Case 1:16-cv-07673 Document 1 Filed 09/30/16 Page 1 of 10

IN THE UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF CALIFORNIA AND
THE ENTITIES IN STEVEN VAN SCHOFER
AKA AND HIS MOST HONORABLE LORD
AND FLIGHT NAVIGATE OMNIPOTENT
SUPERNAL IN DEITY-WILLIAM P
WILLIAMSON AKA AND ANTZEE DANCEE
ET AL UN
proceeding under a pseudonym, )
)
Plaintiff, )
v. ) Case No.:
)
DONALD J. TRUMP Jim Mattis; Joe ) JURY TRIAL DEMANDED
Dunsford-County-of Orange Ca- )
Sandra Hutchens- )
)
Defendants.
COMPLAINT FOR GENOCIDE, So by stipulating a n D I V I N E
INTERVENTION In place 24/7/365 25 years ongoing stipulation
audible and visual way-of contending in lawful regard by which
to enter into Court record and so stipulations so compelling an

Exhibit 04a.v.1 Above and Entitled Cartoon Phenomena-The Image

 Case 1:16-cv-07673 Document 1 Filed 09/30/16 Page 10 of 10

Revelation 20:4
I saw thrones on which were seated those
who had been given authority to judge.
The Contorting Like Facial Contours I saw the murders lying as
she too looking for tumult solidarity in they -deputies like she
the way-the wacko heard you saw and so by feeling annoyed
as new developing invoices if you stipulated some who done
reasonable study-when we might had an insight from a nice 300
kt inan 10 year older report -but first the from thence- for me
and if any as a BOOK THAT IF REVELATION IN MY PERSONAL
BETTER EITHER ONLY FOR AN HEAVENLY LIKE
ACCENTUATION- either if we were to highlight IMAGE LIKE
INA BOOK OF PROPHECY W HEN SOMEONE WAS GIVEN
AUTHORITY TO SAYSO BY STIPULATING KNOWING W HO

NEVER LIKED OUR CL

2
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EAR LY AN
D
VISIBLE

E WAY- THE EVEN AS IF TO STIPULATE 24/7/365 LETS

STIPULATE -THE FBI DIARY-S AND KNOW N TO BE RECORDED
ON FILM RECORD OF JANUARY 01 1994 THE LAST THING
ANY W HO STIPULATE THIS COMPLAINT AND CHARGES THE
NUCLEAR MAGICIAN SO TERRIBLE AN ABUSE

Revelation 20:4
I saw thrones on which were seated those
who had been given authority to judge.

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SO BY LONG BREACHING YOU AND THEY-HER THAT-THE COUNTY OF

ORANGE CORONER WHO BY CAREFULLY CALLING HER

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The following is a minimal Miranda warning, as outlined in the Miranda v Arizona case.

1. You have the right to remain silent and refuse to answer questions. Do you
understand?

2. Anything you do say may be used against you in a court of law. Do you understand?

3. You have the right to consult an attorney before speaking to the police and to have
an attorney present during questioning now or in the future. Do you understand?

4. If you cannot afford an attorney, one will be appointed for you before any
questioning if you wish. Do you understand?

5. If you decide to answer questions now without an attorney present you will still have
the right to stop answering at any time until you talk to an attorney. Do you
understand?

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 Case 1:16-cv-07673 Document 1 Filed 09/30/16 Page 10 of 10

6. Knowing and understanding your rights as I have explained them to you, are you
willing to answer my questions without an attorney present?

United States [
Oath:
Do you solemnly (swear/affirm) that you will tell the truth, the whole truth, and nothing but the
truth, (so help you God/under pains and penalties of perjury)?
as to accommodate United States v. Ward, the Ninth Circuit Court of Appeals ruled
Oath (California):
You do solemnly state that the testimony you may give in the case now pending before this
court shall be the truth, the whole truth, and nothing but the truth, so help you God.

Statutory declaration
Affirmation in law
Performativity

On This 16th of April the year 2017 in so saying seeing exacting

contentions in some circles an Image that not only caught the phony

sold to the Devils the murder culprits so genocidal and if I need a gas

mask here at what I have to stipulate - And the most flagrant aiding an

abetment if I saw who by working an program by way of sophisticated

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communication electronic warfare involvement - IF I WE TALKED HIGHER

AND HIGHEST SECURITY CLEARANCES AND IF ANY WHO BY SHARING THE

INPUT IN DATUM THE SOLD OUT ALL THE WAY IN HELL AN IF FIRST

CONSENSUS USMC GENERALS IN SO EVER I SEATED ANY WHO BY

REASONS IF TELECARE-S CORP DETENTION AN LAST THING ANY WHO BY

STIGMATA THE EMPHASIS RATHER THAN_

THE ALPHA BRAVO IN IF YOU SO MUCH SAW WHAT WE TALKED OVER - IN

EVERYBODY IN DENSITY MAGIC ADVANTAGE MONSTERS GOT THEIR

COORDINATES TO MURDER AS MANY BY JOHN MOORELACHS GUNS TO

STIPULATE ANY CONVEYANCE MODULE BY SHOOT DEAD ON SITE ANY

AND EVERY SANDRA HUTCHENS TREACHERY AIDI NG IN HIS THE

ABETMENT- THE NEW PRESIDENTS IN REGARD TO IF AS VALUE MY OWN

LIFE-CAN STIPULATE AND IF EITHER THE CLAP ON EAST SAW ANTZEE LIKE

OUR WORDS AND LIMERICKS ANY WHO BY CHECKING OUT TWO WEEKS IN

A TOPIC_-

IS ANY WHO COULD BE SLEEPING-TOPIC-

SO WHEN I FALL ASLEEP AND IF YOU NEITHER DIES BY AN INCEST

CAULKERS OF EITHER:

