNSON
)
CV-30 (05/13) NOTICE OF INTERESTED PARTIES
Case 5:16-cv-00797-DMG-KS Document 3 Filed 04/26/16 Pagel1of2 Page ID #:12
KATIE JOHNSON
6634 DESERT QUEEN AVE. TWENTYNINE PALMS, CA. 92277 (760) 401-0192
NO FAX OR E-MAIL
VMINSO Hy .
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HWY 192 UW 9102
UNITED STATES DISTRICT COURT Boz CENTRAL DISTRICT OF CALIFORNIA on TO
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KATIE JOHNSON semsciesciaiamaineanios ; a
9 CVvi6-0079 ( [xs . P'¢ scanmmme Dove \) \ Ma x) - REQUEST TO PROCEED DONALD J. TRUMP and IN FORMA PAUPERIS WITH JEFFREY E. EPSTEIN TERRA ANITE. DECLARATION IN SUPPORT
I, KATIE JOHNSON , declare under penalty of perjury, that the foregoing is true and correct; that I am the petitioner/plaintiff in the above entitled case; that in support of my motion to proceed without being required to prepay fees, costs or give security therefore, I state that because of my poverty I am unable to pay the costs of said proceedings or to give security therefore and that I am entitled to redress.
I further declare under penalty of perjury that the responses which I have made to the questions and instructions below are true, correct and complete. 1. Are you presently employed? LlYes MNo
a. Ifthe answer is yes, state the amount of your salary or wages per month, and give the name and address of your
employer.
If the answer is no, state the date of last employment and the amount of the salary and wages per month which
you received. In 2008 I worked as a free-lance model and earned an average of $200-$300 a month
2. Have you received, within the past twelve months, any money from any of the following sources?
a. Business, profession or form of self-employment? OYes WNo b. Rent payments, interest or dividends? OYes MNo c. Pensions, annuities or life insurance payments? OYes MNo d. Gifts or inheritances? OYes MNo e. Any other income (other than listed above)? OYes MNo f. Loans? OYes MNo
If the answer to any of the above is yes, describe such source of money and state the amount received from each
source during the past twelve (12) months:
REQUEST TO PROCEED IN FORMA PAUPERIS WITH DECLARATION IN SUPPORT CV-60 (04/06) () Page | of 2
Case 5:16-cv-00797-DMG-KS Document 3 Filed 04/26/16 Page 2of2 Page ID#:13 3. Do you own any cash, or do you have money in a checking or savings account? (Include any funds in prison accounts, if applicable.) MYes CINo If the answer is yes, identify each account and separately state the amount of money held in each account for each of the six (6) months prior to the date of this declaration.
J have $276 in cash on hand.
4. Do you own any real estate, stocks, bonds, notes, automobiles, or other valuable property (excluding ordinary household furnishings and clothing)? C1Yes MNo
If the answer is yes, describe the property and state its approximate value:
5. In what year did you last file an Income Tax return? J never earned enough in any one year to have to file a return.
Approximately how much income did your last tax return reflect? CA
6. List the persons who are dependent upon your for support, state your relationship to those persons, and indicate how much you contribute toward their support:
No one.
I understand that a false statement or answer to any question in this declaration will subject me to penalties for perjury. I further understand that perjury is punishable by a term of imprisonment of up to five (5) years and/or a fine of $250,000 (18 U.S.C. Sections 1621, 3571).
California | ___San Bernadino Coun State County (or City) I, KATIE JOHNSON | , declare under penalty of perjury that the
foregoing is true and correct.
iff/Petitioner (Si onature)
‘REQUEST TO PROCEED IN FORMA PAUPERIS WITH DECLARATION IN SUPPORT CV-60 (04/06) Page 2 of 2
Case 5:16-cv-00797-DMG-KS Document 4 Filed 04/26/16 Pagelofi Page ID#:14
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
NOTICE OF ASSIGNMENT TO UNITED STATES JUDGES
This case has been assigned to:
District Judge Dolly M. Gee Magistrate Judge Karen L. Stevenson
The case number on all documents filed with the Court should read as follows:
5:16-—cv—00797 DMG(KSx)
Most district judges in the Central District of California refer all discovery-related motions to the assigned magistrate judge pursuant to General Order No. 05-07. If this case has been assigned to Judge Manuel L. Real, discovery-related motions should generally be noticed for hearing before the assigned district judge. Otherwise, discovery-related motions should generally be noticed for hearing before the assigned magistrate judge. Please refer to the assigned judges’ Procedures and Schedules, available on the Court’s website at www.cacd.uscourts. gov/judges-requirements, for additional information.
Clerk, U.S. District Court
April 26, 2016 By _/s/ Edwin Sambrano Date Deputy Clerk ATTENTION
The party that filed the case-initiating document in this case (for example, the complaint or the notice of removal) must serve a copy of this Notice on all parties served with the case-initiating document. In addition, if the case-initiating document in this case was electronically filed, the party that filed it must, upon receipt of this Notice, promptly deliver mandatory chambers copies of all previously filed documents to the newly assigned-district judge. See L.R. 5-4.5. A copy of this Notice should be attached to the first page of the mandatory chambers copy of the case-initiating document.
CV-18 (04/16) NOTICE OF ASSIGNMENT TO UNITED STATES JUDGES
Case 5:16-cv-00797-DMG-KS Document5 Filed 04/26/16 Pagelof2 Page ID#:15
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
CASE NUMBER: Nee 5:16—cv—00797—DMG-KS Plaintiff(s) V. DONALD J. TRUMP, et al. NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM Defendant(s).
NOTICE TO PARTIES:
It is the policy of this Court to encourage settlement of civil litigation when such is in the best interest of the parties. The Court favors any reasonable means, including alternative dispute resolution (ADR), to accomplish this goal. See Civil L.R. 16-15. Unless exempted by the trial judge, parties in all civil cases must participate in an ADR process before trial. See Civil L.R. 16-15.1.
The district judge to whom the above-referenced case has been assigned is participating in an ADR Program that presumptively directs this case to either the Court Mediation Panel or to private mediation. See General Order No. 11—10, §5. For more information about the Mediation Panel, visit the Court website, www.cacd.uscourts.gov, under "ADR."
Pursuant to Civil L.R. 26—1(c), counsel are directed to furnish and discuss with their clients the attached ADR Notice To Parties before the conference of the parties mandated by Fed.R.Civ.P. 26(f). Based upon the consultation with their clients and discussion with opposing counsel, counsel must indicate the following in their Joint 26(f) Report: 1) whether the case is best suited for mediation with a neutral from the Court Mediation Panel or private mediation; and 2) when the mediation should occur. See Civil L.R. 26—-1(c).
At the initial scheduling conference, counsel should be fully prepared to discuss their preference for referral to the Court Mediation Panel or to private mediation and when the mediation should occur. The Court will enter an Order/Referral to ADR at or around the time of the scheduling conference.
