Trump Flies Epstein Air, aka the Lolita Express

[admin]

Katie Johnson's full testimony of 2/11/16
Jun 5, 2020

Katie's video description was captured before Trump became President and matches perfectly with what's described by 100's of other underage girls.

Given Epstein’s history of secretly taping famous people taking sexual advantage of young women procured by Epstein, if the allegations in the Katie Johnson complaint are true, Trump has every reason to be concerned that tapes might exist which would prove Johnson’s allegations.

Attorney General (and Trump personal lawyer) Bob Barr made the highly unusual decision to un-recuse himself from the Epstein case and actually take direct control over the case, despite having previously announced he had a conflict of interest.

I would never have guessed that a billionaire could run a sex trafficking ring for decades with numerous people as accomplices and co-conspirators. But Epstein is already a convicted sexual predator and he continued the behavior even after his conviction.

These women who were sexually abused as girls deserve the complete truth. They deserve justice and it appears that Bill Barr and Donald Trump have the motivation to go to unimaginable lengths to prevent that from ever happening.

https://www.gq.com/story/jeffrey-epst...

WARNING: Extremely graphic

Here's Katie's case: Katie Johnson v. Donald J. Trump (5:16-cv-00797)
https://www.courtlistener.com/docket/...



Transcript

[Katie Johnson] I came to this interview of my free will. No, there was nothing promised to me for doing this interview. Yes, everything that I say at this interview will be the truth.

I met Donald Trump at some parties when I was working for Mr. Jeffrey Epstein. There was about three or four times that I had encounters with Donald Trump. I was 13. The first time that I met Donald Trump was at a party at Jeffrey Epstein's mansion. There was an orgy going on, and he was kind of watching off in the distance. And he basically asked if I could come over and give him a hand job. And at first I wasn't very comfortable with it. This was like my first or second party, and I didn't think that that was my responsibility. But my recruiter told me that I needed to do it. So I agreed to. I said -- sorry, this is a little difficult -- but before I gave him a hand job he kind of slapped my hand away and said, "You need to use a glove." And the recruiter ran over and handed me a glove, and said, "No one touches Mr. Trump's penis without a glove." So I needed to use a glove.

I gave him a hand job and then immediately after he had an orgasm, he left. And I didn't see him again at that party.

Jeffrey Epstein is a billionaire friend of Donald Trump's who was responsible for throwing the sex parties. I originally came to New York trying to be a model, and in my travels, I met a girl named Tiffany there who was very interested in me, and she said that's what she did, is that she helped girls, you know, get what they wanted, and she could help me get into modeling, and that she knew a lot of people that were higher-ups, and that it would be no problem. And she said that I would just basically have to come model at a couple of events and meet some people. It would be no sweat.

So of course I went. You know, it sounded like no big deal. And she was recruiting the girls to come to these parties. And, they all looked, I mean most of them were near my age. There were a couple girls that were maybe 14 or 15, but it seemed to me like we were all very young.

So Jeffrey Epstein knew that I was 13 years old. When he interviewed me, he asked me to get down to my bra and panties, and I thought that was weird. But I mean, modeling, maybe it was something about my figure. And he asked that I give him a massage. And then he asked me my age/ I told him, you know, I told him that I was 13. I told him why I was there, and he basically said, "Well, I'm sure that you'll fit pretty nicely here. And then he tried to basically slip himself inside of me. And I pushed him away, because at that point in time I still believed that there were models, and then there were the girls that did that. Like I thought there was a separation. So, I told him that I wasn't interested in that, but he said that I would do.

And as far as Donald Trump, he knew that I was 13. I believe that Tiffany told him. He seemed to take a liking to me, because I was so young, and I was also a virgin. So, I don't know, but it seemed like he wasn't really into having girls that were liked by the other guys. He kind of liked things to be his first, you know, for lack of a better term. But he was the one who wanted to get to a girl before everyone else did.

Donald Trump knew that I was 13, because the first the first night that I was there, Tiffany actually suggested that, and she had a whole bunch of different wigs then. I expressed interest in them, you know. I always told her that I would love to walk around with blue hair, and so I tried some on, and there was a blonde wig that she said that looked great on me. So I wore that wig. And Donald Trump had specifically asked about me, because I reminded him of his daughter. And Tiffany said, "Well, she's 13 as well." So, he knew the first time that he saw me. But he took a liking to me because I looked like his daughter.

The reason I'm coming out now is when it happened originally, I just wanted to forget about the whole incident. And when I saw that he was running for President [in 2016], I felt it was my responsibility to come out and tell our country what kind of man this person is. I don't think that he should even be the dog catcher, let alone running the greatest country in the world.

After I met Tiffany at the bus station, she basically took me to her house, her apartment, and I got ready. I put on a blonde wig, because it seemed fun to pretend to be someone different, and then we went to the party that I was basically interviewing for. And Jeffrey Epstein was the one that was running the party. He had a quick meeting with everyone who was employed there, and he had a private interview with me.