THE NIGHTYS OPTIONS-THE BALL IT NEVEDADA IS MAD YA NEITHER:

BLEW OR TOOK WADS IS SO MAD SO BY ELIMINATING A IS MORE YES SIR

SO EACH IN HIS NEVER ENOUGH TO DESCRIBE EITHER_ AN

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DREAMLAND

IF ALL COSMIC LIFE AND MY STIPULATED LIKE DECOY KINDS

IS PREPLANNED PHONY FAMILY AND FRIENDS IN EVERY WAY THEY WHO

BY SAYING THE WORST LUCIPHERIAN LIKE DARK SAUCER CREWS IN

ASSUMED IDENTITIES IF ANY WHO HAD A CALL TO SEAT AN STIPULATION

BEING GIVEN TO STIPULATE IN IN ORDER TO BRING RESULTS ORIENTED

OUTCOME AT THE UNSTABLE AS RICKY SHERIFF DEPUTIES WHO BY

DEFINING THE ENEMY-EITHER WHEN THE STIPULATION BEING GIVEN-

THE MANAGEMENT-GOING DOWNTHE THE ENEMY TOGETHER DER

THECOURT ANDMARSHALLPO SERVICE TO SEIZE CHARTLESSCJIOFERALL

AND ALLTHE I KNOW- THOUGHTS YOU TOO-TTHERE-D EVER BEEN- IF

EITHER AT THE NOT ABLE TO SPEAK TO ME HIS MIND IN ANY SENSE IF

THE DOUBTS OF RECALL FAST IF ANY WHO BY STIPULATING IF ANY WHO

KNOW BETTER THE HOW AND WHY-S ANY WHO GIVEN CHANCE AFTER

CHANCE INHERE AGAIN AT THE 01: OCLOCK AFTERNOON HOUR IF THE

SULPHER OXOUS FERROUS-LIKE GASMASK REMINDERS OF NEVER A

CONCERN TO THESE WHO BY NOT EVEN AS SO MUCH THERE NEED FOR IS

CRITICAL LIFE SUPPORT AN TH ING TO DO WITH STIPULATIONS BEING

MADE EACH NEVER NEEDED EITHER */-------------------------------------

-----------------------------------------------------------------------------

------------------------O9XYGEN ALL TO DOWITH -BREATHABLE OITIN

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SCENT OF RELEASE MAY STEM SOME TO SIDE-NEVER THE STIPULATION

BEING GIVEN IF SHOOT DEAD THAT SOB THINK JUST BLAS OK EITHER

THE INVALUABLE IN TREPIDATION OF SUPERVISE AN

EITHER WHOSE CALLING WHO AN NUCLEAR STRIKE SOB TO OF THE IF

ANY TO SAY AH CRAP AND WE BROUGHT UP DONALD NOT TO BE THE

MOST GRATECONSENSUS- TRUMPKIDDINGINEVERY DINGLESOLITARY

TODESCRIBE AT THE - CONTRO0OL HIS OR CAMPING AT YOUR FUNNY

FARM _GOT A GUN IF THE MONSTER SAW SEE YOUR 34YR-

AND IF WE WERE TO STIPULATE-CLAP ON BACK AS NEW_

AND AFTER THE MOST DISGUSTING THING ABOUT AS MANY CLAP ON AND

CLAP OFF BLOWN SAVES.

SO IF AS MANY AS IF EVER THE WORST WAY-THE ENTITY CAN BE BEAT

DID OR COULD AN ECHO ON THAT YOU SAID YOU CAN CLAP WEST COAST

IN AN ABOUT WAY THAT IS COULD GIVE CREED TO ALWAYS KEEP A

BACKUP CLAP OFF KEY NEARBY CAN THIS OR DAH BE SO IS MY CUP OF

NOODLES SOUPS SANITARY-TO BETOS DID US UP THAT-?

SO BY EITHER FAKING US OUT TO WHOS GOING TO KNOW -

BY DEPENDING ON ME OR THE TWO OF US ANY WAY OR YOUD NOT

EXISTED TOPIC---

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BUT WHAT IS THIS SCENT OF SULPHER DIOXIDE THAT IF EITHER -SANDRA

HUTCHENS CAN NEVER BE TRUSTED.

IS THIS A CASE OF EITHER A PARASITIC CREATURE-SO IF BY CHANCE WE

UP TO THE FINDING SHOULD BERT BE TAKEN OUT FOR FANCYING THE

TRUMP LEAD

IF NOT FOR THE ANTZEE SHIELD BY WHICH EACH AND EVERY IS GRATEFUL

A CONTENTION TO EITHER: IF YOU SEE ME GET ON MY KNEES TOO?

