Case 5:16-cv-00797-DMG-KS Document 1-1 Filed 04/26/16 Page 1 of 3 Page ID #:7 Case 5:16-cv-00797-DMG-KS Document 1-1 Filed 04/26/16 Page 2 of 3 Page ID #:8 Case 5:16-cv-00797-DMG-KS Document 1-1 Filed 04/26/16 Page 3 of 3 Page ID #:9 Case 5:16-cv-00797-DMG-KS Document 1 Filed 04/26/16 Page 1 of 6 Page ID #:1 Case 5:16-cv-00797-DMG-KS Document 1 Filed 04/26/16 Page 2 of 6 Page ID #:2 Case 5:16-cv-00797-DMG-KS Document 1 Filed 04/26/16 Page 3 of 6 Page ID #:3 Case 5:16-cv-00797-DMG-KS Document 1 Filed 04/26/16 Page 4 of 6 Page ID #:4 Case 5:16-cv-00797-DMG-KS Document 1 Filed 04/26/16 Page 5 of 6 Page ID #:5 Case 5:16-cv-00797-DMG-KS Document 1 Filed 04/26/16 Page 6 of 6 Page ID #:6¶
Case 5:16-CV-OOH&TED SITESDIST BIT CURT CENTRENDOSIRIG/LEF CALIFORND 3 Page ID #:8 CIVIL COVER SHEET VIII. VENUE: Your answers to the questions below will determine the division of the Court to which this case will be initially assigned. This initial assignment is subject to change, in accordance with the Court’s General Orders, upon review by the Court of your Complaint or Notice of Removal. QUESTION A: Was this case removed from state court? STATE CASE WAS PENDING IN THE COUNTY OF INITIAL DIVISION IN CACD IS: Yes X No Los Angeles, Ventura, Santa Barbara, or San Luis Obispo Western If “no, ” skip to Question B. If “yes,” check the box to the right that applies, enter the corresponding division in response to Question E, below, and continue from there. Orange Riverside or San Bernardino QUESTION B: Is the United States, or B.1. Do 50% or more of the defendants who reside in one of its agencies or employees, a the district reside in Orange Co.? PLAINTIFF in this action? check one of the boxes to the right L Yes X No If “no, ” skip to Question C. If “yes,” answer Question B. 1, at right. B.2. Do 50% or more of the defendants who reside in the district reside in Riverside and/or San Bernardino Counties? (Consider the two counties together.) check one of the boxes to the right QUESTION C: Is the United States, or C.1. Do 50% or more of the plaintiffs who reside in the one of its agencies or employees, a district reside in Orange Co.? DEFENDANT in this action? check one of the boxes to the right Yes X No If “no,” skip to Question D. If “yes,” answer Question C.1, at right. C.2. Do 50% or more of the plaintiffs who reside in the district reside in Riverside and/or San Bernardino Counties? (Consider the two counties together.) check one of the boxes to the right Southern Eastern YES. Your case will initially be assigned to the Southern Division. Enter “Southern” in response to Question E, below, and continue from there. NO. Continue to Question B.2. YES. Your case will initially be assigned to the Eastern Division. Enter “Eastern” in response to Question E, below, and continue from there. NO. Your case will initially be assigned to the Western Division. Enter “Western” in response to Question E, below, and continue from there. YES. Your case will initially be assigned to the Southern Division. Enter “Southern” in response to Question E, below, and continue from there. NO. Continue to Question C.2. YES. Your case will initially be assigned to the Eastern Division. Enter “Eastern” in response to Question E, below, and continue from there. NO. Your case will initially be assigned to the Western Division. Enter “Western” in response to Question E, below, and continue from there. Orange County Riverside or San Bernardino County Los Angeles, Ventura, Santa Barbara, or San Luis Obispo County QUESTION D: Location of plaintiffs and defendants? indicate the location(s) in which 50% or more of plaintiffs who reside in this district reside. (Check up to two boxes, or leave blank if none of these choices apply.) Indicate the location(s) in which 50% or more of defendants who reside in this district reside. (Check up to two boxes, or