The first time that I met Jeffrey Epstein, he did try to force himself inside of me without getting the go-ahead, or anything, and then it was probably about the third or fourth party when he basically forced, it was another massage, and it wasn't sex, but there was penetration, and I told him that I didn't want that. But he got a little irritated, so there was something about him that I kind of held a lot of resentment towards him.

By the time that happened, I kind of already had started catching on that maybe I wasn't there for modeling, and maybe I was just getting used for things. And I kind of held him responsible.

I did receive money to go to these parties. After every party I was paid by Mr. Epstein. Out of all the girls that were there with me -- most of them were 13, or 14. I think the oldest one might have been just turned 16. I mean, she'd been there for a while.

It was actually -- it was Tiffany who said he liked to watch other people have sex. I mean, he was a germophobe. He doesn't like germs. So rather than partaking, he just watches.

So I informed him that I was a virgin, so I was basically sorry. So it was Tiffany who introduced us.

The second time that I saw Mr. Trump was the same scenario. He was looking on at an orgy. And Tiffany came over to me and said that Donald Trump had requested that I perform oral sex on him. And I'd never done something like that with anybody, so I was a little nervous. So I walked up to him, and he was standing there very proud-like. and I just kind of moved towards that direction, and he kind of slapped me away, and said, "What are you doing? You know you need to put a condom, like I was some dirty filth or something without a condom. Tiffany ran over and handed me a condom, and she was apologizing profusely to Trump, and she said that would never happen again. And she looked at me and scolded me for being kind of like a child, and that anytime you touched Donald Trump's penis, it needed to have a condom on, or glove, you know. And especially when it comes to performing oral sex.

So I apologized, and then I performed oral sex on him. And again, once he was done, he hopped up and that's the last I saw of him at that party. Some of the things that I noticed that were weird with him was that sometimes, before the parties, he would come over, Jeffrey Epstein and himself, would kind of banter back and forth. And Donald Trump was very racist. He said a lot of racist things. Like there were a lot of comments towards Mr. Epstein being Jewish, and comments like, "You Jewish bastard." And there were some words I didn't even understand -- something about the shape of Epstein's penis being directly related to his mole, and I'm not too familiar with the Jewish tradition, but I'm pretty sure that whatever he was saying wasn't very nice.

He also referred to people of Hispanic background, and he called them Spics. That was around the first time that the World Trade Center had gotten the bombing in the 90s, and he was talking about the towelheads, and how it would just be better off if we didn't let them in, or you know, basically get rid of every one, every single one that was already here. And that just made me really uncomfortable; really, really uncomfortable.

He also loved to call black people "Niggers," and Arabic people he called "Sandniggers."

The only time that he tried to give me some money was our last encounter together, where he acted out a rape fantasy. I was forced to give that money back, because Jeffrey Epstein paid us after the party. So he just gave me the money. I don't even know why. He gave it to me maybe to make me feel more cheap, because it was a rape fantasy to him, but I wasn't playing.

So there were those two times, and then there was after. And the next thing that happened was that Tiffany approached me and said he had a fantasy where he walked in on his maids basically making out, and that it was some type of fantasy for him. So at that point, I was like, "I don't want to be involved with anything that has to do with him." But she's like, "There's nothing that you'll have to do, just he's requesting you to be involved." So I felt like I didn't have a choice there. But his fantasy is basically, he's walking in on his two maids. I was the white maid, and there was a Spanish girl named Maria, who was the Hispanic maid. And we were making out, and he walks in, and he gets really angry, and threatens to call immigration on Maria if she doesn't come over and make things right, and give him a blow job. So while she is over there giving him a blow job, I am just supposed to look scared, like, "Oh no," you know, and cleaning up things, and pretending like I'm trying to go back to my job as a maid. And he was so rude to Maria -- I felt so bad for her -- and I guess it just didn't seem like a fantasy. And it's the weirdest fantasy, you know. He was threatening to call immigration on her.

So she wasn't even near going down to give him oral sex before he slapped her away, and said, "You need to put a condom on." And she's trying to say that she is so sorry, and he's like, "I can't even understand what you're saying," and "Speak English'. He made derogatory comments to her, and then he's like, "You know what? You don't know what you're doing. Have her come over and show you how it's done." And he said that I had to go over there or else he was going to call immigration on Maria. I didn't know if it was true or not. And he said that if I didn't show her how to perform oral sex on him, then he was going to call immigration on her, and then get rid of us both.

You know, anything in relation to him getting off, or being satisfied, or happy, had to do with him being in power, extreme power. And it was always intimidating when he was like that. You didn't really know if it was true, or funny. It's like, if you refuse to play along, would he really call immigration on Maria? Would he really get rid of us both? And I didn't even want to know what that meant. You know -- it wasn't a game. We just felt like it wasn't a game.

The one night that I had the blonde wig on, he mentioned that I reminded him of his daughter. And actually, during the maid fantasy, I didn't have a blonde wig on. I was trying to stay away from blond wigs at the time. But he actually requested -- told -- Tiffany that he wanted me to wear it. Like anytime I had it on, and he'd see me, he would say, "Man, you look just like my daughter. And it wasn't like, "Oh, you remind me of my daughter." It was a sick, evil-like, "You remind me of my daughter." It was just this weird pleasure-sick-smile. Like, I don't even want to know what he was thinking about. I could imagine what he was thinking about.

