GOP Presidential Nominee Donald J. Trump and convicted sex offender Jeffrey E. Epstein have been named as defendants in an amended complaint alleging rape, sexual misconduct, criminal sexual acts, sexual abuse, forcible touching, assault, battery, intentional and reckless infliction of emotional distress, duress, false imprisonment and defamation. The suit, filed in the US District Court for the Southern District of New York was filed today by a Jane Doe plaintiff, amending an original complaint withdrawn by the plaintiff two weeks ago in a voluntary dismissal without prejudice.
The refiling of the case comes at a point in the presidential campaign where Trump has announced his intention to use his opponent’s husband’s past sexual indiscretions as a campaign issue. On Saturday, the same day that the blog Law Newz reported the case would be refiled, Trump not only hammered former President Bill Clinton for infidelity, but suggested Democratic nominee, former Secretary of State Hillary Clinton had been unfaithful as well.
The amended complaint appears below:
gov.uscourts.nysd.463432.4.0 by BillSchmalfeldt on Scribd
According to Law Newz:
The original lawsuit claimed Trump raped the then-13-year-old plaintiff in the 1990s. There was also a second anonymous woman, known as “Tiffany Doe.” She said that Epstein had her pickup teenage girls for his parties. One of these girls was Jane, and Tiffany said she witnessed Trump and Epstein rape the plaintiff several times.
The new complaint adds a third woman. She’s known in court documents as “Joan Doe.”
“In the 1994-95 school year, I was told by the plaintiff in Jane Doe v. Trump and Epstein (1:16-cv-04642, SDNY) that the plaintiff was subject to sexual contact by the Defendants at parties in New York City during the summer of 1994,” her declaration states.
The complaint also builds on the lawsuit’s original defamation claim.
According to the blog, Trump’s attorney, Alan Garten, threatened legal action against the plaintiff and the attorney who filed the amended complaint.
“As I have said before, the allegations are categorically untrue and an obvious publicity stunt aimed at smearing my client,” he told LawNewz.com on Saturday. “In the event we are actually served this time, we intend to move for sanctions for this frivolous filing.”
The complaint was actually filed in the court today, Oct. 3. The filing by Princeton, NJ, attorney Thomas Francis Meagher includes declarations by the Jane Doe plaintiff as well as declarations from two alleged witnesses, identified as Tiffany Doe and Joan Doe.
gov.uscourts.nysd.463432.4.1 by BillSchmalfeldt on Scribd
gov.uscourts.nysd.463432.4.2 by BillSchmalfeldt on Scribd
gov.uscourts.nysd.463432.4.3 by BillSchmalfeldt on Scribd
In her declaration, the then-13-year-old Jane Doe alleges:
There I met a woman who introduced herself to me as Tiffany. She told me about the parties and said that, if I would join her at the parties, I would be introduced to people who could get me into the modeling profession. Tiffany also told me I would be paid for attending.
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 I attended. I understood that both Mr. Trump and Mr. Epstein knew that I was 13 years old.
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, I 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.
She alleged that Trump threatened to have her killed if she told anyone about the purported rape.
Defendant Trump threatened me that, were I ever to reveal any of the details of Defendant Trump’s sexual and physical abuse of me, my family and I would be physically harmed if not killed.
Jane Doe also alleges Epstein, a Trump associate, assaulted her as well. According to the London tabloid The Mirror:
Trump’s co-accused, Epstein, who was once a close friend of the Duke of York, pleaded guilty to two [Florida] state charges of soliciting a minor for prostitution and soliciting prostitution. He served 13 months after being sentenced in 2008.
Investigators suspected the former New York financier of abusing 34 underage girls but lawyers failed to charge him or any of his “co-conspirators” and instead offered him a secret plea bargain.
The case’s future is a subject of controversy as there are several hurdles that must be overcome on the path to a verdict against Trump and/or Epstein, according to Law Newz.
For one, the statute of limitations on many of the claims including sexual misconduct, assault and battery has run up. Other than an affidavit by another unidentified woman who claims to have witnessed the encounters, there appears to be no other evidence concerning what happened. This woman does not indicate that she ever went to police. In addition, no other evidence like DNA or taped conversations has surfaced.
The plaintiff in this case has additionally claimed that she was “defamed” after Trump’s attorney said her allegations were “categorically false” following her first lawsuit in California. At this point, the real identity of whoever is behind these lawsuits has yet to surface. It would be hard to prove that an anonymous woman suffered damage to her reputation if no one knows who she is.
Whether or not this complaint bears fruit, if the media should decide to mention the allegations, it would seem to be just another gallon of gas poured on the blazing inferno that is the self-destructing Trump presidential campaign.