Clerk, U.S. District Court
April 26, 2016 By _/s/ Edwin Sambrano Date Deputy Clerk
ADR-08 (05/13) NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM
Case 5:16-cv-00797-DMG-KS Document5 Filed 04/26/16 Page 2of2 Page ID #:16
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
NOTICE TO PARTIES: COURT POLICY ON SETTLEMENT AND USE OF ALTERNATIVE DISPUTE RESOLUTION (ADR) Counsel are required to furnish and discuss this Notice with their clients.
Despite the efforts of the courts to achieve a fair, timely and just outcome in all cases, litigation has become an often lengthy and expensive process. For this reason, it is this Court's policy to encourage parties to attempt to settle their disputes, whenever possible, through alternative dispute resolution (ADR).
ADR can reduce both the time it takes to resolve a case and the costs of litigation, which can be substantial. ADR options include mediation, arbitration (binding or non—binding),neutral evaluation (NE), conciliation, mini—trial and fact-finding. ADR can be either Court—directed or privately conducted.
The Court's ADR Program offers mediation through a panel of qualified and impartial attorneys who will encourage the fair, speedy and economic resolution of civil actions. Panel Mediators each have at least ten years of legal experience and are appointed by the Court. They volunteer their preparation time and the first three hours of a mediation session. This is a cost-effective way for parties to explore potential avenues of resolution.
This Court requires that counsel discuss with their clients the ADR options available and instructs them to come prepared to discuss the parties' choice of ADR option (settlement conference before a magistrate judge; Court Mediation Panel; private mediation) at the initial scheduling conference. Counsel are also required to indicate the client's choice of ADR option in advance of that conference. See Civil L.R. 26—1(c) and Fed.R.Civ.P. 26(f).
Clients and their counsel should carefully consider the anticipated expense of litigation, the uncertainties as to outcome, the time it will take to get to trial, the time an appeal will take if a decision is appealed, the burdens on a client's time, and the costs and expenses of litigation in relation to the amounts or stakes involved.
With more than 15,000 civil cases filed in the District in 2012, less than | percent actually went to trial. Most cases are settled between the parties; voluntarily dismissed; resolved through Courtdirected or other forms of ADR; or dismissed by the Court as lacking in merit or for other reasons provided by law.
For more information about the Court's ADR Program, the Mediation Panel, and the profiles of mediators, visit the Court website, www.cacd.uscourts.gov, under "ADR."
ADR-08 (05/13) NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM
i + as i H q A A ki f ii ' i i I : f i 5 4 t 1 A. i i i i d |
Case 5:16-cv-00797-DMG-KS, Document 6 Filed 05/02/16 Page 1 of 3 Page ID #:17
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA |
KATIEJOHNSON, | | CASE NUMBER | ED CV 16-797-DMG (KSx) - PLAINTIFE(S) : . | = - DONALD J. TRUMP and JEFFREY E. EPSTEIN, | ORDER RE REQUEST TO PROCEED | IN FORMA PAUPERIS . DEFENDANT(S)
IT IS ORDERED that the Request to Proceed In Forma Pauperis is hereby GRANTED.
eee
Date | United States Magistrate Judge
IT IS RECOMMENDED that the Request to Proceed In Forma Pauperis be DENIED for the ilowine reason(s):
- [7] Inadequate showing of indigency [7] District Court lacks jurisdiction
I _— and/or factually patently frivolous — o Immunity as to
Comments:
v Le alta otal mum ovandum
AME no Oy United States Magistrate Judge |
IT IS ORDERED that the Request to Proceed In Forma Pauperis is hereby:
~ [x] DISMISSED <a ' | i DENIED (see comments above). IT IS FURTHER ORDERED that this case is hereby: a —_
Date United Stafgs District Judge
) RDER RE REQUEST TO PROCEED IN FORMA PAUPERIS | | |
CV-73 (03/16) O
Case 5:16-cv-00797-DMG-KS Document6 Filed 05/02/16 Page 2 of 3 Page ID #:18
ATTACHMENT TO DENIAL OF IFP APPLICATION FOR
KATIE JOHNSON, ED CV 16-797-DMG (KSx)
In the Complaint, Plaintiff Katie Johnson (‘Plaintiff’) alleges that defendants Donald J. Trump and Jeffrey E. Epstein (together, “Defendants”) | violated her civil rights through sexual and physical abuse and conspired to deprive her of her civil rights. (Complaint at 2.) Plaintiff seeks $100,000,000 in compensatory damages. (/d. at 6.) Plaintiff utilized the form provided by the Central District of California for civil actions and asserts that her action is brought pursuant to 18 U.S.C. § 2241 (aggravated sexual abuse) and 42 US.C. § 1985 (conspiracy to interfere with civil rights). Plaintiff has failed to state a claim for relief under either statute.
First, 18 U.S.C. § 2241(C) is a criminal statute that provides for the - prosecution of persons who cross a State line with the intent to engage in a sexual act with a minor. Specifically, the statute provides that a person who knowingly engages ina sexual act under circumstances described in sections (a) and (b) of the
statute, with a person between the ages of 12 years and 16 years may be “fined
under this title and imprisoned for not less than 30 years or for life.” 18 U.S.C.
§ 2241 (c). Nothing in the statute provides for a private right of action for civil | damages such as Plaintiff seeks here. |
Second, 42 U.S.C. § 1985 proscribes certain types of conspiracies to interfere with civil rights. Sanchez vy. City of Santa Ana, 936 F.2d 1027, 1039 (9th Cir. 1991); Karim-Panahi v. Los Angeles Police Dep t, 839 F. 2d 621, 626 (9th Cir. 1988). Clause (1) of the statute prohibits conduct that prevents federal officers from performing their duties, while clause (2) addresses obstructing justice; intimidating a party, witness or juror. 42 U.S.C. § 1985 (1)(2); see also Portman v. Cty of Santa Clara, 995 F.2d 898, 909 (9th Cir. 1993) (second clause of § 1985 creates a federal cause of action for conspiracies to obstruct access to state or territorial courts). Here, because Plaintiff does not assert any federal interest or : ~ involvement with the alleged conspiracy, the Court must conclude that her § 1985 | claims is based upon clause (3), which prohibits conspiracies to deprive a person or
Case 5:16-cv-00797-DMG-KS Document 6 Filed 05/02/16 Page 3o0f3 Page ID #19
class of persons of equal protection of the law, or equal privileges and immunities under the laws, including, for example, exercising the right to vote.
