Mega Edition: Stacey Plaskett And Her Motion For Rule 11 Sanctions Against The Epstein Survivors (8/21/25)

Congresswoman Stacey Plaskett, the Delegate from the U.S. Virgin Islands, became the lone remaining defendant in a civil case filed by six survivors of Jeffrey Epstein’s abuse after the court dismissed the claims against other parties. The survivors alleged that Plaskett was complicit in Epstein’s sex trafficking operation, accusations that she forcefully denied. In April 2025, a second amended complaint reiterated the charges, to which Plaskett responded by filing a motion to dismiss, calling the claims baseless and defamatory. She has consistently framed the lawsuit as politically motivated and lacking in legal merit.

Prior to this, in July 2024, Plaskett filed a motion under Rule 11 of the Federal Rules of Civil Procedure seeking sanctions against the survivors’ attorney. Rule 11 motions are designed to punish parties or lawyers for filing frivolous, unfounded, or harassing litigation. Plaskett argued that the case against her was precisely that.


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Episode Transcript

Speaker 1 (00:00):
What's up everyone, and welcome back to the Epstein Chronicles.
In this episode, we're going to start taking a look
at Democratic Congresswoman Stacey Plaskett and her motion for Rule
eleven sanctions against the Epstein survivors who filed the lawsuit
against her. Meanwhile, Ted lu has all kinds of fairy
Tales to sell you Case number one twenty three Dash

(00:23):
CV DASH one zero three zero one DASH as memorandum
of law and support of congress Woman Stacey Plaskett's motion
for Rule eleven sanctions. Preliminary statement. Rule eleven imposes the
duty and obligation on all Council to conduct a reasonable inquiry,
to only file pleadings with the sound basis in law
in fact, and to not file an action for an

(00:45):
improper purpose. Council signed and filed the Individual and Class
Action second Amended Complaint with a flagrant disregard for these obligations.
The sac makes loud but hollow accusations against Congresswoman Plasket
knowingly joined a destructive sex trafficking ring that harmed hundreds
of women for decades. She took his money, Okay, and

(01:07):
not only did she take his money, folks, she took
it after he was already convicted, So spare me the bullshit, please.
The essayc claims are seemingly derived from pure invention. They
stretch facts to the point of misrepresentation in an attempt
to bolster the otherwise conclusiony fictional claims. The legal claims
asserted or all frivolous, each lacking at least one fundamental,

(01:29):
well established element. The full facts and circumstances strongly suggest
an improper motive or bad faith on the part of
Plaintiff's council. The inclusion of Congresswoman Plasket in this action
are a textbook rule eleven violation. Congresswoman Plasket regretfully but
respectfully moves for sanctions against plaintiff's council. Oh yeah, regretfully.

(01:51):
Huh was she regretful when she was taking Epstein's money
or begging them for a donation for the Democrats Facts
and procedural history. Congresswoman plascid It has dedicated the past
seventeen years to serving the people of the United States
Virgin Islands. In nineteen ninety four, upon graduation from law school,
Miss Plaskets wore the oath of office as an assistant
District attorney in the Bronx County of New York, where

(02:14):
she prosecuted crimes on behalf of the people of Bronx County,
meaning she put people in jail for Pott Declaration of
Stacey Plaskett. From ninety seven to ninety nine as a
young lawyer, she worked for a private company. From nineteen
ninety nine to two thousand and two, she served as
council on the United States House of Representatives Ethics Committee.
So somebody that was on the Ethics Committee didn't know

(02:35):
it was a bad idea to take money or even
solicit money from a child predator. Okay, I guess it
makes sense. And then you take a look at the
ethics of the people who were in office, and it
really does start to come into focus. Right From two
thousand and two to two thousand and four, Congresswoman Plasket
served first as council to the Assistant Attorney General of

(02:56):
the Civil Division and then his senior council to the
Deputy of Attorney General. In two thousand and seven, after
two more years in private practice, Congresswoman Plasket accepted the
position of General Counsel for the Virgin Islands Economic Development Authority,
where she served from two thousand and seven to twenty twelve.
The VIETA is a semi autonomous government organization dedicated to

(03:18):
economic development in the Virgin Islands. Virgin Island Code twenty nine,
Section eleven hundred, USVII Economic Development Authority. The Economic Development
Commission is one of four functions for the Vieta USVII
Economic Development Authority about US. The EEDC has responsibility for
investigating and recommending tax incentives to qualifying companies and individuals.

