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Epstein’s Co-Conspirator(s) - New York Supreme Court filing

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Posted on July 12 2019


Epstein, NYC Recruiters & Victim

If you’ve watched the news there’s no doubt you’ve watched the newest Epstein victim - this previous entry (although largely focused on Alex Acosta) but it does include the NBC-Today interview with Jennifer Arazo.


I could be wrong but I haven’t notice much reporting about the Complaint she filed in New York Supreme Court.  I should disclose that I’m not well versed in the State of New York’s Judicial System. Specifically their local rules and/or procedures. Nonetheless late yesterday I received an alert (yes I am that person who has various alerts set up) that Epstein 


New York CPLR § 3102 (c):

Before action commenced. Before an action is commenced, disclosure to aid in bringing an action, to preserve information or to aid in arbitration, maybe obtained, but only by court order. The court may appoint a referee to take testimony.


New York CPLR § 3102 (e):

Action pending in another jurisdiction. Except as provided in section three thousand one hundred nineteen of this article, when under any mandate, writ or commission issued out of any court of record in any other state, territory ,district or foreign jurisdiction, or whenever upon notice or agreement, it is required to take the testimony of a witness in the state, he or she may be compelled to appear and testify in the same manner and by the same process as may be employed for the purpose of taking testimony in actions pending in the state. The supreme court or a county court shall make any appropriate order in aid of taking such a deposition.


What you should know about the N.Y. Judicial System is their case numbers are known as Index Numbers. According I pulled down Jennifer Araoz’s VERIFIED COMPLAINT INDEX NO. 156728/2019.

I’ve taken the liberty of uploading the petition my public google drive, found here.

For an Order pursuant to section 3102(c) of the Civil Practice Law and Rules to PETITION Compel Disclosure from JEFFERY EPSTEIN and Jane Does 1-3


Paragraph 4 - pages 1 & 2 respectively - subsection entitled: “the Facts”.  Let’s be clear here, she’s a victim and Epstein is a sexual predator. During Ms. Araoz’s Today-Show Interview - at one point in the interview she blames herself. The point is it is not her fault. She was a child that Epstein repeatedly sexually assaulted and ultimately raped.



It doesn’t matter that she waited to come forward.  What matters is she came forward. She spoke her truth. Insofar as to encourage other previously unknown Epstein victims to also come forward. 

The from the draft complaint which is an Exhibit included in the aforementioned petition - it is difficult to read given the new details included.  

Defendant, Jane Doe 1, referred to in this Complaint as the “Recruiter,” was brunette woman believed to be in her early 20s, who worked for Defendant Epstein in New York, New York.

Defendant, Jane Doe 2, referred to in this Complaint as the “Secretary,” was an adult female, who worked for Defendant Epstein in New York, NY.

Defendant, Jane Doe 3, referred to in this Complaint as the “Maid,” was an adult female, who worked for Defendant Epstein in New York, NY.


What’s further detailed in the draft Complaint is just disgusting - meaning Epstein’s “recruiter” was just as much as a predator as Epstein himself. The recruiter targeted victims and I’ll bet you Investigators will take another run at previous interviews. What’s pretty clear in the draft Complaint is this was a well orchestrated “apparatus” to solicit victims and then victimize them. It is like a text book study of how to identify a victim and then prey on their naivety for Epstein’s own sexual perversions.     


The campus is within the Julia Richman Education Complex along with five other schools: Urban Academy, Vanguard High School, P226M Junior High Annex, Ella Baker Elementary School, and Manhattan International High School

Recruiter approached Ms. Araoz repeatedly over the course of a week or two, offering to take her for lunches close by the school, and during the meals, would continue to ask personal questions about her.

At some point during this approximate two week period, the Recruiter began to speak about Defendant Epstein, almost as if he was her uncle or a family friend. 

The Recruiter said that Epstein was a “nice guy,” and that he takes care of her and her family. The Recruiter spoke glowingly of Epstein, stating he is very wealthy, and “you have to see his house.


Again do not blame or shame the victim(s) they were children. At the time Ms Araoz was 14 years old. Think about what you were like at 14 - that her father had recently died due to complications or HIV - Epstein used other women to procure new child victims. It is so gross


Epstein’s Secretary’s office with a waiting room, couches and chairs. To the right there was the trophy room filled with hunted animals.
There was also a kitchen on the same floor. As one kept walking forward, there was a spiral staircase with a self-portrait of Epstein on the wall with a young girl, who Epstein said he considered like a daughter.

He also told Ms. Araoz that he was “a big AIDS activist,” which meant a lot to Ms. Araoz at the time, because her father had recently passed away from the disease.

Each time, Ms. Araoz stayed between 1-2 hours, and at the end
of the stay, Epstein would direct his Secretary to give her $300 and just say that he “wanted to help her out,” while she and the Recruiter would be served cheese, crackers and wine by the Maid.


🚨trigger warning - if you are easily offended or reading about sexual assault may trigger you I would stop reading now🚨


Epstein showed Ms. Araoz the art work in the room and the massage table, stating that “not many people know about this room.” He then stated, “You really should be a model,” “You’re beautiful,” “I’ll bet your body is incredible,” and “In order to help you with your modeling career, I will need to see your body.”...Epstein had a lot of paintings of nude women on the walls.

He even commented on one painting of a nude woman with small breasts and brunette hair, but you couldn’t see her face clearly because she was partially turned. That painting was right behind the massage table, and he said how much the woman in the picture looked like Ms. Araoz, then 14 years old. He said he liked “girls with small breasts” because they were “natural and real.” He then complimented Ms. Araoz repeatedly about her breasts. 




And while you might assume this is an unusual move by Epstein’s victim, specifically asking a Court to order him to submit to a deposition - the reality is in the State of New York there is a mechanism to do just that. As argued in the following Affirmation by Ms Araoz’s attorney. I want to draw your attention to the firm she hired: Kaiser Saurborn & Mair, P.C. 

“...recruiter identified in paragraphs 12" to "23" of the draft complaint to be filed on August 2019. [See paragraph "5" of the Petition and attached Complaint]. Further, the recruiter is a potential defendant in the contemplated lawsuit. The recruiter aided and abetted Respondent's sexual abuse of Petitioner and conspired with Respondent in his commission of the sexual detailed in her to be filed complaint...a key witness to Respondent's sexual abuse, including rape, of Petitioner was the recruiter...”


Petitioner respectfully requests that the Court order that Respondent submit for a deposition at the offices of Petitioner's attorney and further order Respondent to produce documents and records that identify his employees between the years 2000 and 2003 and finally produce for inspection any and all logs of all visitors to his New York City mansion between the dates of 2000 and 2003


With respect to Epstein’s Bail Package you can read his attorneys filing here (which I also uploaded to my public google drive) Epstein’s argument is he will make his NYC Mansion his “own private prison” and he’s willing to offer up more than $89M+. The  media reported $77M that figure is patently incorrect. The $77M is strictly for Epstein’s Value of his NYC mansion.

 It is a reasonable conclusion that no amount of collateral assets would convince AUSA Berman that Epstein should be released pending Trial.


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1 comment

  • Maureen A Donnelly: July 15, 2019

    i’m going to take her complaint and write an erasure poem. this shit is so far off the rails and so deep. the trump—epstein debacle may be the thing that gets the orange menace. seems like too few members of the GOP are offended by child rape—e.g., support for Roy Moore.

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