“AI US. C. § 1985(3) — the Ku Klux Klan Act of 1987 — was enacted by the Reconstruction Congress to protect individuals—primarily blacks—from conspiracies to deprive them of their legally protected rights.” Sever v. Alaska Pulp Corp., 978 F.2d 1529, 1536 (9th Cir. 1992). To state a claim under section 1985(3), a plaintiff must allege: (1) a conspiracy; (2) for the purpose of depriving any person ora class of persons of the equal protection of the laws, or of equal privileges and immunities under the laws; (3) an act by one of the conspirators in furtherance of the conspiracy; and (4) a personal injury, property damages, or a deprivation of any right or privilege of a citizen of the United States. Jd. The Supreme Court has emphasized that § 1985 (3) is not to be interpreted as a general federal tort law, but, as under § 1981, a plaintiff must prove as an element of the cause of action “some racial, or perhaps otherwise class-based, invidiously discriminatory animus behind the conspirators’ action.” Bray v. Alexandria Women’s Health Clinic, 506 U.S. 263, 268-69 (1993) (quoting Griffin v.— Breckenridge, 403 U.S. 88, 102 (1971); see also RK Ventures, Inc. v. City of Seattle, 307 F.3d 1045, 1056 (9th Cir. 2002) (“To bring a cause of action successfully under § 1985 (3), a plaintiff must demonstrate a deprivation of a right motivated by ‘some racial, or perhaps otherwise class-based, invidiously discriminatory animus behind the conspirators’ action.’ Particularly relevant here, the plaintiff must be a member of the class discriminated against.” (citation
omitted)).
| Here, even construing the pro se pleading liberally, Plaintiff has not alleged : any race-based or class-based animus against her and, consequently, her section 1985 allegations fail to state a claim upon which relief may be granted.
Accordingly, IFP status should be denied.
. Case 5:16-cv-00797-DMG-KS : 7 Filed ee = ' —_.. ID #:20
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Case 5:16-cv-00797-DMG-KS Document 7 Filed 05/09/16 Page 2of5 Page ID #:21
Case: 5:1l6cv797 Doc: 5
Katie Johnson 6634 Desert Queen Ave. Twentynine Palms, CA 92277
Case 5:16-cv-00797-DMG-KS Document 7 Filed 05/09/16 Page 3of5 Page ID #:22
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UNITED STATES DISTRICT COURT for the CENTRAL DISTRICT OF CALIFORNIA
Notice of Electronic Filing The following transaction was entered on 4/27/2016 at 2:12 PM PDT and filed on 4/26/2016
Case Name: Katie Johnson v. Donald J. Trump et al Case Number: 5:16-cv-00797-DMG-KS Filer:
Document Number:
Docket Text: NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed.(esa)
5:16-cv-00797-DMG-KS Notice has been electronically mailed to:
5:16-cv-00797-DMG-KS Notice has been delivered by First Class U.S. Mail or by other means BY THE FILER to:
Katie Johnson
6634 Desert Queen Ave.
Twentynine Palms CA 92277
aN i es eat ae EI eer a tater tl GL 2
Case 5:16-cv-00797-DMG-KS Document 7 Filed 05/09/16 Page 4of5 Page ID #:23
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
CASE NUMBER: KATIE JOHNSON 5:16—cv-00797~-DMG-KS Plaintiff(s) Vv. DONALD J. TRUMP, et al. NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM
Defendant(s).
NOTICE TO PARTIES:
It is the policy of this Court to encourage settlement of civil litigation when such is in the best interest of the parties. The Court favors any reasonable means, including alternative dispute resolution (ADR), to accomplish this goal. See Civil L.R. 16-15. Unless exempted by the trial judge, parties in all civil cases must participate in an ADR process before trial. See Civil L.R. 16-15.1.
The district judge to whom the above-referenced case has been assigned is participating in an ADR Program that presumptively directs this case to either the Court Mediation Panel or to private mediation. See General Order No. 11-10, §5. For more information about the Mediation Panel, visit the Court website, www.cacd.uscourts.gov, under "ADR."
:
Pursuant to Civil L.R. 26—1(c), counsel are directed to furnish and discuss with their clients the attached ADR Notice To Parties before the conference of the parties mandated by Fed.R.Civ.P. 26(f). Based upon the consultation with their clients and discussion with opposing ; counsel, counsel must indicate the following in their Joint 26(f) Report: 1) whether the case is 7 best suited for mediation with a neutral from the Court Mediation Panel or private mediation;
2 and 2) when the mediation should occur. See Civil L.R. 26—1(c).
|
| At the initial scheduling conference, counsel should be fully prepared to discuss their
! preference for referral to the Court Mediation Panel or to private mediation and when the mediation should occur. The Court will enter an Order/Referral to ADR at or around the time of the scheduling conference. |
Clerk, U.S. District Court
Date Deputy Clerk
ADR-08 (05/13) NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM
: : : April 26, 2016 By _/s/ Edwin Sambrano |
Sree te a eta
eee at the lib etal ase aren
ar a A EY See led
Case 5:16-cv-00797-DMG-KS Document 7 Filed 05/09/16 Page5of5 Page ID #:24
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
NOTICE TO PARTIES: COURT POLICY ON SETTLEMENT AND USE OF ALTERNATIVE DISPUTE RESOLUTION (ADR) Counsel are required to furnish and discuss this Notice with their clients.
Despite the efforts of the courts to achieve a fair, timely and just outcome in all cases, litigation has become an often lengthy and expensive process. For this reason, it is this Court's policy to encourage parties to attempt to settle their disputes, whenever possible, through alternative dispute resolution (ADR).
ADR can reduce both the time it takes to resolve a case and the costs of litigation, which can be substantial. ADR options include mediation, arbitration (binding or non—binding),neutral evaluation (NE), conciliation, mini—trial and fact-finding. ADR can be either Court—directed or privately conducted.
The Court's ADR Program offers mediation through a panel of qualified and impartial attorneys who will encourage the fair, speedy and economic resolution of civil actions. Panel Mediators each have at least ten years of legal experience and are appointed by the Court. They volunteer their preparation time and the first three hours of a mediation session. This is a cost—effective way for parties to explore potential avenues of resolution.
This Court requires that counsel discuss with their clients the ADR options available and instructs them to come prepared to discuss the parties’ choice of ADR option (settlement conference before a magistrate judge; Court Mediation Panel; private mediation) at the initial scheduling conference. Counsel are also required to indicate the client's choice of ADR option in advance of that conference. See Civil L.R. 26-1(c) and Fed.R.Civ.P. 26(f).
Clients and their counsel should carefully consider the anticipated expense of litigation, the uncertainties as to outcome, the time it will take to get to trial, the time an appeal will take if a decision is appealed, the burdens on a client's time, and the costs and expenses of litigation in relation to the amounts or stakes involved.
With more than 15,000 civil cases filed in the District in 2012, less than 1 percent actually went to trial. Most cases are settled between the parties; voluntarily dismissed; resolved through Courtdirected or other forms of ADR; or dismissed by the Court as lacking in merit or for other reasons provided by law.
