Lest we forget .... this plaintiff was 13:
"Defendant Trump initiated sexual contact with Plaintiff at four different parties.
On the fourth and final sexual encounter with Defendant Trump, Defendant Trump tied Plaintiff
to a bed, exposed himself to Plaintiff, and then proceeded to forcibly rape Plaintiff. During the
course of this savage sexual attack, Plaintiff loudly pleaded with Defendant Trump to stop but
with no effect. Defendant Trump responded to Plaintiff’s pleas by violently striking Plaintiff in
the face with his open hand and screaming that he would do whatever he wanted. Exhs. A and
B.
11. Immediately following this rape, Defendant Trump threatened Plaintiff that, were
she ever to reveal any of the details of the sexual and physical abuse of her by Defendant Trump,
Plaintiff and her family would be physically harmed if not killed. Exhs. A and B.
12. Defendant Epstein had sexual contact with Plaintiff at two of the parties. The
second sexual encounter with Defendant Epstein took place after Plaintiff had been raped by
Case 1:16-cv-07673 Document 1 Filed 09/30/16 Page 4 of 10
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Defendant Trump. Defendant Epstein forced himself upon Plaintiff and proceeded to rape her
anally and vaginally despite her loud pleas to stop. Defendant Epstein then attempted to strike
Plaintiff about the head with his closed fists while he angrily screamed at Plaintiff that he,
Defendant Epstein, rather than Defendant Trump, should have been the one who took Plaintiff’s
virginity, before Plaintiff finally managed to break away from Defendant Epstein. Exhs. A and
B.
13. The threats of violence against Plaintiff and her family continued, this time from
Defendant Epstein, who again reiterated that Plaintiff was not to reveal any of the details of his
sexual and physical abuse of her or else, specifically, Plaintiff and her family would be seriously
physically harmed, if not killed. Exhs. A and B.
14. While still under threats of physical harm by coming forward and having no
reason to believe that the threats have ever been lifted or would ever be lifted, Plaintiff, who has
suffered from stress, emotional distress, mental pain and suffering, among other problems, ever
since the assaults, was subjected to daily painful reminders of the horrific acts of one of the
perpetrators, Defendant Trump, via mass media coverage of him starting on or about June 16,
2015 that, over a short period of time, became continuous and unavoidable. Exh. A"