THE AGAIN AFTER AN NIGHT OF TALKED ABOUT DREAMLAND SCAPE AT

WHEN WE AWAKE-WHAT ANY WHO RESEARCH AND NAH MAKING SURE HE

AND OTA DID WE CAN CALL EVERY IS SYLLABLE OF IF EITHER I AM

DEBRIEFED IN THE COMPANY OF ALL WHO BY JUST NEVER ALLOWED ANY

WHO BY KILLING 5 OR 10 OR THIRTY OF MES MY TYPES IN SO FAR AS

ANYWAY IN NOTICING THE WORDS OF KILLING IN THE ACCUSED IT THEY

TOO BEFORE AND ON KNOWING AN IMAGE CAN PRESS CHARGES AT ANY

OLD RESERVATIONS IF NOT ANY AS THING TO DO WITH:

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IN SO THE THREE PARTICULARS IN SUPPOSES AFTER AS MANY TIMES-AS

EVALUATION TREATMENT PERSONNEL IN FACT THE PROGRAMS

DIRECTORS AT EITHER ROYALE ETC AND IS CARE UNITS DESERVING THE

EYE FOR AN RYR

WVER T5HE RIGHJT INHOWMANYTIMES

TILLAROUND

IN AN EXAMOPLEORYNOPSISOF
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HIS FATHER SRIPULATED THE Sonan IN NAMELY - AN TALKING IMAGE AND

IF NONEVERHAS AN AND APROPHET THEABOVE AND BELOWENTITIED

EXHIBITIONS STIPULATING PHOTOGRAPHIC DISPLAYS OF ANY A MATTER

TO EITHER CONTEND FOR

OR BY SIDE MTIFYING THESESAID TO BE COURT ROO M EVIDENCE IN

RULES OF EVIDENCE BING SHARED THE PHOTOGRAPHY BEING WHO BY

COLLECTING ND IF NO NEED TO EITHER QUANTIFY DATUMIN AND RE

APPENDAGE THEANYWHOPRACTIVWLAWBE GIVEN AND OBE STIPULATED

THEY FIRST

OLE I WE WAS IN THE MOODTO SED OTHEDRIVEWAYU A NY AS ALL DO AS

NOTED THE JOHN VOWELL CAME TO TALK KILL US AGAIN -AND IF THEY

FIRST-ANY REASON WE SEE AN IMAGE THAT BY

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ANDON A NO SIT FRONJT Y LING THEY TOO GAVEEAR -EOFLYING POLAIN

CLORTHES

UNDER THEEARLYMORNING HOUR INL EDT KNOWING DREAMLASND

GET A HEAD OF THE STIPULATED CREATURE OF TE LAGOON

THE AREA I OF ANIMAL I KNOW YOU AINT IN BED ASLEEP EAC HAND

EVERY MORE THAN AN HOUR THE WHILE DEATH PERCENTAGE IN AN

HOUR LIVING A POLICE BATTALION TO STIPULATE G TO STIPULATE

REMEMBER THE ALL TOO WELL UNDERSTOOD

SURVIVED AS YOU ALL DID SO THE SAME-AFTERMATH CONFUSED EITHER

BED TO BE GOTTEN BY SURPRISE ATTACKS IN WETTERS ASIDE

How to and by diagnosis

MULTIVARIATE MITOCHONDRIA RETRANSFORMATION SYNDROME IN

COSMIC RE STAGE CHRONIC-

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NOT HAVE SAME KIND IF STIPULATED DEMERITS - MARSHALLS SERVICE-

POLITE I KNOW UNLESS AN ABSENCE OF CIA SEATING ALL THE

NEED IN DISQUALIFIED THEMSELVES BEFORE AS MANY AS DIVINE

INTERVENTION WHAT WHY- AGAIN WITCENTER ANDTAL SOUTH

CORPORATE WORD TO BRING UP EIHER MONTHSAGOS SO SORRY WANT

TO DOTHE SAME-ANYWHO OWNLIFESA NEWS BLACKOUT A NEVER

THINKAONE MANWHOSE STIPLATION BEING <ADE BY THE BULKMAJORITY

FINDING OT HIGHER ANDWITHANTZEE

and overview of the ENTIRE ASSIGNED A

NEED FOR A GOOD SHOT OR GUNNERY RIFLE COMPANY WITH ANY

A SNIPERS SCOPE WITH CALIBRATION OHM INSANDRA
URCHENSNAMERIGHTOIT- M27 IAR WAS THEFORthe specs and
overview of the ENTIRE ASSIGNED A TECHNOLOGY WHO BY
HELPING THE ANATOMICAL SUPERIORITY SO MASSIV E A NUCLEAR
ARSENALS ARE THEY THE THUMP US NOT THE SAME

SO LET ME US GET THIS STRAIGHT

TRUMP INDISGUISE WORD TURD TOOS NAME SO NIT THEY- SANDRA

URCHENSNAMERIGHTOIT- M27 IAR WAS THEFORthe specs and
overview of the ENTIRE ASSIGNED AND NON ASSIGNED CZAR BOMBS
SOVIETS CLASS IN ITS COMPERABLE EVAST AN TARGETED AND NOT
TARGETED MIRVED ICMB SLBM INTERMEDIATE-AND ALL TO DO WITH
MANUEL MEANING ANY EITHER BALLISTIC EITHER LONG SHORT MED

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IN EVERY LYING NEVER HAVE A NEED TO COLLECT THEGREAT SZAR

BOMBS ORDNANCE CONTRAPTION RAIL CANISTERS RAILWAY
BOMBERS FLOTILLA OF SURFACE TO AIR SHIPS THE WHOLE EITHER
WORLDLY AND MATERIAL STIPULATIONS BEING BROUGHT TO THE
TRYING USMC GENERALS EITHER CHIEF OF STAFFS SEC OF DEFENSE
US NAVY OFFICERS I NOTED TOO-

