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7 18 19 20 21 22 23 24 25 26 27 28 FACTUAL ALLEGATIONS 5. The Plaintiff, Katie Johnson, alleges that the Defendants, Donald J. Trump and Jeffrey E. Epstein, did willfully and with extreme malice violate her Civil Rights under 18 U.S.C. ; 2241 by sexually and physically abusing Plaintiff Johnson by forci
nt, Jeffrey E. Epstein, the Plaintiff, Katie Johnson, 17 was forced to disrobe into her bra and panties and to give a full body massage to Defendant Epstein 18 while he was completely naked. During the massage, Defendant Epstein physically forced Plaintiff 19 Johnson to touch his erect penis with her ba
ra and panties and to give a full body massage to Defendant Epstein 18 while he was completely naked. During the mas
ry DC KATIE JOHNSON v. DONALD J. TRUMP and JEFFREY E. EPSTEIN UNITED STATES DISTRICT COURT CENTRAL D
ry DC KATIE JOHNSON v. DONALD J. TRUMP and JEFFREY E. EPSTEIN UNITED STATES DISTRICT COURT CENTRAL DI
tate of New York and the action is for damages above $75,000. VENUE 2. The venue is established as the Eastern Division of the United States Court Central District of California because the plaintiff resides in San Bernadino County, State of California 1 - O xj CV-I26 (09/09) PLEADING PACE FOR A COMPLAINT
uring those negotiations against either party. BACKGROUND The Court is very familiar with this matter, having handled the civil suits filed against Jeffrey Epstein pursuant to the Non-Prosecution Agreement and this actions filed by Jane Does #1 and #2 against the United States. For purposes of this Supplemental
of the government, the Jane Does have only received the portions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Ja
gotiations between the Intervenors (on behalf of Jeffrey Epstein) and the U.S. Attorney's Office. The Inte
by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by
torney Intervenors discuss a series of common law privileges, including a "mediation privilege" that has been recognized by the Second Circuit, the Central District of California, and the Western District of Pennsylvania, relying on a decision of Judge Marcus. As quoted by the Intervenors, mediation "afford[s] t
uring those negotiations against either party. BACKGROUND The Court is very familiar with this matter, having handled the civil suits filed against Jeffrey Epstein pursuant to the Non-Prosecution Agreement and this actions filed by Jane Does #1 and #2 against the United States. For purposes of this Supplemental
of the government, the Jane Does have only received the portions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Ja
gotiations between the Intervenors (on behalf of Jeffrey Epstein) and the U.S. Attorney's Office. The Inte
by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by
torney Intervenors discuss a series of common law privileges, including a "mediation privilege" that has been recognized by the Second Circuit, the Central District of California, and the Western District of Pennsylvania, relying on a decision of Judge Marcus. As quoted by the Intervenors, mediation "afford[s] t
the death of Breonna Taylor, and requested information on the collaboration between state and local law enforcement partners. OPA declined comment. Epstein/Prince Andrew: OPA/NY — Continue to receive inquiries into Jeffrey Epstein's death and alleged activity involving Prince Andrew. OPA, in coordinatio
boration between state and local law enforcement partners. OPA declined comment. Epstein/Prince Andrew: OPA/NY — Continue to receive inquiries into Jeffrey Epstein's death and alleged activity involving Prince Andrew. OPA, in coordination with New York Field Office, declined comment. LOCAL STORIES Los Angeles —
drew: OPA/NY — Continue to receive inquiries into Jeffrey Epstein's death and alleged activity involving P
" is operating at the department's Compton Station. Division is declining to confirm/deny the existence of an investigation. Los Angeles — The USAO—Central District of California issued a press release today announcing an indictment returned against Samuel' Trelawney Hughes of Pasadena, charged with making a ser
FBI for DT investigations. OPA advised the FBI had no further comment outside previous remarks made by Director Wray and AD Sanborn. Prince Andrew/Jeffrey Epstein: OPA—An L.A.-based London Sunday Mirror reporter asked about the FBI's continued investigation into Jeffrey Epstein and his interactions with Prince