(03:43):
Its function and many of its procedures are defined by statute.
In twenty fourteen, after a short time in private practice
in the USVII Congresswoman Plasket ran for office and was
elected to Congress. She was sworn in as a member
of the fourteenth Congress on January six, twenty fifteen, where
she served the people of her community ever since. All

(04:05):
of these facts are easily located through basic Internet research.
Jeffrey Epstein was a wealthy financier pedophile who was famously
well connected the one hundreds of socially and politically active
individuals CEG. Taylor, Nicole Rodgers, Aeron Snodgrass, Kelsey Vlamis, and
madelen Berg. Here are all the famous people. Jeffrey Epstein

(04:26):
was connected to Business Insider January fourth, twenty twenty two,
Taylor Nicole Rodgers. Here are all the politicians. Jeffrey Epstein,
the money manager arrested for charges of sex trafficking, has
donated to So she's trying to use somewhat about ism here, right,
But what about all these other people? Epstein maintained a
home in the USVII. He also had financial service related

(04:48):
companies with employees in the USVII. In nineteen ninety nine,
his company purportedly applied for and received tax incentives from
the USVII for a ten year term. CEG. Jonathan Stemple
Jeffrey Epstein got three hundred million dollars in tax breaks paid.
US Virgin Islands Police JP Morgan says his company reapplied

(05:09):
in tax incentives were renewed in twenty twelve. For twenty years.
Between nineteen ninety nine and twenty nineteen, Epstein's companies received
approximately three hundred million dollars in tax breaks in the USVII.
In two thousand and eight, Epstein pleaded guilty in Florida
for soliciting prostitution from an underage girl. Samuel Goldsmith. Jeffrey

(05:30):
Epstein pleads guilty to prostitution charges and y post June thirtieth,
two thousand and eight. This was just the tip of
his criminality. In twenty nineteen, Epstein was revealed as having
operated a worldwide sex trafficking operation see Maheta Kajnin. Here's
what to know about the sex trafficking case against Epstein.

(05:51):
The fallout was public and wide ranging, with many high
profile individuals alleged to have participated in Epstein's sex trafficking activities.
On the December twenty seventh, twenty twenty two, the Government
of the United States Virgin Islands filed suit against JP
Morgan Chase in the Southern District of New York, alleging
that JP Morgan Chase profited from Epstein's sex trafficking ring

(06:13):
and failed to report his activities see Government of the
US Virgin Islands versus JP Morgan Chase bank. The JP
Morgan filing included claims that Epstein had deep connections to
the USVII and USVII politicians. The release made national news.
The JP Morgan filing made the following claims about Congresswoman
Plasket One that Epstein supported her for Congress after she

(06:35):
worked for the Vieta, two that he had several individuals
connected to him, donated thirty thousand dollars across three campaigns,
three that she solicited donations from Epstein, and four that
he contributed the maximum amount to her campaigns. The JP
Morgan filing made no other allegations and did not accuse
the congresswoman of knowing complicity in epstein sex trafficking. Here's

(06:58):
the big rub, just to interject, and this is why
it's not a RICO case. If it was a reco case,
then Stacey Plaskett would be caught up. And we know
that their faves can't be caught up, and we know
that this is just backfired on them at this point,
and the boomerang effect is certainly happening. People have a
lot of questions about all these high profile democrats that
were involved with Jeffrey Epstein now, and we have Ted

(07:18):
lud to thank for it, because he had to open
his big mouth. Right, didn't know the first thing about
the first thing, but he had to open his mouth.
So if you want to be mad at anybody, be
mad at him. On November twenty second, twenty twenty three,
Council filed the first complaint in this action. On December thirteenth,
twenty twenty three, Council filed the first amended complaint. The
first amended complaint asserted claims for violations of the Trafficking

(07:41):
Victims Protection Act, aiding and abetting the TVPA, conspiracy to
violate the TVPA, and negligence. The first amended complaint barely
mentioned the congresswoman. It cited just the following facts that
Congresswoman Plasket worked for a law firm used by Epstein,
two that Epstein and his colleagues contributed thirty thousand to
her campaign, three that Congresswoman solicited a donation from Epstein

(08:04):
for the Democratic Congressional Campaign Committee, and four that on
this information and belief, Congresswoman Plasket recommended three hundred million
in tax breaks for Epstein's companies. On March nineteenth, twenty
twenty four, Congresswoman Plasket served a letter on plaintiff's council,
identifying several factual inaccuracies in the first amended complaint and

(08:25):
pointing out that several of the claims were legally frivolous.
The letter warned that should council continue to press the complaint,
the congresswoman would proceed to serve and then file a
rule eleven motion. Plaintiff's council responded right away, indicating that
they would consider withdrawing the allegations against the congresswoman if
given access to her deposition in the JP Morgan action.