IF ITS A M16 DA RIFLE COMPANY CHAIR AND HISSERETRY-

EMPHASIZE SPACEBASE OT OF MATERIAL TOTAL ESTIMATED nuclear
proliferation and non proliferation treatwork -if I inI do--the did the
damage- I even describe anatomical nuclear built in murder magic
flight aperture if any who understated at you watched us the man at
the type pad-in so reiterating some say the mother of all
BOMBStheCZAR-simple 750megatinne total world estimate -s
nuclearesrimated

Swearing-in Sandra Hutchens The genocide saucer module abu se

worst ones who by Identifying the killer and if no deputy bailiffs and
by20 vidoe posted court room videnceexhibits and in so Sandra
Hutchens an appeared before us-and statement text THEY TO THE
ARE WE A WITNESS STAND-STIPULATING THESE IN FACT- under oath
lying police who by stipulating all the consensus killed by the
billions each and if by now a days never dawned on it a when
omnipotent creator complaint like i did as well in so stipulating my
origins as a persona problem i take umbrage and by objecting at is
tis a phony court ledgers in an call it a superior court in the act of
if sabotage and is foul play the nice bible model when the
omnipotent and stipulated everyones all the way leaves omitted the
omnipotent creator who by seeing the mass murder every living
thing in creation caper- the double side to shit a Stanley f over and
in fact the team they call them selves and as i we were redressing
the if i talked mental this or ci fi escape that if never would i had

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let you live as a result of me and my example-by information to-kill

is the word to neither make no mistake about here -the
recommendation sin summary execution to serve they these as noted
traitors in treason as charged and 33 counts each county detention
who by see ing we at ch the he too in the act- to predicated a hit at
my defense to stipulate after a few days in to his the ot care to
discuss and if i saw you did stipulate the man you hear is united
states of America presidents if not for the omnipotent creator who
had been working a December 10 1989 insight fallacy and by good
stipulated involved Steven Van S chofer-and in so seeing the quote-
of the never allow and in so saying - the man named Donald Trump
in leading a big shot caller double side as a nuclear arsenal -

weapons program in loins his heart liver -if you thought researched
or heard a 700 mega tonne was huge the killed every magician and
citizen as many as 1000 times a minute or less each his their said to
be the same an cosmic and double side to as talked an ho ur-one
month and three weeks an like every day annihilated so terribly the
want to be bad about this in cahoots with he - if not for the safety
screens of Antzee and the inter dimensional at mospheric
firmaments-i saw the Telecare corp and every could care l ess as and
in on it no such thing as real court -and so by catching they in the
act and if to classify a retard they can and done lied to kill us and
all every living thing in asking me if we a need to miraculously
vacuum the trump and others too the same as he

so by as upset as anything you never want to imagine so when as

just did 14 minutes gone- as nice to see-the omnipotent creator did
bid or check what saw our hands do what in the past was never
appreciated and by still all the way his th eirs the hate the lying
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megalomaniacs of all intending mass kills each and every lying

syllable of they kill a million or billion extra-terrestrial beings and
the whole planets and kill in so evil a way -rectal insemination
assault and wee in cahoots with the trump playing on everyones sin
or demerits by assisting the devil like leader the queer and sodomic
assaulting rapists got me thinking only burn that wicked leader and
deputies and all that by seeing an invisible safety screen -they still
and still out killing in the billions daily times how many billion
pretend to be people-any numerical if did we stipulate quantum the
end if they right here or disposition to think these kill and talk do
me us away has no place for seditious actions i fi ever criminals
like that- want to be nice to they he se tele cater west court
superior collaborative-courts a need for boomerang end they cut us
down in telecare tao south and wit center the worse all the way for
sty-they all the way-

neither will i rest easy until they-are burning like he though he can
withstand-and in so stipulating unless otherwise stipulate if not the
obvious murder problem any who despond at us as if to need her
they dead as any who transform into a kill is all they like she about -
oa doornail in stipulating an like i like dead any who to get it in the
b-and kills they-still laughing a fight the need

the up sandra hutchens if ears the worst knowing the needy and
deserving enough to either leave a better impression never sho uld
who do too her dead is all i know-each day like sandra hutchens
say-a need for thermal heat-ac killers in either detention bring -
mental teams guts to intention-

so they need to be killed- straight up-- la tumult they predicated at

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us-in the act- the only way to get they- they to burn in nin their
own tumult so all the way-each and every-tried another trick to kill
m-and in saying getting shot at she telling they to ends - us when in
fact the top of tomahawk going to any who by so stating the need
to clip their wings and their dick is stated and stipulation n being
made-how can any who began this event by stipulating omnipotent
is never to be mistreated or if ever i see even kathy teirney one
minute she supposedly a stipulation being made in obs erving the
fumigator dunder triers outright - so either by being an lone only
like mankind specimen a decoy-who being by being as any who else
could and if the atmosphere was annihilated so terribly only to see
an heaven scape where the thought to be nucle ar composite
presidents after as many blown atmospheric firmament - when the
hated us in as disappointing a let down the obvious and as evil
intend to me by knowing she emulsifies and got dicks as if you saw
she no longer a she but a he an alloy monsters an d by neither ever
wanting to get her or the others back on track ---in any epitome of
what never to all the way a f over to our life and lives we brought
forward only to see they her corrupt all to metamorphosis

and with ugly disgusting worlds if rect al inseminating quantum

detestable stinking-est killing bio microbes to shorten any like my
german like also preplanned screw-over decoy brother-s and by
observing our every intention to neither emulsify the end of either
the first to went was the cosmos by poor trusting nice being or
polite person being over powered by the one -who by understood
the big big bang theory where we live and learn and share with
stipulated benevolence its just too much to think and when talked
and in either any that when test r esearch and neither disturb the
stipulated cemeterys of life can stipulate -