leave blank if none of these choices apply.) D.1. Is there at least one answer in Column A? Yes No If “yes,” your case will initially be assigned to the SOUTHERN DIVISION. Enter “Southern” in response to Question E, below, and continue from there. If “no,” go to question D2 to the right. QUESTION E: Initial Division? Enter the initial division determined by Question A, B, C, or D above: - QUESTION F: Northern Counties? Do 50% or more of plaintiffs or defendants in this district reside in Ventura, Santa Barbara, or San Luis Obispo counties? CV-71 (02/16) CIVIL COVER SHEET D.2. Is there at least one answer in Column B? Yes No If “yes,” your case will initially be assigned to the EASTERN DIVISION. Enter “Eastern” in response to Question E, below. If “no,” your case will be assigned to the WESTERN DIVISION. Enter “Western” in response to Question E, below. INITIAL DIVISION IN CACD EASTERN Yes _ No Page 2 of 3 HOUSE_OVERSIGHT_029258¶
Case 5:16-CV-OQINTED TOTESDISOBICT COURT CEN FREDDOSINGHOF CAAYORND 3 Page ID #:9 CIVIL COVER SHEET NO IX(a). IDENTICAL CASES: Has this action been previously filed in this court? If yes, list case number(s): IX(b). RELATED CASES: Is this case related (as defined below) to any civil or criminal case(s) previously filed in this court? X NO If yes, list case number(s): Civil cases are related when they (check all that apply): • A. Arise from the same or a closely related transaction, happening, or event; B. Call for determination of the same or substantially related or similar questions of law and fact; or • C. For other reasons would entail substantial duplication of labor if heard by different judges. Note: That cases may involve the same patent, trademark, or copyright is not, in itself, sufficient to deem cases related. YES • YES A civil forfeiture case and a criminal case are related when they (check all that apply): A. Arise from the same or a closely related transaction, happening, or event; B. Call for determination of the same or substantially related or similar questions of law and fact; or C. Involve one or more defendants from the criminal case in common anei would entail substantial duplication of labor if heard by different judges. X. SIGNATURE OF ATTORNEY (OR SELF-REPRESENTED LITIGANT): Got ton DATE: 2p01|262016 Notice to Counsel/Parties: The submission of/this Civil Cover Sheet is required by Local Rule 3-1. This Form CV-71 and the information contained herein neither replaces nor supplements the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. Fol nore detailed instructions, see separate instruction sheet (CV-071A) Key to Statistical codes relating to Social Security Cases: Nature of Suit Code Abbreviation 861 HIA 862 863 863 864 865 BL DIWC DIWW SSID RSI Substantive Statement of Cause of Action All claims for health insurance benefits (Medicare) under Title 18, Part A, of the Social Security Act, as amended. Also, include claims by hospitals. skilled nursing facilities, etc. for certification as providers of services under the program. (42 U.S.C. 1935FF(b)) Al slaims for “Black Lung” benefits under Tide 4, Part B, of the Federal Coal Mine Health and Safety Act of 1969(30 U.S.C. All dams file or chirst sures benefits iased on disa bine: (sUS. (s2U.SeC T10s the Social Security Act as amended: plus All claims filed for widows or widowers insurance benefits based on disability under Title 2 of the Social Security Act, as amended. (42 U.S.C. 405 (g)) amendes for supplemental security income payments based upon disabilit filed under Title 16 of the Social Security Act, as All claims for retirement (old age) and survivors benefits under Title 2 of the Social Security Act, as amended. (42 U.S.C. 405 (g)) CV-71 (02/16) CIVIL COVER SHEET Page 3 of 3 HOUSE_OVERSIGHT_029259¶