(08:46):
That deposition was marked confidential, but the congresswoman's council agreed
to try to get the confidentiality designation lifted. Well, that
should be easy. All she should have to do is
request it. On March twenty eighth, twenty twenty four, congress
Woman Plasket filed her motion to dismiss to comply with
then existing deadlines, further putting plaintiff's councils on notice of

(09:07):
the defects in the first amended complaint. On May thirteenth,
twenty twenty four, just before plaintiff's replies were due, plaintiff's
council filed the second amended complaint. Plaintiff later filed a
corrected second amended complaint that made some substantative changes to
the factual allegations but not the legal claims. Rather than
wait to review the deposition of Congresswoman Plasket and potentially

(09:30):
withdraw the complaint. Plaintiff doubled down with the SAC. The
SAC took the allegations from speculative into pure fantasy. Recognizing
that the first amended complaint contained no facts supporting the
claims against the congresswoman, it appears Plaintiff's council made the
decision to simply make facts up. Many of these facts
are directly controverted by law, regulation, or even a simple

(09:53):
Internet search. The SAC openly accused the congresswoman of taking bribes.
It accused her of using her position and her office
to further a sex trafficking operation. It accused her of
facilitating Epstein's access to victims, and it accused her of
expressly agreeing to join a sex trafficking operation. Far from
correcting factual errors and misstatements from the first amended complaint,

(10:17):
Council mutated them, crossing the line from questionable exaggeration to
outright untruth fiction and misrepresentation. Council withdrew the untenable aiding
and abetting the TVPA account from the first amended complaint,
but replaced it with an equally frivolous civil reco claim.
Council also left in the nonsensical negligence claim from the

(10:37):
first amended complaint, all the while it relied on defamatory
and inflammatory claims that congress Woman plascd was a knowing
participant in Epstein's criminality. The sac violates every precept of
Rule eleven. The outrageous allegations, the baseless legal claims, and
the refusal to correct the affirmative misstatements all demonstrated and

(10:58):
improper purpose. Rule eleven sanctions are now warranted. All right,
We're going to wrap up right here and in the
next episode we're going to pick up with the legal argument.
All of the information that goes with this episode can
be found in the description box. What's up everyone, and
welcome back to the Epstein Chronicles. In this episode, we're
getting right back to Stacey Plaskett and her emotion for

(11:20):
Rule eleven sanctions against the Epstein survivors. The legal argument
Rule eleven exists a curb abuses in the legal system,
and to deter baseless filings Bus Guides Incorporated Versus Chromatic
Commercial Enterprises Incorporated, four ninety eight US five thirty three,
five thirty four, nineteen ninety one, it imposes an affirmative

(11:41):
duty on each attorney to conduct a reasonable inquiry into
the viability of ampleating before it's signed. Dmitri Enterprises Incorporated
versus Spar Insurance Agencyllc. Number twenty one DASH seventeen twenty two,
DASH CV twenty twenty two w L fifty two thirty
seven eight eleve seven at two, Second Circuit, October six,

(12:03):
twenty twenty two. By signing a pleating council certifies that
the pleting is well grounded in the fact n law
and is not bought for an improper purpose. Bus Guides
Incorporated Versus Chromatic Commercial Enterprises Incorporated. Four ninety eight US
five point thirty three five forty two, nineteen ninety one.
In deciding whether the signer of a pleating motion or

(12:25):
other paper is crossed the line between zealous advocacy and
plane pedaphogory, the Court applies an objective standard of reasonableness.
Rule eleven provides for sanctions where an action is bought
for an improper purpose. Rule eleven B one raises claims
that are not warranted by existing law or do not
constitute a non frivolous argument for extending, modifying, reversing, or

(12:48):
establishing law. Rule eleven B two and for making factual
contentions without evidentiary support. Rule eleven B three as concerns
the SAC council violates all three all time. Although some
subsections a Rule eleven also provide for sanctions against a party,
the Congresswoman is not pursuing sanctions against plaintiffs at this time.
A review of the SAC strongly suggests that misrepresentations in

(13:12):
the SAC are council driven and council created. As of
this filing, the Congresswoman seeks sanctions only against plaintiff's council.
A council violated Rule eleven B three by misrepresenting facts
and making inflammatory claims not grounded in fact. Misrepresenting facts
in a pleading violates rule eleven. Park versus Kim ninety

(13:32):
one F four six ten, five, fourteen and fifteen Second
Circuit twenty twenty four. A lawyer also violates rule eleven
by filing a complaint containing vague and implausible allegations which
he or she had to have known were based on
no more than speculation. Goldman versus Barrett, Number fifteen CIV