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if anyone who by stipulating if not even a one college or associate

or fellow girlfriends or foreign or domestic in consular or
diplomatic envision-ment if any reason to suggest emerge safe far
and free away from un intention al or deliberate acts satanic like all
the while supplication could get caught could get the better might
want to behave even all the more-if the divine intervention might
think what in thejoy to the world-in fact your kinds should had
been three times better at this then all due regard we here at by
objecting objection- if it was a la leche deal if neither not enough
to go around. but herein the recent attempting to resituate in try
this and try that and some composition and psaltery and abit of
chemistries and an omnipotent creator -with audio visuals set in and
if by some reason a program and if me and my topic rather get a wit
new school reminders that if you or one cant be at one with any a
lesson learned anyone who by saying if or is something going on -in
any who by working this sad to say -like an art

or an machines in your distant or if a neither not too far away

reaches in so by wows while if others having a sense of is either an
product-and or a services?

and so by in surprising enough not to go down on the what have you us -

like hers-

whether you right from quarter panel need a newsy -overwhelming

consensus the body repair estimate-s of life-

and a surprise presents of omnipotent ion and of computer minded

innuendo could get
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a bit in morning yesterdays but as any whose father had by having

they identities hijacked from the get go - cause dad carried her to
your place at attention to my fo r the children worst case-contribute
to that-

under supervision your energy were noted were non proliferations

setbacks in treatys the dilemma was technical means for stipulated
verifications negotiate disputes without shots fired celestial
diplomacy was the one-to

consular or national security enthusiast -

the kind up front enough

can across you mean to stipulate t up and outright - as if the actual

of way cold had been conceivably in the face to instigate the fill
where with al lof her their endeavor mentee were the all the way
my direct brother sandra hutchens live and grow and give would
have been the is stipulating the if neither charles or deputies had
been snapped never trust they-so by insisting an up the a need you
had better pay us back or ie-of in dimensionalitys ways of either
accorded ways of rectally raped or attacked the whole planet
emulsified and the need not talk too much more

now im going to have stipulate kill these living things r do these

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types if by understanding our platform in the same situation as like

the same as a surreal assimilations of thought to be doing ok
civilization only to be under regular like tenor wise thin imaginable
the the-s and the rectal inseminating f only to an devil even as
type be mis diagnosing and why-

pretty as not many as billion stop for the us to us and wit telecare in
so knowing why the ran to ours in such a way that -

if the last thing they needed to s

careless we gave the then so sa hand-of precipitous of neptune

sovieltly glasnost minded here a why is it or why were we lead to
believe or was the all magician like stalking gins over here a devil
delta lucipherian believe on love

on set free is for they the predications of the usual thought id one
miracle deliver miracles that imagine

capability- retard and kill-and prophet of the jesus like event -

monitoring the a new mental health program an so by insinuating
opportunity knocks program-or me and omnipotent-- as we die-
never to god damn take for granted

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more so called stipulation

the live their live sea can did everyone in court can intellectual entity
back in the talking image for as much to do with tumult better or
everyone-recidivist try is not even enough to sheriff coroner-sandra
hutchens the presidents donald trump and here the do all they can
looking for a weakness the stipulation being made -is the long devil like
practice she kills a billion or more unprovoked innocent civilizations and
my stipulated brothers in inter-dimensional so serious a genocide capital
crime- i say it is though-

that if i this not enough to stipulate billions a rectal insemination

assault she really being an invisible like nuclear oneness that if the
scent of nuclear oxide and in any sense and if you like the others
had killed also like stipulation being phony family and p hony
friends in so when all hope seem -ed lost- the contention-s being
any reasonable person if given a vision by god almighty who even of
not the case but is the reason why i who by 26 years an sworn in
officer when all who lied had no knowledge of coming of the lord
was never liked by these who by either a double side and having
their identities assumed in as terrible an exploitation of the
situations the thought of as innocent women kind in being either
taken advantage so terribly evil if some peoples id eas of stipulated
love or survive or reproach are much to difficult to stipulated

the mention of how the unity of murder magic in now a days the
nuclear arsenals so huge in mr trumps diaphragm for example had
not antzee and stipulated steven here in not wanted the subject
each and every lying the omnipotent creator neither exists in so all