After the parties would end, we were to report to Mr. Epstein, and basically tell him everything that happened, who and what they liked, and what they disliked, and if there were any requests or if there was talk about anything. That's when we told Mr. Epstein everything. And then he paid us, and we went home. And with me, you know, I would normally get taken to the airport to go back home.

The fact that Trump has a chance to be the next President makes me feel disgusting inside. I've always been proud to be an American, and I think we live in a beautiful country. But I just see him ruining everything. He's horrible. What he portrays on the outside isn't even that great, but people don't even know the half of it -- how evil, sick and twisted that man is.

I have a friend that's been my friend ever since the eighth grade. I confided in her, and she knows all about it. She knows everything. I mean, I destroyed everything from that trip. I couldn't risk my dad finding out. And now I think I'm old enough, but at that point, I didn't want to not be his little girl, you know. I didn't want to lose my dad.

Basically, I never kept proof of any of the trips. I never told my parents because, you know, there would be no good outcome of telling my parents. They would have grounded me, and I would have never been allowed out of the house. My father would have come unglued. I did tell a friend, my best friend, and she's still my best friend to this day. She knows everything. She knows it all.

I'm prepared to do whatever it takes to save the country that I believe that we have. I know what he does behind closed doors. And I'm willing to sacrifice my life to get our country back. And they're right about going in some type of positive direction, but this guy's not gonna take us anywhere positive.

You know, as far as my life changing by coming out with this information, I've thought long and hard about whether or not I should do it. And I've gone back and forth. But I think that the American people need to know what kind of man this person is. And if my life changes because of that, then so be it. But the American people need to know what they're dealing with.

If I had the chance to talk to Donald Trump, I would run the other way. I'm scared of him like I've never been scared of anything else in my entire life. I can't explain it to you, but the fear of him even being in the next room makes me have panic attacks.

The last encounter that I had with Donald Trump, Tiffany approached me about a rape scene that we're supposed to play out, and I didn't like the sound of that at all. But Tiffany promised, ensured me, that if I wasn't comfortable with something, we could stop. That she would be right there, and it wouldn't get out of hand; and it was just a fantasy, and it wasn't really gonna happen. Tiffany was always nice to me. I felt I trusted her. And I wouldn't always trust her, or do what she asked me to, but she was there.

And when he came in, he basically tied me to a bed with pantyhose. And they ties were so tight it hurt to even lay there. And I tried to say something, and his response was "Just shut up; shut up bitch." He was being really, really rough, and it just didn't seem like a fantasy. And I started to get scared. And he was basically ripping my clothes off, and I actually got really freaked out, and I told him, "I don't want to do this." I was screaming for Tiffany, and this was scaring her, and he's like, "Oh, you shut up, too." He just turned into this animal. It was a completely different person. It was like everyone in the room was scared of him and it was like I couldn't do anything about it. And he ripped off all my clothes, and he started to basically have sex with me. And I was screaming, because I never had sex before. It was my first time. And Tiffany was yelling at him too. She was saying that I was a virgin, and he told us to "Just shut the fuck up," and basically took my virginity while I was crying and telling him to stop, and just begging for him to stop. And Tiffany didn't know what else to do either. No one was there to help us, or me.

And so, he basically finishes it, and it didn't take that long at all. I mean, it felt like it was like five and a half hours; it seemed like an eternity. I don't even know how long it was, but he was done, and I was crying, and Tiffany was apologizing. She told me that she would never put me in that situation again. But he came over mad, because I was crying. And he said that I should be thankful that someone like Donald Trump took my virginity. Well, he didn't say "took my virginity." He said I should be glad that someone like Donald Trump popped my cherry and not some pimply little 14-year-old. And speaking to Tiffany, I asked, "What if I get pregnant"? I wasn't even talking to him. I didn't want to talk to him. I was talking to Tiffany. And he said, "Well, you'll get an abortion then, bitch." And then he just walked away. And then I told Tiffany that I needed to go home. And I never went back again.

I guess it's for you to decide. You know, I don't have any kids myself because I'm afraid to have kids, because who knows what kind of damage they can get into. But if you have a 13-year-old daughter, would you be okay with the person who's running our country doing that to your little girl? And I just want people to know. I have faith in our society that it will make the right choice.

He seemed to be taking great pleasure, and enjoyed the dominance and control he had over me. And the more I screamed, the more I got scared, the more he was enraged with power. And it was like he was just charged with it. It was scary.

My experience with Donald Trump has made it to where I can't be in a healthy relationship, I can't be in a relationship without without self-sabotaging it. I don't do well. I mean, I've been in a couple of relationships. I mean they're never of interest to me normally, but one man in particular was a wonderful man, and I couldn't even control myself from self-sabotaging. It was like I had to get him out of my life, and I don't even know why. It was like, anytime anyone loves me I don't feel worth it. I don't even know how to explain it. Like I can be friends, I can have acquaintances with guys, but anytime it's someone who expresses anything else besides that, I can't take any pleasure in it. Whether I mean to or not, it's like I hurt their feelings just so they'll never talk to me again. And make sure that it's not ever a possibility.