For more information about the Court's ADR Program, the Mediation Panel, and the profiles of mediators, visit the Court website, www.cacd.uscourts.gov, under "ADR."
ADR-08 (05/13) NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM
Case: 5:16cv7/97 Doc: 4
Katie Johnson 6634 Desert Queen Ave. Twentynine Palms, CA 92277
Case 5:16-cv-00797-DMG-KS Document 8 Filed 05/09/16 Pageilof4 Page ID #:25
Case 5:16-cv-00797-DMG-KS Document 8 Filed 05/09/16 Page 2of4 Page ID #:26
MIME-Version:1.0 From:cacd_ecfmail@cacd.uscourts.gov To:ecfnef @cacd.uscourts.gov Message-Id:<21394517 @cacd.uscourts.gov>Subject:Activity in Case 5:16-cv-00797-DMG-KS Katie Johnson v. Donald J. Trump et al Notice of Assignment to United States Judges(CV-18) - optional html form Content-Type: text/html
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"NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
UNITED STATES DISTRICT COURT for the CENTRAL DISTRICT OF CALIFORNIA
Notice of Electronic Filing The following transaction was entered on 4/27/2016 at 2:11 PM PDT and filed on 4/26/2016
Case Name: _ Katie Johnson v. Donald J. Trump et al Case Number: 3:16-cv-00797-DMG-KS Filer:
Document Number:
Docket Text: NOTICE OF ASSIGNMENT to District Judge Dolly M. Gee and Magistrate Judge Karen L.
Stevenson. (esa)
5:16-cv-00797-DMG-KS Notice has been electronically mailed to:
5:16-cv-00797-DMG-KS Notice has been delivered by First Class U. S. Mail or by other means BY THE FILER to:
Katie Johnson
6634 Desert Queen Ave.
Twentynine Palms CA 92277
Case 5:16-cv-00797-DMG-KS Document 8 Filed 05/09/16 Page 3of4 Page ID #:27
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
NOTICE OF ASSIGNMENT TO UNITED STATES JUDGES
This case has been assigned to:
District Judge Dolly M. Gee Magistrate Judge Karen L. Stevenson
The case number on all documents filed with the Court should read as follows:
5:16-cv—00797 DMG(KSx)
Most district judges in the Central District of California refer all discovery-related motions to the assigned magistrate judge pursuant to General Order No. 05-07. If this case has been assigned to Judge Manuel L. Real, discovery-related motions should generally be noticed for hearing before the assigned district judge. Otherwise, discovery-related motions should generally be noticed for hearing before the assigned magistrate judge. Please refer to the assigned judges’ Procedures and Schedules, available on the Court’s website at www.cacd.uscourts. gov/judges-requirements, for additional information.
Clerk, U.S. District Court
April 26, 2016 By _/s/ Edwin Sambrano _ Date Deputy Clerk ATTENTION
The party that filed the case-initiating document in this case (for example, the complaint or the notice of removal) must serve a copy of this Notice on all parties served with the case-initiating document. In addition, if the case-initiating document in this case was electronically filed, the party that filed it must, upon receipt of this Notice, promptly deliver mandatory chambers copies of all previously filed documents to the newly assigned-district judge. See L.R. 5-4.5. A copy of this Notice should be attached to the first page of the mandatory chambers copy of the case-initiating document.
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CV-18 (04/16) NOTICE OF ASSIGNMENT TO UNITED STATES JUDGES
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| Case 5:16-cv-00797-DMG-KS Document 8 Filed 05/09/16 Page 4of4 Page ID #:28 UNITED STATES DISTRICT COURT
OFFICE OF THE CLERK U.S. COURTHOUSE, ROOM G8 LOS ANGELES, CALIFORNIA 90012
OFFICIAL BUSINESS
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Case 1:16-cv-04642-RA Document1 Filed 06/20/16 Page 1 of 9
IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
JEFFREY E. EPSTEIN,
JANE DOE, proceeding under a pseudonym, ) Plaintiff, - Case No.: DONALD J. TRUMP and ) JURY TRIAL DEMANDED ) ) )
Defendants.
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:
PARTIES 1. Plaintiff 1s an individual residing in and a citizen of the State of California. Zi 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 3. 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-04642-RA Document1 Filed 06/20/16 Page 2 of 9
5. 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
7. 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
Case 1:16-cv-04642-RA Document1 Filed 06/20/16 Page 3 of 9
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, inter alia, assault, battery, false imprisonment, and intentional or reckless infliction of emotional distress, including threats of force and serious bodily harm, under New York law. Declaration of Plaintiff Jane Doe, Exhibit A hereto; Declaration of Tiffany Doe, Exhibit B hereto. Jane Doe and Tiffany Doe are each pseudonyms as each woman wishes anonymity. Tiffany Doe, a witness, was an employee of Defendant Epstein. Exh. B.
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 defendants. 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
999
even more critically, to innocent non-parties’”’.), or are neutral with respect to anonymity. Protecting Plaintiff'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
Case 1:16-cv-04642-RA Document1 Filed 06/20/16 Page 4 of 9
Trump had known Defendant Epstein for seven years (New York, 10/28/02), 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 Plaintiff's 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 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 Plaintiff’s 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
Case 1:16-cv-04642-RA Document1 Filed 06/20/16 Page 5 of 9
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.
17. As a direct and proximate result of the sexual assaults and rapes perpetrated by Defendants upon her, Plaintiff has been subjected to public scorn, hatred, and ridicule and has suffered threats against her life and physical safety.
18. As a direct and proximate result of the sexual assaults and rapes perpetrated by Defendants upon her, Plaintiff has incurred special damages, including medical and legal expenses.
19. The sexual assaults and rapes perpetrated by Defendants upon Plaintiff were intentional acts.
20. The conduct of Defendants demonstrates willful, reckless and intentional conduct
that raises a conscious indifference to consequences.
Case 1:16-cv-04642-RA Document1 Filed 06/20/16 Page 6 of 9
Zi. At the appropriate time in this litigation, Plaintiff shall amend her complaint to assert a claim for punitive damages against Defendants in order to punish Defendants for their
actions and to deter Defendants from repeating their conduct.
TOLLING OF STATUTE OF LIMITATIONS
2D, Any statute of limitations applicable to rape, sexual misconduct, criminal sexual acts, sexual abuse, forcible touching, assault, battery, intentional and reckless infliction of emotional distress, false imprisonment of a minor, if any, 1s tolled owing to the continuous and active duress imposed upon Plaintiff by Defendants that effectively robbed Plaintiff of her free will to commence legal action until the present time. Cullen v. Margiotta, 811 F.2d 698, 722 (2nd Cir.1987); Ross v. United States, 574 F. Supp. 536, 542 (S.D.N.Y. 1983). More particularly, Plaintiff was unrelentingly threatened by each Defendant that, were she ever to reveal any of the details of the sexual and physical abuse caused to her by Defendants, Plaintiff 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.
