[DELETE], Plaintiffs, v. DONALD J. TRUMP
Posted: Wed Dec 03, 2025 1:48 amCASE NUMBER: 502025CA012282XXXAMB Div: AD
Filing # 236460866 E-Filed 11/24/2025 02:54:51 PM
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
[DELETE],
Individually and on behalf of [DELETE] a minor,
Plaintiffs,
v.
DONALD J. TRUMP, in his individual capacity and official capacity as President of the United
Defendants.
COMPLAINT AND MOTION FOR SUMMARY JUDGMENT
(Incorporating Prior Default Judgments and Epstein Precedent as Res Judicata / Collateral Estoppel)
NOTICE OF INCORPORATION OF PRIOR FINAL JUDGMENTS
(Entitling Plaintiffs to Summary Judgment)
COMPLAINT FOR
1. Human Trafficking (Force / Fraud / Coercion) under Fla. Stat. § 787.06
2. Civil Damages under Fla Stat. §787.061
3. Intellectual Property Theft / Misappropriation of Trade Secrets
4. Conspiracy
5. Intentional Infliction of Emotional Distress
6. Declaratory and Injunctive Relief
JURY TRIAL DEMANDED
I. PARTIES
1. Plaintiff [DELETE]
2. Plaintiff [DELETE]
3. Defendant Donald J. Trump, in his individual and official capacity as before, during, and after being President of the United States in his first presidency, whose relevant acts include direct oversight of federal agencies (including DHS and DOGE), federal contracting decisions, and executive authority over entities that knowingly misappropriated Plaintiff’s intellectual property (SAFE cybersecurity platform, Abrahamic Accords defense architecture, and non-hormonal contraceptive gel) and that failed to prevent or actively participated in the ongoing human trafficking summarized in over 70 nationwide police reports and judicial filings against the traffickers from 8 years of efforts to escape, sexual coercion, and retaliatory child separation against Plaintiffs. 4-8. Defendants Bill Gates, Bill & Melinda Gates Foundation, Elon Musk, James Cook, United States Department of Homeland Security and presidency affiliates associated with terrorism in the prior cases.
II. JURISDICTION AND VENUE
5-6. Unchanged (jurisdiction under Florida trafficking statutes; venue proper in Palm Beach County due to President Trump’s residence at Mar-a-Lago, DHS operations affecting Florida, and injuries felt in this district).
III. FACTUAL ALLEGATIONS (updated to reflect current administration)
7-14. The eight-year trafficking and exploitation venture that began in 2018 has continued and escalated under the current Trump administration (2025-present). Specifically:
• Defendants engaged in coercion, as defined by Florida’s trafficking statute (Fla. Stat. § 787.06), by:
o threatening or using physical force;
o restraining, isolating, or confining Plaintiffs (or threatening to do so) against their will;
o causing or threatening to cause financial harm; and
o enticing or luring Plaintiffs through fraud or deceit. The Florida Senate+2Florida. Public. Law+2
• As part of this exploitation, Defendants required or pressured Plaintiffs to produce creative works, proprietary information, or other intellectual property. Rather than compensating the Plaintiffs fairly, Defendants claimed ownership, distributed, or monetized these works without proper authorization, credit, or payment.
• Defendants benefited financially (and potentially politically) from the Plaintiffs’ labor and IP, making this a trafficking enterprise. Under Florida law, a “venture” includes any group of two or more individuals associated in fact, whether or not a legal entity. Florida. Public. Law+1
• Plaintiffs were deprived of meaningful control over their lives, including their creative output, finances, and future opportunities.
• Plaintiffs tried to resist or disaffiliate but faced retaliation, threats, or further coercion, making escape or withdrawal difficult or impossible.
As a result of the eight-year exploitation, Plaintiffs have suffered significant emotional, psychological, financial, and reputational harm.
• Defendant Elon Musk, acting in concert with the Trump administration via the Department of Government Efficiency (DOGE), has used Plaintiff’s SAFE cybersecurity platform and Abrahamic Accords defense architecture to secure Elon Musk over $580 billion in federal contracts while refusing to compensate Plaintiff or procure her technology via mandatory sole-source FAR provisions.