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the way better killing us the two father and son in the need to
absolve the trump administration along with sandra hutchens a da
as well by stipulating the trump president in knowing the difference
between nuking and sodomizing and so detestable a double side so
gigantic a monster like creature the others by saying he did they
and us up first though and by resting an stipulation being tip of the
iceberg your going toto need to either educate the others by
stipulating a penalty assessment in stipulation a more fuller
contribution to the either higher courts and even thought of any

who by sharing research or in any ones being tested whether it be

points of reference as some could say unless this open forum and
higher and is any who stipulate they froze -and not wanting all to do
they self in by the way so stipulation as we were saying the new
president will be mitch mcconnell by lawful and if some who by
stipulating competent means neither aggravate mayhem -looting or
tumult if i we the personal opinions of reasonable and verifiably
resolute castration procedures is hereby ordered - and by stipulating
the not allowed neither teach nor laugh it good to attempte d to kill
us each every murdered too much can never either public defend
and what the omnipotent creator who by seeing the need to kill the
firing squad is more the need in as i noted shoot dead on site if by
easing up in an effort to accompany this text u pgrade with vocal
audio meaningful tenor in that will be between the administrative
need to either reimburse our is this an 30 million dollar an hour job
to my own better it be than an phony diagnosis to sinned so terribly
again at just that need for as many as 30 million dollar paid to the
order of the entities and esq..that of steven van schofer arroyo in
the matters as many to demand and if not only my our its safety
oriented personification of due patriotic -this and in accordance to
these pre plea terms an federal and his own repercussions in if
nuclear anatomical so superior than any who suppose balk in neither

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an effort to get either back on track -stay aligned and if the subject
to either stipulate any who could neither value their life but could
did too though- so in violation are we going to stipulate -

AND EVERY SYLLABLE OFLYING MAGE CAN SPEAK cartoon like

p h e n o m e n a - a l o n g w i t h t o meaning a double side to ive their lives-in
areas of so terribly sensitive the matter in its own Honor for Omnipotent
Creators Complaint-s to
2
suggest; MISSING COLONIES STARS, PLANETS,
REAL
3 WOMEN/CHILDREN/PEOPLE/ BINARY AND CREATIONS BEING EMULSIFIED
UNTIL CONTENTS OF NOT AT LIBERTY THE CAUSES HERETO.
4

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. Epstein

each reside in this District and are citizens of the State of New York.

24
 Case 1:16-cv-07673 Document 1 Filed 09/30/16 Page 10 of 10

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

25
 Case 1:16-cv-07673 Document 1 Filed 09/30/16 Page 10 of 10

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 publics 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-

26
 Case 1:16-cv-07673 Document 1 Filed 09/30/16 Page 10 of 10

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 Plaintiffs 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 Plaintiffs 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,

27
 Case 1:16-cv-07673 Document 1 Filed 09/30/16 Page 10 of 10

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 Plaintiffs 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
28
 Case 1:16-cv-07673 Document 1 Filed 09/30/16 Page 10 of 10

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

29
 Case 1:16-cv-07673 Document 1 Filed 09/30/16 Page 10 of 10

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 Plaintiffs 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 shouldnt ever say anything if she didnt 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

30
 Case 1:16-cv-07673 Document 1 Filed 09/30/16 Page 10 of 10

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 Plaintiffs 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
 Case 1:16-cv-07673 Document 1 Filed 09/30/16 Page 10 of 10

31. As a direct and proximate result of Defendant Trumps 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

attorneys 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,

/s/ Thomas Francis Meagher

Of Counsel: Thomas Francis Meagher
J. Cheney Mason SDNY Bar Code TM6707
Law Office of J. Cheney Mason, P.A. One Palmer Square
250 Park Avenue South, Suite 200 Princeton, New Jersey 08542
32
 Case 1:16-cv-07673 Document 1 Filed 09/30/16 Page 10 of 10

Winter Park, Florida 32789 Telephone: (609) 558-1500

tmeagher@thomasfmeagheresq.com

33
JS 44C/SDNY Case 1:16-cv-07673 Document1-1s H Filed 09/30/16 Page 1 of 2
REV. 2/2016
The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of
pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial
Conference of the United States in September 1974, is required for use of the Clerk of Court for the purpose of initiating the civil
docket sheet.

PLAINTIFFS DEFENDANTS
Jane Doe, proceeding under a Donald J. Trump and Jeffrey E. Epstein
pseudonym

ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER ATTORNEYS (IF KNOWN)
Thomas Francis Meagher, Esq.
One Palmer Square
Princeton, NJ 08542
609-558-1500
CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE)
(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)

28 U.S.C. 1332, 1391: RAPE, SEXUAL MISCONDUCT, CRIMINAL SEXUAL ACTS,

SEXUAL ABUSE, FORCIBLE TOUCHING, ASSAUL'
SDNY at any time? NoZYesQudge Previously Assigned
Has this action, case, or proceeding, or one essentially the same been previously filed in
If yes, was this case Vol.Q Invol. Q Dismissed. No Q Yes Q If yes, give date & Case No.