D3: 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 she didn’t want to disappear
like Maria, a 12-year-old female that was forced to be involved in the third incident with
Case 1:16-cv-04642-RA Document1 Filed 06/20/16 Page 7 of 9
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.
26. Moreover, this action has been brought before the facts giving rise to the estoppel have ceased to be operational (1.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.
DEFAMATION 21 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 Plaintiff's complaint 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
Case 1:16-cv-04642-RA Document1 Filed 06/20/16 Page 8 of 9
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). The statement provided for publication by Defendant Trump and that was published by said websites is false as it pertains to Plaintiff.
28. The published statement is libelous on its face, and clearly exposes Plaintiff to hatred, contempt, ridicule and obloquy.
20. As a proximate result of the above-described publication, 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 publication was not privileged because it was published by Defendant Trump 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;
Case 1:16-cv-04642-RA Document1 Filed 06/20/16 Page 9 of 9
B. That all costs of this action be assessed against Defendants, including all reasonable 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.
JURY DEMAND
Plaintiff demands a trial by jury of all issues properly triable by jury in this action.
Respectfully submitted,
Dated: June 20, 2016 By: /s/ Thomas Francis Meagher Thomas Francis Meagher SDNY Bar Code TM6707 One Palmer Square Princeton, New Jersey 08542 Telephone: (609) 558-1500 tmeagher @thomasfmeagheresq.com
ATTORNEY FOR PLAINTIFF
Case 1:16-cv-04642-RA Document1-1 Filed 06/20/16 Page 1 of 2
DECLARATION IN SUPPORT OF PLAINTIFF’S REQUEST FOR PROTECTIVE ORDER
|, Jane Doe, the Plaintiff in this matter proceeding under a pseudonym, state as follows:
\
1. lam acompetent adult over 18 years of age able to testify as to personal knowledge. The facts in this declaration are true and correct to the best of my knowledge, information, and belief, and | am competent to testify to them if called upon to do so.
2. | was subject to extreme sexual and physical abuse by the Defendants, including forcible rape, that took place at several parties of Defendant Epstein during the summer of 1994 in New York City at a residence used by Defendant Epstein. During this period, | was 13 years old.
3. More particularly, | traveled by bus to New York City in June 1994 in the hope of starting a modeling career. | went to several modeling agencies but was told that | needed to put together a modeling portfolio before | would be considered. | then went to the Port Authority in New York City to start to make my way back home. There | met a woman who introduced herself to me as Tiffany. She told me about the parties and said that, if | would join her at the parties, | would be introduced to people who could get me into the modeling profession. Tiffany also told me | would be paid for attending.
4, The parties were held at a New York City residence that was being used by Defendant Jeffrey Epstein. Each of the parties had other minor females and a number of guests of Mr. Epstein, including Defendant Donald Trump at four of the parties | attended. | understood that both Mr. Trump and Mr. Epstein knew that | was 13 years old.
5, Defendant Trump had sexual contact with me at four different parties in the summer of 1994. On the fourth and final sexual encounter with Defendant Trump, Defendant Trump tied me to a bed, exposed himself to me, and then proceeded to forcibly rape me. During the course of this savage sexual attack, | loudly pleaded with Defendant Trump to stop but he did not. Defendant Trump responded to my pleas by violently striking me in the face with his open hand and screaming that he would do whatever he wanted.
6. Immediately following this rape, Defendant Trump threatened me that, were | ever to reveal any of the details of Defendant Trump’s sexual and physical abuse of me, my family and | would be physically harmed if not killed.
Z. Defendant Epstein had sexual contact with me at two of the parties that summer. On the second occasion involving Defendant Epstein, Defendant Epstein forced himself upon me and proceeded to rape me anally and vaginally despite my Joud pleas to stop. Defendant Epstein then attempted to strike me about the head with his closed fists while he angrily screamed at me that he, Defendant Epstein, should have been the one who took my virginity, not Defendant Trump, before | finally managed to break away from Defendant Epstein.
Case 1:16-cv-04642-RA Document 1-1 Filed 06/20/16 Page 2 of 2
8. Immediately following this rape, just like Defendant Trump, Defendant Epstein threatened me not to ever reveal any of the details of Defendant Epstein’s sexual and physical abuse of me or else my family and | would be physically harmed if not killed.
9. Both Defendants had let me 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 | 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 | had not seen since that third incident, and that he was capable of having my whole family killed.
10. The duress imposed on me by Defendants not to ever reveal any of the details of the sexual and physical abuse caused to me by Defendants has not terminated and the fear it has instilled in me has not subsided. Unfortunately, making matters worse for me, | was subjected to daily painful reminders of the horrific acts of Defendant Trump via mass media coverage of him starting last summer that, over a short period of time, became continuous and unavoidable.
11. The duress had prevented me from starting litigation before this year. However, as soon as | surfaced, | received threats. More specifically, shortly after my first complaint was filed in California on April 26, 2016, | started receiving threatening phone calls on a cell phone | then owned. The calls were never for more than 20 seconds or so before they hung up and they were always from a blocked or unavailable phone number according to my caller ID feature. Since | changed phone numbers, the threatening calls have completely stopped.
12. This litigation involves matters that are highly sensitive and of a personal nature, and | believe that identification of me would pose a risk of retaliatory physical harm to me and to others.
13. | have no reason to believe that the Defendants’ threats have ever been lifted or will ever be lifted and so | request that the Court issue an order protecting me and my family from harm and harassment by the Defendants.
| declare under penalty of perjury that the foregoing is true and correct.
DATED: June 18, 2016 ne Doe, a pseudonym
Case 1:16-cv-04642-RA Document 1-2 Filed 06/20/16 Page 1 of 2
DECLARATION IN SUPPORT OF PLAINTIFF’S REQUEST FOR PROTECTIVE ORDER
|, Tiffany Doe, a pseudonym, state as follows:
\
1. |am acompetent adult over 18 years of age able to testify as to personal knowledge. The facts in this declaration are true and correct to the best of my knowledge, information, and belief, and !am
competent to testify to them if called upon to do so.
2. | originally met Jeffrey E. Epstein in New York City in 1990 when | was the age of 22. | attended a
series of parties in that same year of 1990 where | was paid to entertain various guests of Mr. Epstein.
3. In the year 1991, | was promoted to the occupation of party planner in which my duties were to
get attractive adolescent women to attend these parties.
4, | was hired by and paid directly by Mr. Epstein from the years of 1991-2000 to attract adolescent women to attend these parties, most of which were held at what is known as the Wexner Mansion
located at 9 E. 71st St. in New York City.
5. In June, 1994 while performing my duties as a recruiter of adolescent women to attend Mr. Epstein's parties, | met a 13-year-old adolescent woman, the Plaintiff in this matter, at the Port Authority in New York City who said that she had come to New York City in the hope of starting a
modeling career.