Donald Trump destroyed my feeling of self-worth, and my self-esteem, when it just bloomed. It hadn't even had a chance to experience anything.

I have only spoken to to one therapist about, this just recently actually. For a long time I just really tried to forget about it. I tried very hard. But I've been to counseling for other things. I went to counseling for the previous relationship that I was sabotaging. And my counselor said, "Something has happened to you, and you need to deal with that." And I was like, "Hmm." He knew that there was something that had happened where I was self-sabotaging, or sabotaging these relationships. But he said that it was my responsibility to deal with it.

Donald Trump has just destroyed my self-esteem. And I feel like it's destroyed part of my life. The only healthy relationship I could have had, I completely demolished it. And I love to choose the dysfunctional ones that I know I can just push away. After what happened with Donald Trump, I can't trust a man ever again. And thinking about it just makes me sick to my stomach. So when something so traumatic happens to someone who's so young, you never ever really get over it.

[admin]

Here’s Everything We Know So Far About the ‘Katie Johnson’ Allegations Against Trump — It’s Serious and MUST Be Dealt With. This gets tricky, but it doesn't sound out of character for Trump OR Epstein.
by Andrew Simpson
Political Flare
July 9, 2024

[x]

My editor says I should put this disclaimer at the end, but I’m going to come right out front with it, just so you know this isn’t clickbait. I have been reporting on Trump since before he was ever president, and nothing that is “alleged” here doesn’t line up with other circumstances he himself has described as having done.

None of this has yet been proven in court.

But the severity of the allegations notwithstanding, Trump is a proud misogynist, and the myriad pictures of him leering at his own teenage daughter as she sat on his lap, later to say that if he weren’t her father, he might be dating her, make everything in this viral story seem like it holds water.

Basically, what we have now is the story of an anonymous accuser who has gone variously by Jane Doe and now Katie Johnson. A post featuring a case filed against Trump in 2016 by an anonymous woman and Jeffrey Epstein, the pedophile who died under mysterious circumstances in prison before he could be forced to testify about who had accompanied him on a plethora of “sex trips” to a private island of his, has been making the rounds since the release of a slew of documents related to the Epstein case were released recently.

The case alleged that she had been held by the men as a “sex slave” in 1994, when she was 13.

It says that she was forced to “perform lesbian sex acts” against her will.

It basically says everything that always came to your mind whenever you thought about Jeffrey Epstein, or Ivanka on Trump’s lap.

Bill Madden
@maddenifico
Y'all know now about Trump's rape of 13-year-old Katie Johnson. This is how people got the details, not only about Trump's rape of Johnson, but about the relationship between 'pedo bros' Trump and Jeffrey Epstein -- and their secret lives as sexual predators and child rapists.

https://www.courtlistener.com/docket/41 ... d-j-trump/

The April 2016 filing — coincidentally right around the time that Trump was being accused of his affairs with Stormy Daniels and Karen McDougal, during the election — was dismissed by a judge on lack of merit. The case was refiled in June, then again in September of that same year.

At the time of the filing, Trump’s then-lawyer, Alan Garten, told Politico that the charges were “categorically untrue,” though the disappearance of Ms. Doe/Johnson certainly raises some doubts. She hasn’t been heard from since she dropped the last case she filed due to death threats.

“It is completely frivolous. It is baseless. It is irresponsible. I won’t even discuss the merits because it gives it credibility that it doesn’t deserve,” said Garten. That ALSO sounds a lot like what his lawyers were saying about Stormy and Karen — that they wouldn’t even dignify it with a response. Trump’s sentencing in the hush money case involving those two is scheduled for September.

Although Epstein died awaiting trial for his 2019 case of sex trafficking, his grooming partner, Ghislaine Maxwell, was convicted and is serving a 20-year sentence.

Among the things released with the Epstein documents recently were a trove of pictures of Trump and Epstein together, both on his plane and on the island, and even at Mar-a-Lago.

See the post here:

True Blue
@AginsMichael
Is raping a 13 year old at Epstein’s NYC mansion considered an “official act”?
Asking for Katie Johnson.
5:14 PM · Jul 8, 2024

Here is her testimony and it’s brutal:

Political World Network
@Sharpcut
BREAKING NEWS: Here is the full 2016 testimony of a girl who claimed she was raped by Donald Trump (with Jeffrey Epstein) when she was 13 years old. It is explicit. Please watch the entire video. If you believe her, please share.
4:00 PM · May 2, 2023

Sarah Kendzior
@sarahkendzior
Trump was accused of raping his ex-wife Ivana as well as a 13-year-old girl. Both cases went to court. People who discussed the cases were threatened. https://theglobeandmail.com/amp/opinion ... ssion=true

In July, 2015, shortly after Mr. Trump declared his candidacy, the Daily Beast attempted to report on court documents stating that Mr. Trump had raped his ex-wife, Ivana. The inquiry into the case prompted a response from Mr. Cohen that mirrors the threat to Ms. Daniels: "I'm warning you, tread very fucking lightly, because what I'm going to do to you is going to be fucking disgusting," Mr. Cohen told the Daily Beast reporter. "You write a story that has Mr. Trump's name in it, with the word 'rape,' and I'm going to mess your life up ... for as long as you're on this frickin' planet ..."

