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Amended Complaint Filed 9/30/2016 | Diversity Jurisdiction | Assault

Amended Complaint Filed 9/30/2016

Uploaded by LawNewz Related Interests Diversity Jurisdiction Assault Intentional Infliction Of Emotional Distress Rape Damages Rating and Stats 2.0 ( 10 ) Document Actions Share or Embed Document Sharing Options Share on Facebook, opens a new window Share on Twitter, opens a new window Share on LinkedIn Share by email, opens mail client Embed Description: Jane Doe says Trump rape her when she was a teen. View More Jane Doe says Trump rape her when she was a teen. Copyright: © All Rights Reserved Download as PDF, TXT or read online from Scribd Flag for inappropriate content Recommended Documents Documents Similar To Amended Complaint Filed 9/30/2016 The Dworkin Report by The Democratic Coalition by Grant Stern Donald Trump Lawsuit by tom cleary Clinton's Response 9.15.2016 by LawNewz Documents About Diversity Jurisdiction T. O. Bradbury and N. B. Burt v. Frank Dennis, 310 F.2d 73, 10th Cir. (1962) by Scribd Government Docs Randolph H. Guthrie, III v. City of New York, 11th Cir. (2015) by Scribd Government Docs Axel Johnson, Incorporated v. Carroll Carolina Oil Company, Incorporated Linda A. Carroll Charles S. Lanier, Trustee, and Pace Oil Company, Incorporated, 145 F.3d 660, 4th Cir. (1998) by Scribd Government Docs More From LawNewz Fisk v Delta County Joint School District by LawNewz Reality Winner Transcript by LawNewz Xi v Haugen - Second Amended Complaint - 10.31.2017 by LawNewz Recommended Documents Documents Similar To Amended Complaint Filed 9/30/2016 Skip carousel carousel previous carousel next The Dworkin Report by The Democratic Coalition Donald Trump Lawsuit Clinton's Response 9.15.2016 Judge Status Conference Order Jane Doe. V Trump Doe V. Donald Trump Katie Johnson Trump Lawsuit 1997 Jill Harth Lawsuit Tiffany Doe Declaration Doe v. Trump et al refiled complaint 9/30/16 Trump Deposition - Trump University Lawsuit Jane Doe v. Donald J. Trump and Jeffrey E. Epstein Jane Doe Declaration as Filed 2016-04-18 Cheri Jacobus Lawsuit Against Trump and Lewandowski Doe Vs. Trump - Judge's Order Donald Trump & Jeffrey Epstein Rape Lawsuit and Affidavits Donald Trump's Financial Disclosures Leopold and Shapiro vs FBI, IRS for Donald Trump Documents Russia Influence Warning Letter from NSA members Trump Income 50 Military Generals and Officers Denounce Donald Trump State of Arkansas V. Thomas Alfred Taylor Tantaros Complaint Doe v. Trump et al notice of voluntary dismissal 9/16/16 Dcat FBI Vra Memo Dworkin Report Trump Russian Ties - Unabridged - 11/13/2016 Federal Judge Orders RNC Discovery Trump Election Complaint To Intervene - Colorado Electors Lawsuit TargetSmart/William & Mary Florida Poll of Early and Likely Voters DCAT - Stephen Bannon - FBI Complaint Memo FM x Eichen Pop 202 (1) More From LawNewz Skip carousel carousel previous carousel next Fisk v Delta County Joint School District Reality Winner Transcript Xi v Haugen - Second Amended Complaint - 10.31.2017 Harvey Weinstein complaint against Weinstein Co. DEFENDANT PAUL J. MANAFORT, JR.’S MEMORANDUM REGARDING CONDITIONS OF RELEASE Dunlap Complaint Hall v United Airlines - Complaint 2 Memorandum of Law in Support of Motion OReilly v Panter Wheeler Amended Complaint USA v AT&T Poff Indictment David Boies Letter to Law Firm Employees Over Weinstein Spies Debacle Dickinson v Cosby Spencer v Red Lobster Anti SLAPP motion to dismiss Gary Johnson Et Al V Commission on Presidential Debates Opinion Order of Dismissal Bernie Backers Lawsuit Hatch Act Letter 8-24 Evans Cert Petition Final Oakley Complaint Corley v Harris County First Amended Complaint Bolton Arpaio Order Opinion on Sarah Palin lawsuit Stone Motion to Dismiss - rule 12 Mullen Declaration Dalia Dippolito Order Denying Appellate Bond FNC Motion Hughes Complaint Hearing Letter - Charlottesville (FINAL) ">

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Due to the method this docum nslmguxg. US Digital Millennium Copyright Actent is displayed on the page, screen readers may not read the content correctly. For a better experience, please download the original document and view it in the native application on your computer.     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.: 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 IMPRISONME NT, 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 o f the State of California. 2.   Upon information and belief, Defendants Donald J. Trump and Jeffrey E. Epstein each reside in this District and are citizens of the State of New York. JURISDICTIO N AND VENUE 3.   Plaintiff is a citizen of the State of California for purposes of d iversity jurisdiction under 28 U.S.C. § 1332. 4.   Defendants are citizens of the State of Ne w York for purposes of diversity  jurisdiction under 28 U.S.C. § 1332.     2 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 an d reckless infliction of emotional distress, duress, false imprisonment, and threats of death and/or serious bodily injury b y the Defendants that took place at s everal 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, Plaintif f 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     3 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 c ivil remedy for personal injuries because Plaintiff, while a minor, was a victim of violations of 18 U.S.C. §§ 15 91, 2421, 2422(b), and 2423(a) and she suff ered personal injury as a res ult 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 wi tness, was a childhood classmate of Plaintiff who, in the 1994-95 school year, was told by Plaintiff that Plaintiff was subject to sexual contact b y the Defendants at parties i n New York City during the s ummer 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 r isk 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 anon ymity, 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 anon ymously] or Footer Menu About About Scribd Press Our blog Join our team! 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