6. | persuaded the Plaintiff to attend a series of parties of Mr. Epstein that took place during the summer of 1994. | told her that, if she would join me at the parties, she would be introduced to people
who could get her into the modeling profession and she would be paid for attending.
J. it was at these series of parties that | personally witnessed the Plaintiff being forced to perform various sexual acts with Donald J. Trump and Mr. Epstein. Both Mr. Trump and Mr. Epstein were
advised that she was 13 years old.
8. | personally witnessed four sexual encounters that the Plaintiff was forced to have with Mr. Trump during this period, including the fourth of these encounters where Mr. Trump forcibly raped her
despite her pleas to stop.
Case 1:16-cv-04642-RA Document 1-2 Filed 06/20/16 Page 2 of 2
9, | personally witnessed the one occasion where Mr. Trump forced the Plaintiff and a 12-year-old female named Maria perform oral sex on Mr. Trump and witnessed his physical abuse of both minors
when they finished the act.
10. | personally witnessed or was made immediately aware of the two occasions where my boss Mr. Epstein attempted to rape and sodomize the Plaintiff. | sersonally witnessed Mr. Epstein sexually and
physically abuse other minor females even younger than her.
11. It was my job to personally witness and supervise encounters between the underage girls that
Mr. Epstein hired and his guests.
12. | personally witnessed Mr. Trump physically threaten the life and well-being of the Plaintiff if she
ever revealed any details of the physical and sexual abuse suffered by her at the hands of Mr. Trump.
13, | personally witnessed Mr. Epstein physically threaten the life and well-being of the Plaintiff if she ever revealed the details of the physical and sexual abuse she suffered at the hands of Mr. Epstein
or any of his guests.
14. | personally witnessed Defendant Trump telling the Plaintiff that she shouldn’t ever say anything if she didn’t want to disappear like the 12-year-old female Maria, and that he was capable of having her
whole family killed.
15. After leaving the employment of Mr. Epstein in the year 2000, | was personally threatened by Mr. Epstein that | would be killed and my family killed as well if | ever disclosed any of the physical and
sexual abuse of minor females that | had personally witnessed by Mr. Epstein or any of his guests.
16. | am coming forward to swear to the truthfulness of the physical and sexual abuse that | personally witnessed of minor females at the hands of Mr. Trump and Mr. Epstein, including the Plaintiff, during the time of my employment from the years of 1990-2000 for Mr. Epstein. | swear to these facts under penalty of perjury even though | fully understand that the life of myself and my family
is now in grave danger.
| declare under penalty of perjury that the foregoing is true and cerrect.
a
DATED: June 18, 2016 LL af Fs
Tiffany | Doe, afis€tidonym
—
JS 44C/SDNY REV. 2/2016
PLAINTIFFS
Case 1:16-cv-04642-RA Qoalcoebe 2HHEHed 06/20/16 Page 1 of 2
The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the
Judicial Conference of the United States in September 1974, is required for use of the Clerk of Court for the purpose of
initiating the civil docket sheet.
Jane Doe, proceeding under a pseudonym
ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER
Thomas Francis Meagher,
One Palmer Square Princeton, NJ 08542 609-558-1500
Esq.
DEFENDANTS
Donald J. Trump and Jeffrey E. Epstein
ATTORNEYS (IF KNOWN)
CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE) (DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)
28 U.S.C. § 1332, 1391: RAPE, SEXUAL MISCONDUCT, CRIMINAL SEXUAL ACTS, SEXUAL ABUSE, FORCIBLE TOUCHING, ASSAUL
Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY at any time? Nd“Ves LTjudge Previously Assigned
If yes, was this case Vol.[ | Invol. [ ] Dismissed. No[ | Yes [ |
No [x|
IS THIS AN INTERNATIONAL ARBITRATION CASE?
(PLACE AN [x] IN ONE BOX ONLY)
CONTRACT
10 INSURANCE 20 MARINE
MILLER ACT
40 NEGOTIABLE INSTRUMENT RECOVERY OF OVERPAYMENT & ENFORCEMENT OF JUDGMENT MEDICARE ACT RECOVERY OF DEFAULTED STUDENT LOANS (EXCL VETERANS) RECOVERY OF OVERPAYMENT OF VETERAN'S BENEFITS STOCKHOLDERS SUITS
OTHER CONTRACT CONTRACT PRODUCT LIABILITY
[ ]196 FRANCHISE
[ 1160 [ 1190
[ ]195
REAL PROPERTY
[ 1210 LAND CONDEMNATION
[ 1220 FORECLOSURE
[ 1230 RENT LEASE & EJECTMENT
[ 1240 TORTS TO LAND
[ 1245 TORT PRODUCT LIABILITY [ 1290 ALL OTHER
REAL PROPERTY
TORTS
PERSONAL INJURY
[ 1310 AIRPLANE
[ 1315 AIRPLANE PRODUCT LIABILITY
[9 320 ASSAULT, LIBEL & SLANDER
[ 1330 FEDERAL EMPLOYERS' LIABILITY
[ 1340 MARINE
[ 1345 MARINE PRODUCT LIABILITY
[ ]350 MOTOR VEHICLE
[ 1355 MOTOR VEHICLE PRODUCT LIABILITY
[ 1360 OTHER PERSONAL INJURY
[ ]362 PERSONAL INJURY - MED MALPRACTICE
ACTIONS UNDER STATUTES
CIVIL RIGHTS
[ ]440 OTHER CIVIL RIGHTS (Non-Prisoner)
[ ]441 VOTING
[ ]442 EMPLOYMENT
[ 1443 HOUSING/ ACCOMMODATIONS
[ ]445 AMERICANS WITH DISABILITIES - EMPLOYMENT
[ ]446 AMERICANS WITH DISABILITIES -OTHER
[ ]448 EDUCATION
Check if demanded in complaint:
[|
DEMAND $
CHECK IF THIS IS ACLASS ACTION UNDER F.R.C.P. 23
OTHER
Check YES only if demanded in complaint JURY DEMAND: #] YES LNO
Yes [ |
If yes, give date
NATURE OF SUIT
PERSONAL INJURY [ ] 367 HEALTHCARE/
FORFEITURE/PENALTY
PHARMACEUTICAL PERSONAL [ ]625 DRUG RELATED
INJURY/PRODUCT LIABILITY [ ] 365 PERSONAL INJURY PRODUCT LIABILITY
[ ]368 ASBESTOS PERSONAL
INJURY PRODUCT LIABILITY
PERSONAL PROPERTY
[ ]370 OTHER FRAUD [ ]371 TRUTH IN LENDING
[ ] 380 OTHER PERSONAL PROPERTY DAMAGE
[ ]385 PROPERTY DAMAGE PRODUCT LIABILITY
PRISONER PETITIONS
[ ]463 ALIEN DETAINEE
[ ]510 MOTIONS TO VACATE SENTENCE 28 USC 2255
[ ]530 HABEAS CORPUS
[ ]535 DEATH PENALTY
[ ]540 MANDAMUS & OTHER
PRISONER CIVIL RIGHTS
[ ]550 CIVIL RIGHTS [ ]555 PRISON CONDITION [ ] 560 CIVIL DETAINEE
SEIZURE OF PROPERTY 21 USC 881 [ 1690 OTHER
LABOR
[ ] 710 FAIR LABOR STANDARDS ACT
[ ] 720 LABOR/MGMT RELATIONS
[ ] 740 RAILWAY LABOR ACT
[ ] 751 FAMILY MEDICAL LEAVE ACT (FMLA)
[ ]790 OTHER LABOR LITIGATION [ ]791 EMPL RET INC
& Case No.