IFlo 22 23 24 25 26 27 28 Case 5:16-Cv-00797-DMG-KS Document 1 Filed 04/26/16 Page 1 of 6 Page ID #:1 BY. 1 2 3 Name: KATIE JOHNSON Address: 6634 DESERT QUEEN AVE. TWENTYNINE PALMS, CA. 92277 4 5 6 Phone: (760) 401-0192 Fax: NO FAX OR E-MAIL In Pro Per 7 8 9 10 11 KATIE JOHNSON 12 13 v. 14 15 DONALD J. TRUMP and JEFFREY E. EPSTEIN 16 RIVEASIDE CLERK U.S. CALI DISTRICT COURT 2016 APR 26 AM II: 12 FILED UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CASE NUMBER: ED CVL6-00797 DIG (KSX) Plaintiff To be supplied by the Clerk of The United States District Court COMPLAINT FOR CLAIM RELIEF DUE TO:¶
- SEXUAL ABUSE UNDER THREAT OF HARM
- CONSPIRACY TO DEPRIVE CIVIL RIGHTS Defendant(s). Plaintiff Katie Johnson, for causes of actions against Defendants Donald J. Trump and Jeffrey E. Epstein, alleges as follows: JURISDICTION
- Jurisdiction is pursuant to the law of Diversity, 28 U.S.C.; 1332, as plaintiff resides in the state of California while defendants reside in the state of New York and the action is for damages above $75,000. VENUE
- 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 CV-126 (09/09) PLEADING PAGE FOR A COMPLAINT HOUSE_OVERSIGHT_029260
Case 5:16-Cv-00797-DMG-KS Document 1 Filed 04/26/16 Page 2 of 6 Page ID #:2 1 2 3 4 5 6 7 PARTIES 3. The Plaintiff, Katie Johnson, resides in the State of California. 4. The Defendants, Donald J. Trump and Jeffrey E. Epstein, each reside in the State of New York. 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 9 sexually and physically abusing Plaintiff Johnson by forcing her to engage in various perverted and 10 depraved sex acts by threatening physical harm to Plaintiff Johnson and also her family. 11 6. The Plaintiff, Katie Johnson, alleges that the Defendants, Donald J. Trump and Jeffrey E. 12 13 14 Epstein, also did willfully and with extreme malice violate her Civil Rights under 42 U.S.C. ; 1985 by conspiring to deny Plaintiff Johnson her Civil Rights by making her their sex slave. 7. The Plaintiff, Katie Johnson, alleges she was subject to extreme sexual and physical abuse by 15 the Defendants, Donald J. Trump and Jeffrey E. Epstein, including forcible rape during a four 16 month time span covering the months of June-September 1994 when Plaintiff Johnson was still only 17 18 a minor of age 13. 8. The Plaintiff, Katie Johnson, alleges she was enticed by promises of money and a modeling 19 career to attend a series of underage sex parties held at the New York City residence of Defendant 20 Jeffrey E. Epstein and attended by Defendant Donald J. Trump. 21 9. On the first occasion involving the Defendant, Donald J. Trump, the Plaintiff, Katie Johnson, 22 was forced to manually stimulate Defendant Trump with the use of her hand upon Defendant 23 Trump’s erect penis until he reached sexual orgasm. 24 10. On the second occasion involving the Defendant, Donald J. Trump, the Plaintiff, Katie 25 Johnson, was forced to orally copulate Defendant Trump by placing her mouth upon Defendant 26 Trump’s erect penis until he reached sexual orgasm. 27 28 2 CV-126 (09/09) PLEADING PAGE FOR A COMPLAINT HOUSE_OVERSIGHT_029261¶
Case 5:16-Cv-00797-DMG-KS Document 1 Filed 04/26/16 Page 3 of 6 Page ID #:3 1 11. On the third occasion involving the Defendant, Donald J. Trump, the Plaintiff, Katie Johnson, 2 was forced to engage in an unnatural lesbian sex act with her fellow minor and sex slave, Maria Doe. 3 age 12, for the sexual enjoyment of Defendant Trump. After this sex act, both minors were forced 4 to orally copulate Defendant Trump by placing their mouths simultaneously on his erect penis until 5 he achieved sexual orgasm. After zipping up his pants, Defendant Trump physically pushed both 6 minors away while angrily berating them for the “poor” quality of their sexual performance. 