IS THIS AN INTERNATIONAL ARBITRATION CASE? No 0 Yes

(PLACE AN [x] IN ONE BOX ONLY) NATURE OF SUIT

TORTS ACTIONS UNDER
STATUTES

CONTRACT PERSONAL INJURY PERSONAL INJURY FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

[ ] 367 HEALTHCARE/ [ ] 375 FALSE CLAIMS [ ]
[ ] 110 INSURANCE [ ] 310 AIRPLANE PHARMACEUTICAL PERSONAL [ ] 625 DRUG RELATED [ ] 4 2 2 APPEAL 376 QUI TAM [ ]400
[ ] 120 MARINE [ ] 315 AIRPLANE PRODUCT INJURY/PRODUCT LIABILITY SEIZURE OF PROPERTY 28 USC 158
STATE
[ ] 130 MILLER ACT LIABILITY [ ] 365 PERSONAL INJURY 21 USC 881 [ ] 423 WITHDRAWAL
[ ] 140 NEGOTIABLE M 320 ASSAULT, LIBEL & PRODUCT LIABILITY 28 USC 157 REAPPORTIONMENT [ ]
INSTRUMENT SLANDER [ ] 690 OTHER [ ] 690 OTHER 410 ANTITRUST [ ] 430 BANKS &
[ ] 368 ASBESTOS PERSONAL
[ ] 150 RECOVERY OF [ ] 3 3 0 FEDERAL INJURY PRODUCT BANKING [ ] 450 COMMERCE [ ]
OVERPAYMENT & EMPLOYERS' LIABILITY PROPERTY RIGHTS 460 DEPORTATION [ ] 470
RACKETEER INFLUENCED &
ENFORCEMENT LIABILITY
CORRUPT ORGANIZATION ACT
OF JUDGMENT [ ] 340 MARINE PERSONAL PROPERTY [ ] 820 COPYRIGHTS
(RICO)
[ ] 151 MEDICARE ACT [ ] 345 MARINE PRODUCT [ ] 830 PATENT [ ] 480 CONSUMER CREDIT [ ] 490
[ ] 152 RECOVERY OF LIABILITY [ ] 3 7 0 OTHER FRAUD [ ] 840 TRADEMARK CABLE/SATELLITE TV
DEFAULTED [ ] 350 MOTOR VEHICLE [ ] 371 TRUTH IN LENDING
STUDENT LOANS [ ] 355 MOTOR VEHICLE [ ] 850 SECURITIES/
(EXCL VETERANS) PRODUCT LIABILITY SOCIAL SECURITY
COMMODITIES/
[ ] 153 RECOVERY OF [ ] 360 OTHER PERSONAL EXCHANGE
OVERPAYMENT INJURY [ ] 380 OTHER PERSONAL LABOR [ ] 861 HIA (1395ff)
OF VETERAN'S [ ] 362 PERSONAL INJURY - PROPERTY DAMAGE [ ] 862 BLACK LUNG (923)
BENEFITS MED MALPRACTICE [ ] 385 PROPERTY DAMAGE [ ] 710 FAIR LABOR [ ] 863 DIWC/DIWW (405(g))
[ ] 160 STOCKHOLDERS PRODUCT LIABILITY STANDARDS ACT [ ] 864 SSID TITLE XVI
SUITS [ ] 720 LABOR/MGMT [ ] 865 RSI (405(g))
[ ] 190 OTHER PRISONER PETITIONS RELATIONS [ ] 890 OTHER STATUTORY
CONTRACT [ ] 463 ALIEN DETAINEE [ ] 740 RAILWAY LABOR ACT ACTIONS
[ ] 195 CONTRACT [ ] 510 MOTIONS TO [ ] 751 FAMILY MEDICAL FEDERAL TAX SUITS [ ] 891 AGRICULTURAL ACTS
PRODUCT ACTIONS UNDER STATUTES VACATE SENTENCE LEAVE ACT (FMLA)
LIABILITY 28 USC 2255 [ ] 870 TAXES (U.S. Plaintiff or
[ ] 196 FRANCHISE CIVIL RIGHTS [ ] 530 HABEAS CORPUS [ ] 790 OTHER LABOR Defendant) [ ] 893 ENVIRONMENTAL
[ ] 535 DEATH PENALTY LITIGATION [ ] 871 IRS-THIRD PARTY MATTERS
[ ] 440 OTHER CIVIL RIGHTS [ ] 540 MANDAMUS & OTHER [ ] 791 EMPL RET INC 26 USC 7609 [ ] 895 FREEDOM OF
(Non-Prisoner) SECURITY ACT (ERISA) INFORMATION ACT [
REAL PROPERTY ] 896 ARBITRATION [ ] 899
[ ] 441 VOTING IMMIGRATION
ADMINISTRATIVE
[ ] 210 LAND [ ] 442 EMPLOYMENT PRISONER CIVIL RIGHTS
CONDEMNATION [ ] 443 HOUSING/ [ ] 462 NATURALIZATION PROCEDURE ACT/REVIEW OR
[ ] 220 FORECLOSURE ACCOMMODATIONS [ ] 550 CIVIL RIGHTS APPLICATION APPEAL OF AGENCY DECISION
[ ] 950 CONSTITUTIONALITY OF
[ ] 230 RENT LEASE & [ ] 445 AMERICANS WITH [ ] 555 PRISON CONDITION [ ] 465 OTHER IMMIGRATION
STATE STATUTES
EJECTMENT DISABILITIES - [ ] 560 CIVIL DETAINEE ACTIONS
[ ] 240 TORTS TO LAND EMPLOYMENT CONDITIONS OF CONFINEMENT
[ ] 245 TORT PRODUCT [ ] 446 AMERICANS WITH
LIABILITY DISABILITIES -OTHER
[ ] 290 ALL OTHER [ ] 448 EDUCATION
REAL PROPERTY

Check if demanded in complaint:

I CHECK IF THIS IS A CLASS ACTION DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y.?
___ | UNDER F.R.C.P. 23 IF SO, STATE:

DEMAND $ ______________ OTHER _____ JUDGE _________________________________ DOCKET NUMBER _________________

Check YES only if demanded in complaint

JURY DEMAND: H YES CNO NOTE: You must also submit at the time of filing the Statement of Relatedness form (Form IH-32).
 (PLACE AN x IN ONE BOX ONLY) ORIGI
0 1 Original N
| | 4 Reinstated or | | 5 Transferred from 1 1 6 Multidistrict
Proceeding D 2 Removed from Reopened (Specify District) Litigation
D
State Court 3 Remanded from
Appellate
| | a.Case 1:16-cv-07673Court
all parties represented Document 1-2 Filed 09/30/16 Page 1 of 2 I I 7 Appeal to District
| | b. At least one Judge from Magistrate Judge
party is pro se. Judgment
(PLACE AN x IN ONE BOX ONLY) BASIS OF JURISDICTION
1 U.S. PLAINTIFF 2 U.S. DEFENDANT 3 FEDERAL QUESTION [x]4 DIVERSITY
(U.S. NOT A PARTY)
IF DIVERSITY, INDICATE
CITIZENSHIP BELOW.