ACTIONS UNDER STATUTES
BANKRUPTCY
[ ]422 APPEAL 28 USC 158
[ 1423 WITHDRAWAL 28 USC 157
PROPERTY RIGHTS
[ ]820 COPYRIGHTS [ 1830 PATENT [ 1840 TRADEMARK
SOCIAL SECURITY
[ 1861 HIA (1395ff) [ ]862 BLACK LUNG (923)
[ 1863 DIWC/DIWW (405(g)) [ 1864 SSID TITLE XVI
[ 1865 RSI (405(g))
FEDERAL TAX SUITS
[ ] 870 TAXES (U.S. Plaintiff or Defendant)
[ ] 871 IRS-THIRD PARTY 26 USC 7609
SECURITY ACT (ERISA)
IMMIGRATION
[ ] 462 NATURALIZATION APPLICATION
[ ]465 OTHER IMMIGRATION ACTIONS
CONDITIONS OF CONFINEMENT
OTHER STATUTES
[ ]375 FALSE CLAIMS [ 1376 QUI TAM
[ ]400 STATE REAPPORTIONMENT
[ ]410 ANTITRUST
[ ]430 BANKS & BANKING
[ ]450 COMMERCE
[ ]460 DEPORTATION
[ 1470 RACKETEER INFLU- ENCED & CORRUPT ORGANIZATION ACT (RICO)
[ ]480 CONSUMER CREDIT
[ ]490 CABLE/SATELLITE TV
[ ] 850 SECURITIES/ COMMODITIES/ EXCHANGE
[ ]890 OTHER STATUTORY ACTIONS [ ]891 AGRICULTURAL ACTS
[ ]893 ENVIRONMENTAL MATTERS
[ ]895 FREEDOM OF INFORMATION ACT
[ ] 896 ARBITRATION
[ ] 899 ADMINISTRATIVE PROCEDURE ACT/REVIEW OR APPEAL OF AGENCY DECISION
[ ]950 CONSTITUTIONALITY OF STATE STATUTES
DO CO CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y.?
DOCKET NUMBER
NOTE: You must also submit at the time of filing the Statement of Relatedness form (Form IH-32).
Case 1:16-cv-04642-RA Document 2 Filed 06/20/16 Page 2 of 2
(PLACE AN x INONE BOX ONLY) ORIGIN [3] 1 Original CI 2 Removed from CI 3° Remanded [| 4 Reinstated or [| 5 Transferred from [ | 6 Multidistrict [ | f Appeal to District Proceeding State Court from Reopened (Specify District) Litigation Judge from Appellate Magistrate Judge [ | a. all parties represented Court Judgment [ | b. Atleast one party is pro se. (PLACE AN x IN ONE BOX ONLY) BASIS OF JURISDICTION IF DIVERSITY, INDICATE []1 U.S. PLAINTIFF [[]2 U.S.DEFENDANT [_]|3 FEDERAL QUESTION [%]4 DIVERSITY CITIZENSHIP BELOW. (U.S. NOT A PARTY) CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY) (Place an [X] in one box for Plaintiff and one box for Defendant) PTF DEF PTF DEF PTF DEF CITIZEN OF THIS STATE []1 [se] 1 CITIZEN OR SUBJECT OF A []3[]3 INCORPORATED and PRINCIPAL PLACE []5 []5 FOREIGN COUNTRY OF BUSINESS IN ANOTHER STATE CITIZEN OF ANOTHER STATE [x#]2 []2 INCORPORATED or PRINCIPAL PLACE [ ]4[ ]4 FOREIGN NATION []6 []6
OF BUSINESS IN THIS STATE
PLAINTIFF(S) ADDRESS(ES) AND COUNTY (IES)
California (Plaintiff may be reached through her attorney)
DEFENDANT(S) ADDRESS(ES) AND COUNTY (IES) Donald J. Trump: 725 5th Ave., New York, New York; New York County
Jeffrey E. Epstein: 9 E. 71st St., New York, New York; New York County
DEFENDANT(S) ADDRESS UNKNOWN
REPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, | HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN THE RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:
Check one: THIS ACTION SHOULD BE ASSIGNED TO: | |] WHITE PLAINS [3] MANHATTAN (DO NOT check either box if this a PRISONER PETITION/PRISONER CIVIL RIGHTS COMPLAINT.)
ADMITTED TO PRACTICE IN THIS DISTRICT
[] NO
[99 YES (DATE ADMITTED Mo.October yr,1988 __ ) Attorney Bar Code # TM6707
DATE June 20, 201\sigNATURE OF ATTORNEY OF RECORD
RECEIPT # /s/Thomas Francis Meagher
Magistrate Judge is to be designated by the Clerk of the Court. Magistrate Judge is so Designated.
Ruby J. Krajick, Clerk of Court by Deputy Clerk, DATED
UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)
Clear Form Save Print
Case 1:16-cv-04642-RA Document 3 Filed 06/20/16 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the Southern District of New York
Jane Doe, proceeding under a pseudonym,
Plaintiff(s)
V. Civil Action No.
Donald J. Trump and Jeffrey E. Epstein
Neer eae Ol Ol Oe ae” s§
Defendant(s) SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) Donald J. Trump 725 Sth Ave. New York, New York
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and address are:
Thomas Francis Meagher, Esq. One Palmer Square Princeton, NJ 08542
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:16-cv-04642-RA Document 3 Filed 06/20/16 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (1))
This summons for (name of individual and title, if any)
was received by me on (date)
[1 I personally served the summons on the individual at (place)
on (date) , OF
[1] I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
[I I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or [1 I returned the summons unexecuted because - or [I Other (specify): My fees are $ for travel and $ for services, for a total of $ 0.00
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
a co [Reset
Case 1:16-cv-04642-RA Document 4 Filed 06/20/16 Page 1 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the Southern District of New York
Jane Doe, proceeding under a pseudonym,
Plaintiff(s)