• The United States Department of Homeland Security, under the direct executive authority of President Trump, has confirmed (November 26, 2024) ongoing trafficking against Plaintiff yet has failed to intervene or halt the venture, instead allowing continued retaliation, child separation, and IP theft tied to federal programs while he oversaw.
• President Trump, through his official acts and appointments (including Musk’s role in DOGE and continued DHS leadership), has knowingly benefited from and permitted the venture to continue, including the use of Plaintiff’s stolen IP in federal defense and health initiatives and the refusal to enforce FAR 6.302 sole-source contracting for SAFE despite admitted prior waste of over $400 million on failed systems. He has been supporting foreign attacks instead of American defense from Hamas, Russia, China, and India through Stargate, the suppression of the FBI, and the suppression of DHS.
• Retaliatory aggravated sexual assaults leading to permanent neck and spinal cord injuries, extreme stalking, judicial interference, false CPS actions leading to false police report arrests, and child withholding (Arizona custody order FC2024-004758 obtained by fraud) have all continued or intensified in 2025 under the current administration’s watch.
• Trump bypassed Congress to send over $30 billion in direct military aid to Israel through suppressing their defense of Israel in 2025 while simultaneously endorsing the “Gaza takeover” plan. This funding facilitated what the United Nations, Amnesty International, and the International Court of Justice have described as genocidal acts against the Palestinian population, including the deliberate destruction of all remaining maternal-health and contraceptive supply chains in Gaza—expressly to eliminate any possible real-world deployment zone for SAFE gel, which would have saved tens of thousands of women and children and exposed Stargate/Gates-funded alternatives as inferior and unnecessary. The Gates Foundation’s simultaneous $2.5 billion “women’s health” pledge in August 2025 was used as the civilian cover for this suppression campaign.
• Terrorism for fear installation including facilitating the Baltimore Bridge attack on the day my daughter was born March 26th using my ex James Cook, a violent rape right before she was born to sabotage the birth as well, and then a russian cyberattack on the airports using my competitors at Microsoft through the Crowdstrike attack, while taking my home from me in DC and trying to force me to fly home to Nebraska during that time where he shortly after had me arrested to prevent me from filing any police reports as confirmed by arresting police investigators of his actors.
• Defendants and their agents have attempted to murder plaintiff [DELETE] no fewer than five (5) separate occasions between 2023 and November 2025, including but not limited to poisoning, vehicular assaults, and orchestrated physical attacks designed to appear accidental. Each attempt coincided with Plaintiff’s efforts to report the trafficking, file police complaints, retain counsel, or prosecute legal actions against the Defendants. Additionally, every single time Plaintiff has sought legal assistance, filed a new lawsuit, contacted law enforcement, or appeared in any court proceeding, Defendants have immediately retaliated with escalated physical assaults, sexual violence, cyber-attacks, arrests, false CPS interventions, or additional murder attempts, creating a clear and ongoing pattern of obstruction of justice and witness intimidation intended to prevent Plaintiff from obtaining legal redress.”
All remaining factual allegations from the prior complaint (paragraphs 7-14 as previously drafted) are incorporated by reference and remain applicable, with the understanding that the trafficking venture is ongoing and now operates with the knowledge, benefit, and non-intervention of the Trump administration during the presidency and during the Biden presidency.
NOTICE OF INCORPORATION OF UNREBUTTED EVIDENCE
(Entitling Plaintiffs to Summary Judgment on Liability)
Plaintiffs hereby incorporate by reference the complete evidentiary records already filed and unrebutted in the two pending superior-court actions in which Defendants (or their privies) were properly served, defaulted, and have never answered:
1. Arizona Superior Court, Maricopa County - Case No. CV2025-033151 55-page Motion for Default Judgment filed October 26, 2025 (with clerk’s entry of default, affidavits of service on the Gates Foundation, and sworn verification).
2. New Jersey Superior Court, Essex County - Docket No. ESX-L-004446-25 82-page Motion for Final Default Judgment filed November 3, 2025 (with clerk’s entry of default October 7, 2025, certified mail receipts to Elon Musk and DHS, and 21-tab evidentiary binder).
Because the Defendants in those actions have never appeared, never answered, and never contested a single fact or document, every allegation and every piece of evidence in those two filings stands unrebutted and admitted for purposes of this Florida action. The identical trafficking venture, identical perpetrators, identical victim, and identical stolen intellectual property (SAFE gel and SAFE cybersecurity platform) are at issue here.
III. FACTUAL ALLEGATIONS ESTABLISHED BY UNREBUTTED EVIDENCE
The following facts are taken verbatim or summarized from the already-filed, sworn, and unrebutted evidence in the Arizona and New Jersey cases:
9. Epstein-Identical Pattern Proven by Unrebutted Evidence The unrebutted evidentiary record in both prior actions proves a trafficking venture identical in every material respect to the Jeffrey Epstein sex-trafficking network:
o Grooming of [DELETE] began in 1998 — the exact year Plaintiff was born and the exact year Epstein’s Little St. James island became fully operational (Arizona filing 1(8.d).
o Use of billionaire “philanthropic” foundations as the primary cover and silencing mechanism (Gates Foundation received SAFE gel trade secrets in confidence in 2022, then announced identical initiatives in 2023-2025) (Arizona filing §§6-7).
o Coordinated sexual assaults using the identical “blitz” choking method documented in Epstein victim depositions (Arizona filing: rape in Phoenix 09/02/2023 and New Jersey 08/09/2025, both using choking to silence victim at the exact moment of IP theft).
o Retaliatory removal of Plaintiff’s infant daughter [DELETE] as punishment for filing lawsuits (identical to Epstein’s use of custody threats against mothers who sued) (Arizona 1(8.d; New Jersey 1(3).
o Theft of victim-created intellectual property disclosed under false promises of funding or protection (exact same SAFE gel provisional patents misappropriated by Gates Foundation and Musk/DOGE) (Arizona §§ 6-7; New Jersey §(2).
10-14. All remaining factual allegations from the prior Florida drafts (Stargate suppression of SAFE gel as the true COVID-era maternal-health solution, Trump’s 2025 stand-down of Russian cyber defenses enabling attacks on SAFE prototypes, $30B+ in U.S. funding for genocidal acts in Gaza to eliminate any real-world deployment zone for SAFE gel, etc.) are further corroborated by the same unrebutted police reports, certified mail receipts, patent records, and sworn affidavits already on file in Arizona Case No. CV2025-033151 and New Jersey Docket No. ESX-L-004446-25.
Because every Defendant (or their privy) has already been served with this identical evidence, has defaulted, and has never filed a single responsive pleading or affidavit contesting any fact, there is no genuine issue of material fact remaining as to liability on any count.
IV. LEGAL BASIS FOR SUMMARY JUDGMENT
Under Florida Rule of Civil Procedure 1.510, summary judgment is proper when the pleadings and evidentiary record “show that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” The unrebutted evidentiary records in Arizona CV2025-033151 and New Jersey ESX-L-004446-25 — incorporated herein — establish every element of every claim against every Defendant and their privies. Defendants have had notice and opportunity to contest these facts in two jurisdictions and have chosen silence.
III. FACTUAL ALLEGATIONS (continued)
Epstein Pattern - Identical Modus Operandi
9. The trafficking venture proven in the Arizona and New Jersey default judgments is directly identical to the Jeffrey Epstein sex-trafficking enterprise that operated from 1998-2019:
o Grooming began in 1998—the same year Plaintiff [DELETE] was born and the same year Epstein’s Little St. James island became operational.
o Use of billionaire “philanthropic” foundations (Gates Foundation, Clinton Foundation, Wexner Foundation) as laundering and silencing mechanisms.
o Coordinated sexual assaults using the same “blitz” choking method documented in both Epstein victim testimonies and Plaintiff’s two 2023/2025 rapes.
o Theft of victim-created intellectual property disclosed under promises of funding (Epstein victims reported similar theft of business plans, inventions, and artistic works).
o Retaliatory removal of children when victims sued (identical to Epstein’s use of custody threats against mothers who spoke out).
10. Because the Arizona and New Jersey courts have already entered final, unappealable judgments finding this identical Epstein-style venture proven against Gates, Musk, Cook, and DHS, no genuine issue of material fact remains for trial in this Court.
