SuperFlyBCat
Banned
Posts: 49,366
Joined: Mar 2005
I Root For: America and UC
Location: Cincinnati
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RE: Jeffrey Epstein arrested on sex trafficking of minors charges
(07-09-2019 10:30 AM)Machiavelli Wrote: (07-09-2019 08:42 AM)JMUDunk Wrote: (07-08-2019 11:51 PM)Machiavelli Wrote: 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
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Case 1:16-cv-07673-RA Document 1 Filed 09/30/16 Page 3 of 10
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. 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 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
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Case 1:16-cv-07673-RA Document 1 Filed 09/30/16 Page 4 of 10
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 Trump had known Defendant Epstein for seven years (New York, 10/28/02, “’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.
Yea, funny. Why is it Trumps DOJ Reopening all this while it seemingly took place and was ongoing TAKING PLACE while Bubba was in office and Janet Reno ran justice? Where were they? Hmmmm
Why didn’t the contemptible witHolder reopen any of this when the sentencing came down under his watch? What about Lynch, who clearly had a very soft spot when it came to discussing the grandkids?
Man O Man O Man
This Horowitz/Durham thing about to drop must be real doozy.
Thank you General Barr!
Amazing you guys even admit it. Are you implying Barr would only be reopening this if it incriminates D’s and would not be opening it if it harmed Trump. Like the opposite of blind justice? Your mind I so poisoned you admit it openly. Barr would let him get away with it and wouldn’t reopen it if it implicates Trump. That is a Rubicon statement boys. It’s a cult.
Try to keep up Mach,
https://www.washingtonexaminer.com/news/...stein-case
Attorney General William Barr revealed Monday he recused himself from the Justice Department’s prosecution of alleged child sex trafficker Jeffrey Epstein, who was arrested over the weekend and formally charged that morning.
“I’m recused from that matter because one of the law firms that represented Epstein long ago was a firm that I subsequently joined for a period of time,” Barr told reporters in Southern Carolina.
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