CITIZENSHIP OF
PRINCIPAL PARTIES PTF [ DEF PTF DEF [ ] 3 [ PTF [ ] DEF [
(FOR DIVERSITY CASES ]1 M1 ]3
INCORPORATED and PRINCIPAL PLACE OF
5 ]5
CITIZEN OR SUBJECT OF A
FOREIGN COUNTRY BUSINESS IN ANOTHER STATE
CITIZEN OF ANOTHER STATE M2 []2 INCORPORATED or PRINCIPAL PLACE []4[]4 FOREIGN NATION []6 []6
ONLY) OF BUSINESS IN THIS STATE

(Place an [X] in one

box for Plaintiff and one box for Defendant)
CITIZEN OF THIS STATE
PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)

California (Plaintiff may be reached through her attorney)

DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)

Donald J. Trump: 725 5th Ave., New York, New York; New York County Jeffrey E. Epstein: 9 E. 71st

St., New York, New York; New York County

DEFENDANT(S) ADDRESS UNKNOWN

REPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN THE
RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:

Check one: THIS ACTION SHOULD BE ASSIGNED TO: WHITE PLAINS [x] MANHATTAN
(DO NOT check either box if this a PRISONER PETITION/PRISONER CIVIL RIGHTS COMPLAINT.)
DATE
SIGNATURE OF ATTORNEY OF RECORD ADMITTED TO PRACTICE IN THIS DISTRICT
[ ] NO
[X YES (DATE ADMITTED Mo.0ctober Yr. tbOO ) Attorney
RECEIPT #
/s/Thomas Francis Meagher Bar Code #
Magistrate Judge is to be designated by the Clerk of the Court.

Magistrate Judge _______________________________________________________________________is so Designated.

Ruby J. Krajick, Clerk of Court by__________________ Deputy Clerk, DATED ____________________________.

UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)

Clear Form Save Print

Page 1
 Case 1:16-cv-07673 Document 1-1 Filed 09/30/16 Page 2 of 2
IH-32 Rev: 2014-1

United States District Court

for the
Southern District of New York
Related Case Statement
Full Caption of Later Filed Case:

JANE DOE, proceeding under a

pseudonym,

Plaintiff Case Number

No. 1:16-CV-7673
vs.
DONALD J. TRUMP and
JEFFREY E. EPSTEIN

Defendant
Full Caption of Earlier Filed Case:

(including in bankruptcy appeals the relevant adversary proceeding) JANE DOE, proceeding under a
pseudonym,

Plaintiff Case Number

No. 16-CV-4642 (RA)

vs.

D
JEFFREY E. EPSTEIN

Defendant
 Case 1:16-cv-07673 Document 1-2 Filed 09/30/16 Page 2 of 2
IH-32 Rev: 2014-1

Status of Earlier Filed Case:

(If so, set forth the procedure which resulted in closure, e.g., voluntary Closed dismissal,
settlement, court decision. Also, state whether there is an appeal pending.)

Open (If so, set forth procedural status and summarize any court rulings.)

The plaintiff in the earlier filed case filed a Notice of Voluntary Dismissal pursuant to F.R.C.P. 41 (a)(1)(A)(i) of the Federal
Rules of Civil Procedure, without prejudice to refiling the complaint.

Explain in detail the reasons for your position that the newly filed case is related to the earlier filed case.

Both actions concern the identical parties, property, transactions and events; and there is
complete, identical factual overlap.

Date: 9/30/16
/s/ Thomas Francis Meagher
Signature:_____________________________________ ____
Thomas Francis Meagher, Esq.
Firm:

Page 2
 Case 1:38-cv-04642 Document 1-1 Filed 00/20/16 Page 2 of 2

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.
 Case 1:16-cv-04642 Document 1-1 Filed 00/20/16 Page 1 of 2

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, 2016,1 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

 Case 1:16-cv-07673 Document 1-4 Filed 09/30/16 Page 1 of 1

DECLARATIO
N

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

1. l a m 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. In the 1994-95 school year, I was told by the plaintiff in Jane Doe v. Trump and Epstein (l:16-cv- 04642,
SDNY) that the plaintiff was subject to sexual contact by the Defendants at parties in New York City during the
summer of 1994.

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

DATED 2016
Case 1:16-cv-07673 Document 1-5 Filed 09/30/16 Page 1 of 2
 Case 1:16-cv-07673 Document 1-5 Filed 09/30/16 Page 1 of 3

DECLARATION IN SUPPORT OF PLAINTIFF'S REQUEST FOR PROTECTIVE ORDER

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

1. l a m 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 1991,1 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.
 Case 1:16-cv-07673 Document 1-5 Filed 09/30/16 Page 1 of 2

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 2000,1 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.