ut the FBI's continued investigation into Jeffrey Epstein and his interactions with Prince Andrew. The public photo of and was reportedly taken by Epstein in Ghislaine Maxwell's home in London. The reporter alleges that Prince Andrew's law firm has been providing information about the photo the past f
by Director Wray and AD Sanborn. Prince Andrew/Jeffrey Epstein: OPA—An L.A.-based London Sunday Mirror r
onfirmed that FBI Springfield conducted court-authorized activity at the locations in question EFTA00164325 and directed the reporters to the USAO—Central District of Illinois. * * * Please send all Horizon submissions to with "Horizon" in the Subject line, and press releases t All correspondence contained
um summarizes the conflict of interest related to the investigation by the Federal Bureau of Investigation ("FBI") of additional crimes committed by Jeffrey Epstein ("Epstein"). The memo begins with a brief overview of the original investigation of Epstein, dubbed "Operation Leap Year"; summarizes the resolution
onflict of interest related to the investigation by the Federal Bureau of Investigation ("FBI") of additional crimes committed by Jeffrey Epstein ("Epstein"). The memo begins with a brief overview of the original investigation of Epstein, dubbed "Operation Leap Year"; summarizes the resolution of Operat
re detail than you wanted) the background of the Jeffrey Epstein case and some of the reasons why it would
the Virgin Islands also would have jurisdiction. Virginia also reported frequent sexual activity with Epstein in the District of New Mexico and the Central District ofCalifornia. In both of those Districts there is evidence (from Virginia or other witnesses) of Epstein engaging in illegal sexual activity with o
um summarizes the conflict of interest related to the investigation by the Federal Bureau of Investigation ("FBI") of additional crimes committed by Jeffrey Epstein ("Epstein"). The memo begins with a brief overview of the original investigation of Epstein, dubbed "Operation Leap Year"; summarizes the resolution
onflict of interest related to the investigation by the Federal Bureau of Investigation ("FBI") of additional crimes committed by Jeffrey Epstein ("Epstein"). The memo begins with a brief overview of the original investigation of Epstein, dubbed "Operation Leap Year"; summarizes the resolution of Operat
re detail than you wanted) the background of the Jeffrey Epstein case and some of the reasons why it would
rict of the Virgin Islands also would have jurisdiction. also reported frequent sexual activity with Epstein in the District of New Mexico and the Central District ofCalifornia. In both of those Districts there is evidence (from or other witnesses) of Epstein engaging in illegal sexual activity with other und
sidential election results Monday in favor of Joe Biden, even as [Trump's] legal team continued to dispute the results." The New York Times (11/30, Epstein, Thrush, 18.61M) reports the certification of Biden's 21,000-vote win in Wisconsin "came a few hours after Arizona officials formalized Mr. Biden's
he company's website inaccessible, federal prosecutors said." Vaughn "also had sexually explicit images of children, the U.S. Attorney's Office for Central District of California said. He pleaded guilty to a child pornography charge and other counts in November 2019." Baltimore County Schools Remain Closed Foll
sidential election results Monday in favor of Joe Biden, even as [Trump's] legal team continued to dispute the results." The New York Times (11/30, Epstein, Thrush, 18.61M) reports the certification of Biden's 21,000-vote win in Wisconsin "came a few hours after Arizona officials formalized Mr. Biden's
he company's website inaccessible, federal prosecutors said." Vaughn "also had sexually explicit images of children, the U.S. Attorney's Office for Central District of California said. He pleaded guilty to a child pornography charge and other counts in November 2019." Baltimore County Schools Remain Closed Foll
Entities connected to both Jeffrey Epstein and Central District
Leon Black
PERSON
Prince Andrew
PERSON
Eric Trump
PERSON
George Mitchell
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Harry Reid
PERSON
Stephen Hawking
PERSONJack Goldberger
PERSON
Joe Biden
PERSON
Prince Charles
PERSON
FedEx
ORGANIZATIONSouthern District
LOCATIONJane Doe
PERSON
Michael Cohen
PERSON
Tom Pritzker
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON