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onsidered. 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 modelin
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. 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.
intiff Jane Doe, Exhibit A hereto; Declaration of Tiffany Doe, Exhibit B hereto. Jane Doe and Tiffany Doe
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. 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.
ed States citizen in 1988 1-1§1 The couple divorced in 1992, following Trump's affair with actress Marla MaplesP73 He and Maples have one daughter, Tiffany (born 1993). 1$ They married in 1993, separated in 1997, and divorced in 1999.119.1 Tiffany was raised by Marla in California. 2O In 2005, Trump ma
d the company that its use of the word "university" violated state law, its name was changed to Trump Entrepreneur Initiative in 20105151 In 2013, the State of New York filed a $40 million civil suit against Trump University, alleging that the company made false statements and defrauded consumers.(9111 In addition,
ited States citizen in 19-1870 The couple divorced in 1992, following Trump's affair with actress Marla Maples.( A He and Maples have one daughter, Tiffany (born 1993) E-14,1 They married in 1993, separated in 1997, and divorced in 1999.119 Tiffany was raised by Marla in California.13-21 In 2005, Trum
he company that its use of the word "university" violated state law, its name was changed to Trump Entrepreneur Initiative in 2010.19-5.1 In 2013, the State of New York filed a $40 million civil suit against Trump University, alleging that the company made false statements and defrauded consumers.(9-0 In addition, t
Entities connected to both Tiffany Trump and the State of New York

Jeffrey Epstein
PERSON
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSON
the Internal Revenue Service
ORGANIZATION
United States
LOCATION
George W. Bush
PERSON
Newark
LOCATIONLeon Black
PERSON
Federal Reserve
ORGANIZATION
New York
LOCATIONDarren Indyke
PERSON
New York City
LOCATION
Donald Trump
PERSON
Prince Andrew
PERSON
Samantha Power
PERSON
Alan Dershowitz
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
Marc Rich
PERSONthe Southern District
LOCATION