10.-14. [All prior factual allegations from the Stargate / Gaza / Russia / China version remain incorporated, now bolstered by the preclusive effect of the two prior final default judgments.
IV. CLAIMS FOR RELIEF
(Counts 1-6 remain identical in substance, with the addition of President Trump as a named defendant jointly and severally liable under each count for his individual and official acts that have perpetuated the trafficking venture, IP theft, and associated harms in 2025.)
V. PRAYER FOR RELIEF
WHEREFORE, Plaintiffs respectfully request that the Court:
1. Award compensatory damages in an amount to be proven at trial (not less than $310,000,000);
2. Award punitive damages;
3. Order restitution and disgorgement of all profits derived from Plaintiffs’ intellectual property by any Defendant, including profits flowing to or through, STARGATE and technological corporation affiliates, DOGE, DHS, the Abrahamic Accords, Tesla, SpaceX, Neuralink, xAl, or the Gates Foundation;
4. Award pre-judgment and post-judgment interest;
5. Award attorney’s fees and costs ($134,784,000);
6. Issue declaratory relief finding all Defendants, including President Trump, jointly and severally liable;
7. Issue permanent injunctive relief, including but not limited to:
o Immediate return of full legal and physical custody of [DELETE] to [DELETE] and voiding of Arizona order FC2024-004758 ab initio;
o Permanent prohibition on all Defendants’ use of SAFE gel, SAFE cybersecurity platform algorithms, Abrahamic Accords defense architecture, or any derivative works;
o Mandatory sole-source federal contract to [DELETE] for SAFE under FAR 6.302- 1 with immediate $10 billion licensing payment for nation security adherence to promises that were made and not kept to the nation
o Transfer of all patents, contracts, and revenue streams derived from Plaintiff’s IP to [DELETE] exclusively; and
8. Grant any other relief the Court deems just and proper, including any necessary orders directed to federal agencies under the President’s control.
VI. EXPEDITED JURY DEMAND
Plaintiffs demand a trial by expedited jury on all claims, by December 20th, so triable, unless the Judge is prepared for summary judgment.
Dated: November 24, 2025
Respectfully submitted,
[DELETE]
***
Filing # 236460866 E-Filed 11/24/2025 02:54:51 PM
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
[DELETE],
Individually and on behalf of [DELETE] a minor,
Plaintiffs,
v.
DONALD J. TRUMP, in his individual capacity and official capacity as President of the United
Defendants.
COMPLAINT AND MOTION FOR SUMMARY JUDGMENT
(Incorporating Prior Default Judgments and Epstein Precedent as Res Judicata / Collateral Estoppel)
NOTICE OF INCORPORATION OF PRIOR FINAL JUDGMENTS
(Entitling Plaintiffs to Summary Judgment)
COMPLAINT FOR
1. Human Trafficking (Force / Fraud / Coercion) under Fla. Stat. § 787.06
2. Civil Damages under Fla Stat. §787.061
3. Intellectual Property Theft / Misappropriation of Trade Secrets
4. Conspiracy
5. Intentional Infliction of Emotional Distress
6. Declaratory and Injunctive Relief
JURY TRIAL DEMANDED
I. PARTIES
1. Plaintiff [DELETE]
2. Plaintiff [DELETE]
3. Defendant Donald J. Trump, in his individual and official capacity as before, during, and after being President of the United States in his first presidency, whose relevant acts include direct oversight of federal agencies (including DHS and DOGE), federal contracting decisions, and executive authority over entities that knowingly misappropriated Plaintiff’s intellectual property (SAFE cybersecurity platform, Abrahamic Accords defense architecture, and non-hormonal contraceptive gel) and that failed to prevent or actively participated in the ongoing human trafficking summarized in over 70 nationwide police reports and judicial filings against the traffickers from 8 years of efforts to escape, sexual coercion, and retaliatory child separation against Plaintiffs. 4-8. Defendants Bill Gates, Bill & Melinda Gates Foundation, Elon Musk, James Cook, United States Department of Homeland Security and presidency affiliates associated with terrorism in the prior cases.
II. JURISDICTION AND VENUE
5-6. Unchanged (jurisdiction under Florida trafficking statutes; venue proper in Palm Beach County due to President Trump’s residence at Mar-a-Lago, DHS operations affecting Florida, and injuries felt in this district).
III. FACTUAL ALLEGATIONS (updated to reflect current administration)
7-14. The eight-year trafficking and exploitation venture that began in 2018 has continued and escalated under the current Trump administration (2025-present). Specifically:
• Defendants engaged in coercion, as defined by Florida’s trafficking statute (Fla. Stat. § 787.06), by:
o threatening or using physical force;
o restraining, isolating, or confining Plaintiffs (or threatening to do so) against their will;
o causing or threatening to cause financial harm; and
o enticing or luring Plaintiffs through fraud or deceit. The Florida Senate+2Florida. Public. Law+2
• As part of this exploitation, Defendants required or pressured Plaintiffs to produce creative works, proprietary information, or other intellectual property. Rather than compensating the Plaintiffs fairly, Defendants claimed ownership, distributed, or monetized these works without proper authorization, credit, or payment.
• Defendants benefited financially (and potentially politically) from the Plaintiffs’ labor and IP, making this a trafficking enterprise. Under Florida law, a “venture” includes any group of two or more individuals associated in fact, whether or not a legal entity. Florida. Public. Law+1
• Plaintiffs were deprived of meaningful control over their lives, including their creative output, finances, and future opportunities.
• Plaintiffs tried to resist or disaffiliate but faced retaliation, threats, or further coercion, making escape or withdrawal difficult or impossible.
As a result of the eight-year exploitation, Plaintiffs have suffered significant emotional, psychological, financial, and reputational harm.
• Defendant Elon Musk, acting in concert with the Trump administration via the Department of Government Efficiency (DOGE), has used Plaintiff’s SAFE cybersecurity platform and Abrahamic Accords defense architecture to secure Elon Musk over $580 billion in federal contracts while refusing to compensate Plaintiff or procure her technology via mandatory sole-source FAR provisions.
• The United States Department of Homeland Security, under the direct executive authority of President Trump, has confirmed (November 26, 2024) ongoing trafficking against Plaintiff yet has failed to intervene or halt the venture, instead allowing continued retaliation, child separation, and IP theft tied to federal programs while he oversaw.
• President Trump, through his official acts and appointments (including Musk’s role in DOGE and continued DHS leadership), has knowingly benefited from and permitted the venture to continue, including the use of Plaintiff’s stolen IP in federal defense and health initiatives and the refusal to enforce FAR 6.302 sole-source contracting for SAFE despite admitted prior waste of over $400 million on failed systems. He has been supporting foreign attacks instead of American defense from Hamas, Russia, China, and India through Stargate, the suppression of the FBI, and the suppression of DHS.
• Retaliatory aggravated sexual assaults leading to permanent neck and spinal cord injuries, extreme stalking, judicial interference, false CPS actions leading to false police report arrests, and child withholding (Arizona custody order FC2024-004758 obtained by fraud) have all continued or intensified in 2025 under the current administration’s watch.
• Trump bypassed Congress to send over $30 billion in direct military aid to Israel through suppressing their defense of Israel in 2025 while simultaneously endorsing the “Gaza takeover” plan. This funding facilitated what the United Nations, Amnesty International, and the International Court of Justice have described as genocidal acts against the Palestinian population, including the deliberate destruction of all remaining maternal-health and contraceptive supply chains in Gaza—expressly to eliminate any possible real-world deployment zone for SAFE gel, which would have saved tens of thousands of women and children and exposed Stargate/Gates-funded alternatives as inferior and unnecessary. The Gates Foundation’s simultaneous $2.5 billion “women’s health” pledge in August 2025 was used as the civilian cover for this suppression campaign.
• Terrorism for fear installation including facilitating the Baltimore Bridge attack on the day my daughter was born March 26th using my ex James Cook, a violent rape right before she was born to sabotage the birth as well, and then a russian cyberattack on the airports using my competitors at Microsoft through the Crowdstrike attack, while taking my home from me in DC and trying to force me to fly home to Nebraska during that time where he shortly after had me arrested to prevent me from filing any police reports as confirmed by arresting police investigators of his actors.
• Defendants and their agents have attempted to murder plaintiff [DELETE] no fewer than five (5) separate occasions between 2023 and November 2025, including but not limited to poisoning, vehicular assaults, and orchestrated physical attacks designed to appear accidental. Each attempt coincided with Plaintiff’s efforts to report the trafficking, file police complaints, retain counsel, or prosecute legal actions against the Defendants. Additionally, every single time Plaintiff has sought legal assistance, filed a new lawsuit, contacted law enforcement, or appeared in any court proceeding, Defendants have immediately retaliated with escalated physical assaults, sexual violence, cyber-attacks, arrests, false CPS interventions, or additional murder attempts, creating a clear and ongoing pattern of obstruction of justice and witness intimidation intended to prevent Plaintiff from obtaining legal redress.”
All remaining factual allegations from the prior complaint (paragraphs 7-14 as previously drafted) are incorporated by reference and remain applicable, with the understanding that the trafficking venture is ongoing and now operates with the knowledge, benefit, and non-intervention of the Trump administration during the presidency and during the Biden presidency.
NOTICE OF INCORPORATION OF UNREBUTTED EVIDENCE
(Entitling Plaintiffs to Summary Judgment on Liability)
Plaintiffs hereby incorporate by reference the complete evidentiary records already filed and unrebutted in the two pending superior-court actions in which Defendants (or their privies) were properly served, defaulted, and have never answered:
1. Arizona Superior Court, Maricopa County - Case No. CV2025-033151 55-page Motion for Default Judgment filed October 26, 2025 (with clerk’s entry of default, affidavits of service on the Gates Foundation, and sworn verification).
2. New Jersey Superior Court, Essex County - Docket No. ESX-L-004446-25 82-page Motion for Final Default Judgment filed November 3, 2025 (with clerk’s entry of default October 7, 2025, certified mail receipts to Elon Musk and DHS, and 21-tab evidentiary binder).
Because the Defendants in those actions have never appeared, never answered, and never contested a single fact or document, every allegation and every piece of evidence in those two filings stands unrebutted and admitted for purposes of this Florida action. The identical trafficking venture, identical perpetrators, identical victim, and identical stolen intellectual property (SAFE gel and SAFE cybersecurity platform) are at issue here.
III. FACTUAL ALLEGATIONS ESTABLISHED BY UNREBUTTED EVIDENCE
The following facts are taken verbatim or summarized from the already-filed, sworn, and unrebutted evidence in the Arizona and New Jersey cases:
9. Epstein-Identical Pattern Proven by Unrebutted Evidence The unrebutted evidentiary record in both prior actions proves a trafficking venture identical in every material respect to the Jeffrey Epstein sex-trafficking network:
o Grooming of [DELETE] began in 1998 — the exact year Plaintiff was born and the exact year Epstein’s Little St. James island became fully operational (Arizona filing 1(8.d).
o Use of billionaire “philanthropic” foundations as the primary cover and silencing mechanism (Gates Foundation received SAFE gel trade secrets in confidence in 2022, then announced identical initiatives in 2023-2025) (Arizona filing §§6-7).
o Coordinated sexual assaults using the identical “blitz” choking method documented in Epstein victim depositions (Arizona filing: rape in Phoenix 09/02/2023 and New Jersey 08/09/2025, both using choking to silence victim at the exact moment of IP theft).
o Retaliatory removal of Plaintiff’s infant daughter [DELETE] as punishment for filing lawsuits (identical to Epstein’s use of custody threats against mothers who sued) (Arizona 1(8.d; New Jersey 1(3).
o Theft of victim-created intellectual property disclosed under false promises of funding or protection (exact same SAFE gel provisional patents misappropriated by Gates Foundation and Musk/DOGE) (Arizona §§ 6-7; New Jersey §(2).
10-14. All remaining factual allegations from the prior Florida drafts (Stargate suppression of SAFE gel as the true COVID-era maternal-health solution, Trump’s 2025 stand-down of Russian cyber defenses enabling attacks on SAFE prototypes, $30B+ in U.S. funding for genocidal acts in Gaza to eliminate any real-world deployment zone for SAFE gel, etc.) are further corroborated by the same unrebutted police reports, certified mail receipts, patent records, and sworn affidavits already on file in Arizona Case No. CV2025-033151 and New Jersey Docket No. ESX-L-004446-25.
