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Extracted Text (OCR)
Case 1:16-cv-04642 Document 1 Filed 06/20/16 Page 2 of 9
5. This Court has original subject matter jurisdiction with respect to this action
pursuant to 28 U.S.C. § 1332 as there exists complete diversity of citizenship between Plaintiff
and Defendants and the amount in controversy exceeds Seventy Five Thousand Dollars
($75,000.00), exclusive of interest and costs.
6. Defendants are each subject to the jurisdiction of this Court pursuant to 28 U.S.C.
§ 1332 with proper venue pursuant to 28 U.S.C. § 1391 as both defendants are residents of
and/or are domiciled in this district and the events giving rise to the claims occurred in this
district.
RAPE, SEXUAL MISCONDUCT, CRIMINAL SEXUAL ACTS, SEXUAL ABUSE,
FORCIBLE TOUCHING, ASSAULT, BATTERY, INTENTIONAL AND RECKLESS
INFLICTION OF EMOTIONAL DISTRESS, DURESS, AND FALSE
IMPRISONMENT
7. Plaintiff was subject to acts of rape, sexual misconduct, criminal sexual acts,
sexual abuse, forcible touching, assault, battery, intentional and reckless infliction of emotional
distress, duress, false imprisonment, and threats of death and/or serious bodily injury by the
Defendants that took place at several parties during the summer months of 1994. The parties
were held by Defendant Epstein at a New York City residence that was being used by Defendant
Epstein at 9 E. 71st St. in Manhattan. During this period, Plaintiff was a minor of age 13 and
was legally incapable under New York law of consenting to sexual intercourse and the other
sexual contacts detailed herein. NY Penal L § 130.05(3)(a). The rapes in the first, second, and
third degrees; sexual misconduct; criminal sexual acts in the first, second, and third degrees;
sexual abuse in the first, second, and third degrees; and forcible touching (and, on information
HOUSE_OVERSIGHT_026385
Extracted Information
Dates
Document Details
| Filename | HOUSE_OVERSIGHT_026385.jpg |
| File Size | 0.0 KB |
| OCR Confidence | 85.0% |
| Has Readable Text | Yes |
| Text Length | 1,806 characters |
| Indexed | 2026-02-04T16:58:59.234459 |