V. Civil Action No.
Donald J. Trump and Jeffrey E. Epstein
Neer eae Ol Ol Oe ae” s§
Defendant(s) SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) Jeffrey E. Epstein 9 E. 71st St. New York, New York
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and address are:
Thomas Francis Meagher, Esq. One Palmer Square Princeton, NJ 08542
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:16-cv-04642-RA Document 4 Filed 06/20/16 Page 2 of 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (1))
This summons for (name of individual and title, if any)
was received by me on (date)
[1 I personally served the summons on the individual at (place)
on (date) , OF
[1] I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
[I I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or [1 I returned the summons unexecuted because - or [I Other (specify): My fees are $ for travel and $ for services, for a total of $ 0.00
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
a co [Reset
Caédesé:16-6ve0464O4 RAD dhornererd SFikethd@a0/14l 6Patpege afat 2
AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the Southern District of New York
Jane Doe, proceeding under a pseudonym,
Plaintiff(s)
V. Civil Action No. 16cv4642
Donald J. Trump and Jeffrey E. Epstein
Neer eae Ol Ol Oe ae” s§
Defendant(s) SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) Donald J. Trump 725 Sth Ave. New York, New York
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and address are:
Thomas Francis Meagher, Esq. One Palmer Square Princeton, NJ 08542
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
CLERK OF COURT
Date: 06/20/2016 /S/ D. Gonzalez
Signature of Clerk or Deputy Clerk
Caédasé:16-6ve0464O4 RAD dhornererd SFilethd@a0/14l 6Patpeg2 afar 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No. 16cv4642
PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (1))
This summons for (name of individual and title, if any)
was received by me on (date)
[1 I personally served the summons on the individual at (place)
on (date) ; or
[1] I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
[I I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or [1 I returned the summons unexecuted because - or [I Other (specify): My fees are $ for travel and $ for services, for a total of $ 0.00
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
a co [Reset
Caédasé:16-6ve0464O4 RAD dhornerert 6Filethd@ea0/14l 6Patpege afat 2
AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the Southern District of New York
Jane Doe, proceeding under a pseudonym,
Plaintiff(s)
V. Civil Action No. 16cv4642
Donald J. Trump and Jeffrey E. Epstein
Neer eae Ol Ol Oe ae” s§
Defendant(s) SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) Jeffrey E. Epstein 9 E. 71st St. New York, New York
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney, whose name and address are:
Thomas Francis Meagher, Esq. One Palmer Square Princeton, NJ 08542
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
CLERK OF COURT
Date: 06/20/2016 /S/ D. Gonzalez
Signature of Clerk or Deputy Clerk
Caédesé:16-6ve0464O4 RAD dhonnerert 6Filethd@a0/14l 6Patpeg2 afat 2
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (1))
This summons for (name of individual and title, if any)
was received by me on (date)
[1 I personally served the summons on the individual at (place)
on (date) , OF
[1] I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
[I I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or [1 I returned the summons unexecuted because - or [I Other (specify): My fees are $ for travel and $ for services, for a total of $ 0.00
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
a co [Reset
Case 1:16-cv-04642-RA Document 7 Filed 06/30/16 Page 1 of 2
USDC-SDNY DOCUMENT ELECTRONICALLY FILED UNITED STATES DISTRICT COURT DOC#: SOUTHERN DISTRICT OF NEW YORK DATE FILED: 6/30/2016
JANE DOE Processing under a pseudonym,
Plaintiff, No. 16-CV-4642 (RA)
”s ORDER AND NOTICE
DONALD J, TRUMP and JEFFREY E. OF INITIAL CONFERENCE
EPSTEIN,
Defendants.
RONNIE ABRAMS, United States District Judge:
This case has been assigned to me for all purposes. It is hereby:
ORDERED that counsel for all parties appear for an initial status conference on September 9, 2016 at 3:15 p.m. in Courtroom 1506 of the U.S. District Court for the Southern District of New York, 40 Foley Square, New York, New York.
IT IS FURTHER ORDERED that, by September 2, 2016, the parties submit a joint letter,
not to exceed five (5) pages, providing the following information in separate paragraphs:
I, A brief description of the nature of the action and the principal defenses thereto; Z: A brief explanation of why jurisdiction and venue lie in this Court. If any
party is a corporation, the letter shall state both the place of incorporation and the principal place of business. If any party is a partnership, limited partnership, limited liability company or trust, the letter shall state the citizenship of each of the entity’s members, shareholders, partners and/or trustees;
3 A brief description of all contemplated and/or outstanding motions and how such motions may affect scheduling in this matter;
4. A brief description of any discovery that has already taken place, and/or that which will be necessary for the parties to engage in meaningful settlement negotiations;
Case 1:16-cv-04642-RA Document 7 Filed 06/30/16 Page 2 of 2
5. A brief description of prior settlement discussions (without disclosing the parties’ offers or settlement positions) and the prospect of settlement;
6, The estimated length of trial; and
a Any other information that the parties believe may assist the Court in advancing the case to settlement or trial, including, but not limited to, a description of any dispositive issue or novel issue raised by the case.
IT IS FURTHER ORDERED that, by September 2, 2016, the parties jointly submit to the Court a proposed case management plan and scheduling order. A template for the order 1s available at http://nysd.uscourts.gov/judge/Abrams. The status letter and the proposed case management plan should be filed electronically on ECF, consistent with Section 13.1 of the Court’s Electronic Case Filing (ECF) Rules & Instructions, available at http://www.nysd.uscourts.gov/ecf/ecf_rules_080113.pdf.
Plaintiff is ordered to serve Defendants with a copy of this order and to file an affidavit on ECF certifying that such service has been effectuated. SO ORDERED.
Dated: June 30, 2016 New York, New York
United States District Judge
Case 1:16-cv-04642-RA Document 8 Filed 08/25/16 Page 1 of 1
USDC-SDNY DOCUMENT ELECTRONICALLY FILED UNITED STATES DISTRICT COURT DOC#: SOUTHERN DISTRICT OF NEW YORK DATE FILED: 08/25/2016
JANE DOE,
Plaintiff, No. 16-CV-4642 (RA)
V. ORDER
DONALD J. TRUMP and JEFFREY E. EPSTEIN,
Defendants.
RONNIE ABRAMS, United States District Judge:
An initial pretrial conference is presently scheduled for September 9, 2016 in this action. Plaintiff, however, has not yet filed affidavits of service confirming that Defendants have been served with copies of the summons and complaint. In order to allow Plaintiff the full amount of time authorized by Rule 4(m) of the Federal Rules of Civil Procedure to serve Defendants and to allow Defendants the full amount of time authorized by Rule 12(a) to respond to the complaint in
advance of the initial pretrial conference, the conference shall be adjourned until October 14, 2016
at 10:00 a.m. SO ORDERED. Dated: August 25, 2016 ——
New York, New York
Ronnie Abrams United States District Judge
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