Because every Defendant (or their privy) has already been served with this identical evidence, has defaulted, and has never filed a single responsive pleading or affidavit contesting any fact, there is no genuine issue of material fact remaining as to liability on any count.
IV. LEGAL BASIS FOR SUMMARY JUDGMENT
Under Florida Rule of Civil Procedure 1.510, summary judgment is proper when the pleadings and evidentiary record “show that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” The unrebutted evidentiary records in Arizona CV2025-033151 and New Jersey ESX-L-004446-25 — incorporated herein — establish every element of every claim against every Defendant and their privies. Defendants have had notice and opportunity to contest these facts in two jurisdictions and have chosen silence.
III. FACTUAL ALLEGATIONS (continued)
Epstein Pattern - Identical Modus Operandi
9. The trafficking venture proven in the Arizona and New Jersey default judgments is directly identical to the Jeffrey Epstein sex-trafficking enterprise that operated from 1998-2019:
o Grooming began in 1998—the same year Plaintiff [DELETE] was born and the same year Epstein’s Little St. James island became operational.
o Use of billionaire “philanthropic” foundations (Gates Foundation, Clinton Foundation, Wexner Foundation) as laundering and silencing mechanisms.
o Coordinated sexual assaults using the same “blitz” choking method documented in both Epstein victim testimonies and Plaintiff’s two 2023/2025 rapes.
o Theft of victim-created intellectual property disclosed under promises of funding (Epstein victims reported similar theft of business plans, inventions, and artistic works).
o Retaliatory removal of children when victims sued (identical to Epstein’s use of custody threats against mothers who spoke out).
10. Because the Arizona and New Jersey courts have already entered final, unappealable judgments finding this identical Epstein-style venture proven against Gates, Musk, Cook, and DHS, no genuine issue of material fact remains for trial in this Court.
10.-14. [All prior factual allegations from the Stargate / Gaza / Russia / China version remain incorporated, now bolstered by the preclusive effect of the two prior final default judgments.
IV. CLAIMS FOR RELIEF
(Counts 1-6 remain identical in substance, with the addition of President Trump as a named defendant jointly and severally liable under each count for his individual and official acts that have perpetuated the trafficking venture, IP theft, and associated harms in 2025.)
V. PRAYER FOR RELIEF
WHEREFORE, Plaintiffs respectfully request that the Court:
1. Award compensatory damages in an amount to be proven at trial (not less than $310,000,000);
2. Award punitive damages;
3. Order restitution and disgorgement of all profits derived from Plaintiffs’ intellectual property by any Defendant, including profits flowing to or through, STARGATE and technological corporation affiliates, DOGE, DHS, the Abrahamic Accords, Tesla, SpaceX, Neuralink, xAl, or the Gates Foundation;
4. Award pre-judgment and post-judgment interest;
5. Award attorney’s fees and costs ($134,784,000);
6. Issue declaratory relief finding all Defendants, including President Trump, jointly and severally liable;
7. Issue permanent injunctive relief, including but not limited to:
o Immediate return of full legal and physical custody of [DELETE] to [DELETE] and voiding of Arizona order FC2024-004758 ab initio;
o Permanent prohibition on all Defendants’ use of SAFE gel, SAFE cybersecurity platform algorithms, Abrahamic Accords defense architecture, or any derivative works;
o Mandatory sole-source federal contract to [DELETE] for SAFE under FAR 6.302- 1 with immediate $10 billion licensing payment for nation security adherence to promises that were made and not kept to the nation
o Transfer of all patents, contracts, and revenue streams derived from Plaintiff’s IP to [DELETE] exclusively; and
8. Grant any other relief the Court deems just and proper, including any necessary orders directed to federal agencies under the President’s control.
VI. EXPEDITED JURY DEMAND
Plaintiffs demand a trial by expedited jury on all claims, by December 20th, so triable, unless the Judge is prepared for summary judgment.
Dated: November 24, 2025
Respectfully submitted,
[DELETE]
***