7 12. On the fourth and final sexual encounter with the Defendant, Donald J. Trump, the Plaintiff, 8 Katie Johnson, was tied to a bed by Defendant Trump who then proceeded to forcibly rape Plaintiff 9 Johnson. During the course of this savage sexual attack, Plaintiff Johnson loudly pleaded with 10 Defendant Trump to “please wear a condom”. Defendant Trump responded by violently striking 11 Plaintiff Johnson in the face with his open hand and screaming that “he would do whatever he 12 wanted” as he refused to wear protection. After achieving sexual orgasm, the Defendant, Donald J. 13 Trump put his suit back on and when the Plaintiff, Katie Johnson, in tears asked Defendant Trump 14 what would happen if he had impregnated her, Defendant Trump grabbed his wallet and threw 15 some money at her and screamed that she should use the money “to get a fucking abortion”. 16 13. On the first occasion involving the Defendant, 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 bare hands and to clean up his ejaculated semen after he 20 achieved sexual orgasm. 21 14. On the second occasion involving the Defendant, Jeffrey Epstein, the Plaintiff, Katie Johnson, 22 was again forced to disrobe into her bra and panties while giving Defendant Epstein a full body 23 massage while he was completely naked. The Defendant, Donald J. Trump, was also present as he 24 was getting his own massage from another minor, Jane Doe, age 13. Defendant Epstein forced 25 Plaintiff Johnson to touch his erect penis by physically placing her bare hands upon his sex organ 26 and again forced Plaintiff Johnson to clean up his ejaculated semen after he achieved sexual orgasm. 27 28 3 CV-126 (09/09) PLEADING PAGE FOR A COMPLAINT HOUSE_OVERSIGHT_029262¶
Case 5:16-Cv-00797-DMG-KS Document 1 Filed 04/26/16 Page 4 of 6 Page ID #:4 1 15. Shortly after this sexual assault by the Defendant, Jeffrey E. Epstein, on the Plaintiff, Katie 2 Johnson, Plaintiff Johnson was still present while the two Defendants were arguing over who would 3 be the one to take Plaintiff Johnson’s virginity. The Defendant, Donald J. Trump, was clearly heard 4 referring to Defendant, Jeffrey E. Epstein, as a “Jew Bastard” as he yelled at Defendant Epstein, that 5 clearly, he, Defendant Trump, should be the lucky one to “pop the cherry” of Plaintiff Johnson. 6 16. The third and final sexual assault by the Defendant, Jeffrey E. Epstein, on the Plaintiff, Katie 7 Johnson, took place after Plaintiff Johnson had been brutally and savagely raped by Defendant 8 Trump. While receiving another full body massage from Plaintiff Johnson, while in the nude, 9 Defendant Epstein became so enraged after finding out that Defendant Trump had been the one to 10 take Plaintiff Johnson’s virginity, that Defendant Epstein also violently raped Plaintiff Johnson. 11 After forcing Plaintiff Johnson to disrobe into her bra and panties, while receiving a massage from 12 13 the Plaintiff, Defendant Epstein attempted to enter Plaintiff Johnson’s anal cavity with his erect penis while trying to restrain her. Plaintiff Johnson attempted to push Defendant Epstein away, at 14 which time Defendant Epstein attempted to enter Plaintiff Johnson’s vagina with his erect penis. 15 This attempt to brutally sodomize and rape Plaintiff Johnson by Defendant Epstein was finally 16 17 repelled by Plaintiff Johnson but not before Defendant Epstein was able to achieve sexual orgasm. After perversely sodomizing and raping the Plaintiff, Katie Johnson, the Defendant, Jeffrey E. 18 19 Epstein, attempted to strike her about the head with his closed fists while he angrily screamed at Plaintiff Johnson that he, Defendant Epstein, should have been the one who “took her cherry, not 20 Mr. Trump”, before she finally managed to break away from Defendant Epstein. 21 17. The Plaintiff, Katie Johnson, was fully warned on more than one occasion by both 22 Defendants, Donald J. Trump and Jeffrey E. Epstein, that were she ever to reveal any of the details 23 of the sexual and physical abuse that she had suffered as a sex slave for Defendant Trump and 24 Defendant Epstein, that Plaintiff Johnson and her family would be in mortal danger. Plaintiff 25 Johnson was warned that this would mean certain death for herself and Plaintiff Johnson’s family 26 unless she remained silent forever on the exact details of the depraved and perverted sexual and 27 physical abuse she had been forced to endure from the Defendants. 28 CV-126 (09/09) PLEADING PAGE FOR A COMPLAINT HOUSE_OVERSIGHT_029263¶