Few media outlets reported on the allegation after that, and the media were similarly timid in reporting other allegations of sexual assault -- most notably, that of a 12-year-old girl who said in a lawsuit that Mr. Trump raped her in 1994 while in the company of billionaire pedophile Jeffrey Epstein, a friend of Mr. Trump's who was an alleged trafficker of underage girls. In her affidavit, the alleged victim claims that Mr. Trump told her to stay silent since he was capable of having her whole family killed, and noted that another victim, a 12-year-old named Maria, had disappeared.

On Nov. 2, 2016 -- a few days before the election -- that accuser and her lawyer, Lisa Bloom, were scheduled to hold a press conference. According to Ms. Bloom, the press conference was abruptly cancelled due to intense threats to their safety, including a bomb threat. Two days later, the accuser dropped her lawsuit.

[admin]

FILED: 2016 APR 26 AM 11:12

https://ia601203.us.archive.org/26/item ... 85.1.0.pdf

Case Number: ED CV16-00797 DMG *(KSX)

Name: KATIE JOHNSON
Address: 6634 DESERT QUEEN AVE.
TWENTYNINE PALMS, CA. 92277
Phone: (760) 401-0192
Fax: NO FAX OR E-MAIL
In Pro Per

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

KATIE JOHNSON,
Plaintiff
v.
DONALD J. TRUMP and JEFFREY E. EPSTEIN,
Defendant(s).

COMPLAINT FOR CLAIM RELIEF DUE TO:
1. SEXUAL ABUSE UNDER THREAT OF HARM
2. CONSPIRACY TO DEPRIVE CIVIL RIGHTS


18 Plaintiff Katie Johnson, for causes of actions against Defendants Donald J. Trump and
19 Jeffrey E. Epstein, alleges as follows:

JURISDICTION

21 1. Jurisdiction is pursuant to the law of Diversity, 28 U.S.C.; 1332, as plaintiff resides in the state
22 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
26 of California because the plaintiff resides in San Bernadino County, State of California.

2 PARTIES

3 3. The Plaintiff, Katie Johnson, resides in the State of California.

4 4. The Defendants, Donald J. Trump and Jeffrey E. Epstein, each reside in the State of
5 New York.

6 FACTUAL ALLEGATIONS

7 5. The Plaintiff, Katie Johnson, alleges that the Defendants, Donald J. Trump and Jeffrey E.
8 Epstein, did willfully and with extreme malice violate her Civil Rights under 18 U.S.c. ; 2241 by
9 sexually and physically abusing Plaintiff Johnson by forcing her to engage in various perverted and
10 depraved sex acts by threatening physical harm to Plaintiff Johnson and also her family.

11 6. The Plaintiff, Katie Johnson, alleges that the Defendants, Donald J. Trump and Jeffrey E.
12 Epstein, also did willfully and with extreme malice violate her Civil Rights under 42 U.S.c. ; 1985 by
13 conspiring to deny Plaintiff Johnson her Civil Rights by making her their sex slave.

14 7. The Plaintiff, Katie Johnson, alleges she was subject to extreme sexual and physical abuse by
15 the Defendants, Donald J. Trump and Jeffrey E. Epstein, including forcible rape during a four
16 month time span covering the months of June-September 1994 when Plaintiff Johnson was still only
17 a minor of age 13.

18 8. The Plaintiff, Katie Johnson, alleges she was enticed by promises of money and a modeling
19 career to attend a series of underage sex parties held at the New York City residence of Defendant
20 Jeffrey E. Epstein and attended by Defendant Donald J. Trump.

21 9. On the first occasion involving the Defendant, Donald J. Trump, the Plaintiff, Katie Johnson,
22 was forced to manually stimulate Defendant Trump with the use of her hand upon Defendant
23 Trump's erect penis until he reached sexual orgasm.

24 10. On the second occasion involving the Defendant, Donald J. Trump, the Plaintiff, Katie
25 Johnson, was forced to orally copulate Defendant Trump by placing her mouth upon Defendant
26 Trump's erect penis until he reached sexual orgasm.

1 11. On the third occasion involving the Defendant, Donald J. Trump, the Plaintiff, Katie Johnson
2 was forced to engage in an unnatural lesbian sex act with her fellow minor and sex slave, Maria Doe
3 age 12, for the sexual enjoyment of Defendant Trump. After this sex act, both minors were forced
4 to orally copulate Defendant Trump by placing their mouths Simultaneously on his erect penis until
5 he achieved sexual orgasm. After zipping up his pants, Defendant Trump physically pushed both
6 minors away while angrily berating them for the "poor" quality of their sexual performance.

7 12. On the fourth and final sexual encounter with the Defendant, Donald J. Trump, the Plaintiff,
8 Katie Johnson, was tied to a bed by Defendant Trump who then proceeded to forcibly rape Plaintiff
9 Johnson. During the course of this savage sexual attack, Plaintiff Johnson loudly pleaded with
10 Defendant Trump to "please wear a condom". Defendant Trump responded by violently striking
11 Plaintiff Johnson in the face with his open hand and screaming that "he would do whatever he
12 wanted" as he refused to wear protection. After achieving sexual orgasm, the Defendant, Donald J.
13 Trump put his suit back on and when the Plaintiff, Katie Johnson, in tears asked Defendant Trump
14 what would happen if he had impregnated her, Defendant Trump grabbed his wallet and threw
15 some money at her and screamed that she should use the money "to get a fucking abortion".

16 13. On the first occasion involving the Defendant, Jeffrey E. Epstein, the Plaintiff, Katie Johnson,
17 was forced to disrobe into her bra and panties and to give a full body massage to Defendant Epstein
18 while he was completely naked. During the massage, Defendant Epstein phYSically forced Plaintiff
19 Johnson to touch his erect penis with her bare hands and to clean up his ejaculated semen after he
20 achieved sexual orgasm.

21 14. On the second occasion involving the Defendant, Jeffrey Epstein, the Plaintiff, Katie Johnson
22 was again forced to disrobe into her bra and panties while giving Defendant Epstein a full body
23 massage while he was completely naked. The Defendant, Donald J. Trump, was also present as he
24 was getting his own massage from another minor, Jane Doe, age 13. Defendant Epstein forced
25 Plaintiff Johnson to touch his erect penis by phYSically placing her bare hands upon his sex organ
26 and again forced Plaintiff Johnson to clean up his ejaculated semen after he achieved sexual orgasm.

1 15. Shortly after this sexual assault by the Defendant, Jeffrey E. Epstein, on the Plaintiff, Katie
2 Johnson, Plaintiff Johnson was still present while the two Defendants were arguing over who would
3 be the one to take Plaintiff Johnson's virginity. The Defendant, Donald J. Trump, was clearly heard
4 referring to Defendant, Jeffrey E. Epstein, as a "Jew Bastard" as he yelled at Defendant Epstein, that
5 clearly, he, Defendant Trump, should be the lucky one to "pop the cherry" of Plaintiff Johnson.

6 16. The third and final sexual assault by the Defendant, Jeffrey E. Epstein, on the Plaintiff, Kati
7 Johnson, took place after Plaintiff Johnson had been brutally and savagely raped by Defendant
8 Trump. While receiving another full body massage from Plaintiff Johnson, while in the nude,
9 Defendant Epstein became so enraged after finding out that Defendant Trump had been the one to
10 take Plaintiff Johnson's virginity, that Defendant Epstein also violently raped Plaintiff Johnson.
11 After forcing Plaintiff Johnson to disrobe into her bra and panties, while receiving a massage from
12 the Plaintiff, Defendant Epstein attempted to enter Plaintiff Johnson's anal cavity with his erect
13 penis while trying to restrain her. Plaintiff Johnson attempted to push Defendant Epstein away, at
14 which time Defendant Epstein attempted to enter Plaintiff Johnson's vagina with his erect penis.
15 This attempt to brutally sodomize and rape Plaintiff Johnson by Defendant Epstein was finally
16 repelled by Plaintiff Johnson but not before Defendant Epstein was able to achieve sexual orgasm.
17 After perversely sodomizing and raping the Plaintiff, Katie Johnson, the Defendant, Jeffrey E.
18 Epstein, attempted to strike her about the head with his closed fists while he angrily screamed at
19 Plaintiff Johnson that he, Defendant Epstein, should have been the one who "took her cherry, not
20 Mr. Trump", before she finally managed to break away from Defendant Epstein.

21 17. The Plaintiff, Katie Johnson, was fully warned on more than one occasion by both
22 Defendants, Donald J. Trump and Jeffrey E. Epstein, that were she ever to reveal any of the details
23 of the sexual and physical abuse that she had suffered as a sex slave for Defendant Trump and
24 Defendant Epstein, that Plaintiff Johnson and her family would be in mortal danger. Plaintiff
25 Johnson was warned that this would mean certain death for herself and Plaintiff Johnson's family
26 unless she remained silent forever on the exact details of the depraved and perverted sexual and
27 physical abuse she had been forced to endure from the Defendants.

1 MATERIAL WITNESSES

2 18. Tiffany Doe, a former trusted employee of the Defendant, Jeffrey E. Epstein, has agreed to
3 provide sworn testimony in this civil case and any other future civil or criminal proceedings, fully
4 verifying the authenticity of the claims of the Plaintiff, Katie Johnson. Witness Tiffany Doe was
5 employed by the Defendant, Jeffrey E. Epstein, for more than 10 years as a party planner for his
6 underage sex parties. Despite being subject to constant terroristic threats by Defendants Epstein
7 and Trump to never reveal the details of these underage sex parties at which scores of teenagers,
8 and pre-teen girls were used as sex slaves by Defendant Epstein and Defendant Trump, witness
9 Tiffany Doe refuses to be silent any longer. She has agreed to fully reveal the extent of the sexual
10 perversion and physical cruelty that she personally witnessed at these parties by Defendants Epstein
11 and Trump.

12 19. Material witness Tiffany Doe fully confirms all of Plaintiff Katie Johnson's allegations of
13 physical and sexual abuse by Defendants Donald J. Trump and Jeffrey E. Epstein. Tiffany Doe was
14 physically present at each of the four occasions of sexual abuse by Defendant Trump upon the
15 person of Plaintiff Johnson, as it was her job to witness all of the sexual escapades of Defendant
16 Epstein's guests at these underage sex parties and later reveal all of the sordid details directly to
17 Defendant Epstein. Defendant Epstein also demanded that Tiffany Doe tell him personally
18 everything she had overheard at these parties explaining to her that "knowledge was king" in the
19 financial world. As a result of these underage sex parties, Defendant Epstein was able to accumulate
20 inside business knowledge that he otherwise would never have been privy to in order to amass his
21 huge personal fortune.

22 20. Material witness Tiffany Doe will testify that she was also present or had direct knowledge
23 of each of the three instances on which Defendant Jeffrey E. Epstein physically and sexually abused
24 the Plaintiff, Katie Johnson. Tiffany Doe will testify to the fact that the Plaintiff, Katie Johnson,
25 was extremely fortunate to have survived all of the physical and sexual horrors inflicted upon her
26 by Defendants Epstein and Trump.

4 21. The Plaintiff, Katie Johnson, asks the court for relief against the Defendants, Donald J.
5 Trump and Jeffrey E. Epstein, in the amount of $100,000,000.00 (One Hundred Million Dollars) as
6 a result of the Defendants aforementioned acts upon which they willfully and maliciously violated
7 the Civil Rights of the Plaintiff as stated in 18 U.S.c. ; 2241 by sexually and physically abusing the
8 then 13 year old Plaintiff Johnson under threat of harm to her and her family, and 42 U.S.c. ; 1985
9 by the Defendants conspiring to deny the Civil Rights of Plaintiff Johnson by making her their sex
10 slave.

13 Dated: April 26, 2016

KATIE JOHNSON

By _______________
Plaintiff Katie Johnson
Appearing In Pro Per

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https://cdn.factcheck.org/UploadedFiles ... awsuit.pdf

Doe v. Trump (2016) (case 1:16-cv-07673-RA, United States District Court Southern District of New York, filed October 3, 2016).

IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

JANE DOE, proceeding under a pseudonym,
Plaintiff,
v.
DONALD J. TRUMP and JEFFREY E. EPSTEIN,
Defendants.

Case No.: 1:16-cv-07673-RA

JURY TRIAL DEMANDED

COMPLAINT FOR RAPE, SEXUAL MISCONDUCT, CRIMINAL SEXUAL ACTS, SEXUAL ABUSE, FORCIBLE TOUCHING, ASSAULT, BATTERY, INTENTIONAL AND RECKLESS INFLICTION OF EMOTIONAL DISTRESS, DURESS, FALSE IMPRISONMENT, AND DEFAMATION.

Plaintiff Jane Doe, proceeding under a pseudonym, brings this action against Donald J. Trump and Jeffrey E. Epstein, and alleges that:

PARTIES

1. Plaintiff is an individual residing in and a citizen of the State of California.

2. Upon information and belief, Defendants Donald J. Trump and Jeffrey E. E0pstein 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.

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 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 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.

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 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.

21. 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

22. 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, is 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.

23. Both Defendants let Plaintiff know that each was a very wealthy, powerful man and indicated that they had the power, ability and means to carry out their threats. Indeed, Defendant Trump stated that Plaintiff shouldn’t ever say anything if she didn’t want to disappear like Maria, a 12-year-old female that was forced to be involved in the third incident with Defendant Trump and that Plaintiff had not seen since that third incident, and that he was capable of having her whole family killed. Exhs. A and B.

24. The duress had prevented Plaintiff from starting litigation before this year. However, as soon as she surfaced, she received threats. More specifically, shortly after her first complaint was filed in California on April 26, 2016, she started receiving threatening phone calls on her cell phone. Exh. A.

25. Defendants are equitably estopped from arguing that any statute of limitations has not been tolled as Defendants wrongfully forced Plaintiff to refrain from timely commencing this action by threats, duress, and other misconduct. Exhs. A and B. Zimmerman v. Poly Prep Country Day School, ___ F.Supp.2d ___ (2012), 2012 WL 3683393; General Stencils, Inc. v. Chippa, 18 N.Y.2d 125, 127 (1966)(“a wrongdoer should not be able to take refuge behind the shield of his own wrongdoing.”).

26. Moreover, this action has been brought before the facts giving rise to the estoppel have ceased to be operational (i.e., while still under threats of physical harm by coming forward and having no reason to believe that the threats have ever been lifted or would ever be lifted) and since Plaintiff has decided to seek redress at this time, Plaintiff seeks an order of protection in favor of Plaintiff and all associated with her so as to protect them from harm and harassment from Defendants and their agents and associates. Exh. A.

DEFAMATION

27. 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 framed to solicit media attention or, perhaps, are simply politically motivated. There is absolutely no merit to these allegations. Period.” The statement provided for publication by Defendant Trump was published by said website and has been republished elsewhere in whole or in part numerous times (and similar statements of an attorney for Defendant Trump were also published, including on September 22, 2016 by Courthouse News Service). The statements provided for publication by Defendant Trump and his agent and that were published by said websites are false as they pertain to Plaintiff.

28. The published statements are libelous on their face, and clearly expose Plaintiff to hatred, contempt, ridicule and obloquy.

29. As a proximate result of the above-described publications, Plaintiff has suffered loss of her reputation, shame, mortification, and injury to her feelings, all to her damage in an amount to be established by proof at trial.

30. The above-described publications were not privileged because they were published by Defendant Trump and his agent with malice, hatred and ill will toward Plaintiff and the desire to injure her.

31. As a direct and proximate result of Defendant Trump’s defamation of Plaintiff, Plaintiff has been subjected to public scorn, hatred, and ridicule and has suffered other injury.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for judgment against Defendants and for the following relief:

A. That judgment be entered against Defendants for special damages, compensatory damages, and punitive damages in an amount which shall be shown to be reasonable and just by the evidence and in excess of Seventy Five Thousand Dollars ($75,000.00), exclusive of interests and costs;

B. That all costs of this action be assessed against Defendants, including all 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.

Dated: September 30, 2016 Respectfully submitted,

By: /s/
Thomas Francis Meagher Of Counsel:
J. Cheney Mason
Law Office of J. Cheney Mason, P.A.
250 Park Avenue South, Suite 200
Winter Park, Florida 32789

Thomas Francis Meagher
SDNY Bar Code TM6707
One Palmer Square
Princeton, New Jersey 08542
Telephone: (609) 558-1500
[email protected]

DECLARATION IN SUPPORT OF PLAINTIFF'S REQUEST FOR PROTECTIVE ORDER

I, Jane Doe, the Plaintiff in this matter proceeding under a pseudonym, state as follows:

1. I am a competent 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 I am competent to testify to them if called upon to do so.

2. I 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, I was 13 years old.

3. More particularly, I traveled by bus to New York City in June 1994 in the hope of starting a modeling career. I went to several modeling agencies but was told that I needed to put together a modeling portfolio before I would be considered. I then went to the Port Authority in New York City to start to make my way back home. 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.

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 I attended. I understood that both Mr. Trump and Mr. Epstein knew that I 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, 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.

6. Immediately following this 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.

7. 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 loud 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 I finally managed to break away from Defendant Epstein.

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 I 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 I shouldn't ever say anything if I 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 I 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, I 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 I surfaced, I received threats. More specifically, shortly after my first complaint was filed in California on April 26, 2016, I started receiving threatening phone calls on a cell phone I 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 I changed phone numbers, the threatening calls have completely stopped.

12. This litigation involves matters that are highly sensitive and of a personal nature, and I believe that identification of me would pose a risk of retaliatory physical harm to me and to others.

13. I have no reason to believe that the Defendants' threats have ever been lifted or will ever be lifted and so I request that the Court issue an order protecting me and my family from harm and harassment by the Defendants.

I declare under penalty of perjury that the foregoing is true and correct.

DATED: June 18, 2016

DECLARATION IN SUPPORT OF PLAINTIFF'S REQUEST FOR PROTECTIVE ORDER

I, Tiffany Doe, a pseudonym, state as follows:

1. I am a competent 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 I am competent to testify to them if called upon to do so.

2. I originally met Jeffrey E. Epstein in New York City in 1990 when I was the age of 22. I attended a series of parties in that same year of 1990 where I was paid to entertain various guests of Mr. Epstein.

3. In the year 1991, I was promoted to the occupation of party planner in which my duties were to get attractive adolescent women to attend these parties.

4. I 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, I 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. I persuaded the Plaintiff to attend a series of parties of Mr. Epstein that took place during the summer of 1994. I 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.

7. It was at these series of parties that I 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. I 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.

9. I 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. I personally witnessed or was made immediately aware of the two occasions where my boss Mr. Epstein attempted to rape and sodomize the Plaintiff. I personally 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. I 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. I 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. I 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, I was personally threatened by Mr. Epstein that I would be killed and my family killed as well if I ever disclosed any of the physical and sexual abuse of minor females that I had personally witnessed by Mr. Epstein or any of his guests.

16. I am coming forward to swear to the truthfulness of the physical and sexual abuse that I 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. I swear to these facts under penalty of perjury even though I fully understand that the life of myself and my family is now in grave danger.

I declare under penalty of perjury that the foregoing is true and correct.

DATED: June 18, 2016

___________________
Tiffany Doe, a pseudonym

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