Case 5:16-Cv-00797-DMG-KS Document 1 Filed 04/26/16 Page 5 of 6 Page ID #:5 1 MATERIAL WITNESSES 2 3 18. Tiffany Doe, a former trusted employee of the Defendant, Jeffrey E. Epstein, has agreed to provide sworn testimony in this civil case and any other future civil or criminal proceedings, fully 4 verifying the authenticity of the claims of the Plaintiff, Katie Johnson. Witness Tiffany Doe was 5 employed by the Defendant, Jeffrey E. Epstein, for more than 10 years as a party planner for his 6 underage sex parties. Despite being subject to constant terroristic threats by Defendants Epstein 7 and Trump to never reveal the details of these underage sex parties at which scores of teenagers, 8 and pre-teen girls were used as sex slaves by Defendant Epstein and Defendant Trump, witness Tiffany Doe refuses to be silent any longer. She has agreed to fully reveal the extent of the sexual 10 perversion and physical cruelty that she personally witnessed at these parties by Defendants Epstein 11 and Trump. 12 19. Material witness Tiffany Doe fully confirms all of Plaintiff Katie Johnson’s allegations of 13 physical and sexual abuse by Defendants Donald J. Trump and Jeffrey E. Epstein. Tiffany Doe was 14 physically present at each of the four occasions of sexual abuse by Defendant Trump upon the 15 person of Plaintiff Johnson, as it was her job to witness all of the sexual escapades of Defendant 16 Epstein’s guests at these underage sex parties and later reveal all of the sordid details directly to 17 Defendant Epstein. Defendant Epstein also demanded that Tiffany Doe tell him personally 18 19 everything she had overheard at these parties explaining to her that “knowledge was king” in the financial world. As a result of these underage sex parties, Defendant Epstein was able to accumulate 20 inside business knowledge that he otherwise would never have been privy to in order to amass his 21 huge personal fortune. 22 20. Material witness Tiffany Doe will testify that she was also present or had direct knowledge 23 of each of the three instances on which Defendant Jeffrey E. Epstein physically and sexually abused 24 the Plaintiff, Katie Johnson. Tiffany Doe will testify to the fact that the Plaintiff, Katie Johnson, 25 was extremely fortunate to have survived all of the physical and sexual horrors inflicted upon her 26 by Defendants Epstein and Trump. 27 28 5 CV-126 (09/09) PLEADING PAGE FOR A COMPLAINT HOUSE_OVERSIGHT_029264¶
Case 5:16-Cv-00797-DMG-KS Document 1 Filed 04/26/16 Page 6 of 6 Page ID #:6 1 2 3 4 CLAIM FOR RELIEF 21. The Plaintiff, Katie Johnson, asks the court for relief against the Defendants, Donald J. Trump and Jeffrey E. Epstein, in the amount of $100,000,000.00 (One Hundred Million Dollars) as 6 a result of the Defendants aforementioned acts upon which they willfully and maliciously violated 7 the Civil Rights of the Plaintiff as stated in 18 U.S.C.; 2241 by sexually and physically abusing the 8 then 13 year old Plaintiff Johnson under threat of harm to her and her family, and 42 U.S.C.; 1985 9 by the Defendants conspiring to deny the Civil Rights of Plaintiff Johnson by making her their sex 10 slave. 11 12 13 Dated: April 26, 2016 KATIE JOHNSON 14 15 16 17 18 19 Plaintiff Katie Johnson Appearing In Pro Per 20 22 23 24 25 26 27 28 6 CV-126 (09/09) PLEADING PAGE FOR A COMPLAINT HOUSE_OVERSIGHT_029265¶