(13:52):
nine two two three PGG twenty nineteen w L four
five seven two seven two five AT five SDNY, September
twentieth twenty nineteen. Council may not manufacture allegations to put
them in a public court filing without any basis. In
fact O'Rourke Versus Dominion Voting Systems Incorporated. Five point fifty

(14:13):
two Ft. Supp. Three d. Eleven sixty eight twelve oh one, Colorado,
twenty twenty one. Yet this is what happened here. Facts
were misstated to the point of falsehood. Other claims were
simply fabricated with no basis. The SAC repeatedly alleges that
Congresswoman Plasket knew about Epstein's sex trafficking operation and expressly

(14:33):
agreed to join and extend the operation. Council even alleges
at Congresswoman Plasket acted to facilitate Epstein's access to the
plaintiffs and other victims. Plasket entered into an agreement with
Epstein to facilitate the sex trafficking venture to ensure Epstein's clients,
co conspirators, and co defendants had access to victims and

(14:54):
the plaintiffs. The SAC repeatedly alleges that Congresswoman abused or
office to a ad Epstein in exchange for money and influence,
overtly accusing her of accepting bribes. Counsel included no facts
to support these outrageous claims because they do not exist.
No filing, deposition, news article, or any other source of
information supports any of these claims. There's no evidence in

(15:17):
the public record or anywhere else that Congresswoman Plaskett knew
anything about Epstein's sex trafficking, much less he asked her
to do, or that she did anything in furtherance of it.
She asked for money from him after he was already convicted. No,
did he continue abusing girls this whole entire time? Oh
he did right, so again, save the platitudes. Please. The

(15:39):
federal courts cannot tolerate complaints grounded solely in metaphysical inferences,
nor those filed without an informed basis for the allegation.
Murphy versus Cuomo, nine thirteen f. Dot supp. Six seventy
one six eighty three n D n Y, nineteen ninety six,
quoting Keegan Management Company one fifty four Frd two thirty

(16:00):
seven two forty two Northern District of California, nineteen ninety six,
awarding Rule eleven sanctions. See also Goldman versus barrett A,
twenty five f Second Circuit twenty twenty, affirming Rule eleven
sanctions and noting speculation that conversations may have taken place
provides no support for allegations as to the content of

(16:20):
those conversations. Council was aware the first amended complaint was
light on facts, especially after Congresswoman Plasket's council alerted them
to their obligations under Rule eleven. Undaunted by the lack
of actual facts, Council exaggerated or outright misrepresented what little
information they were able to glean from the JP Morgan filing.
For example, paragraph one sixty four and one sixty five

(16:44):
make the repeated claims one sixty four. The ultimate decision
to provide such tax breaks was made by the USVII Governor.
Plaskett was the attorney on the EDC responsible for upon
information and belief, recommending that the EDC provides these benefits
to Epstein and his company's inventure one sixty five. These
tax breaks amounted to three hundred million in direct benefits

(17:05):
to Epstein and his company's inventures. See also sac GC
free DC three hundred million dollars in tax breaks. Despite
being a sex offender defendant. Stacy Plaskett was the attorney
for the usvii's EEDC when it approved over three hundred
million in tax breaks for Epstein's companies. This is not true,
as is clear from a five minute Google search, Epstein's

(17:28):
companies received three hundred million in tax incentives over twenty
years beginning in nineteen ninety nine. Jeffrey Epstein got three
hundred million tax breaks paid US Virgin Islands Police JP Morgan,
says Reuter's June twentieth, twenty twenty three. Epstein's companies were
first approved for ten years of tax incentives starting in
nineteen ninety nine. They were renewed for five year term,

(17:50):
apparently retroactively in twenty twelve. They were renewed again in
twenty thirteen after Congresswoman Plasket had left the Vieta for
another ten year term. Epstein's companies received the vast bulk
of the tax incentives under the nineteen ninety nine approval.
This was not a product of shoddy drafting. It's an
outright misrepresentation. The cornerstone of the sac is the claim

(18:13):
that the congresswoman secured three hundred million in tax incentives
for Epstein to facilitate a sex trafficking in exchange for money, influence,
and a job. All information in the public record establishes
that this claim is affirmatively and provably false. Equally false
is the claim that the congresswoman recommended tax incentives for
Epstein's companies. As the Vieta Statute set out, the General

(18:36):
Council does not make recommendations to the Governor. The Board
of the EDC makes recommendations to the Governor in a
written report after the EDC conducts an investigation and holds
a public hearing. The Chairman of the Board of the
EDC makes those recommendations to the Governor upon a hearing
with the board members, not the General Council. Prefacing the
claim with a blanket on information and belief does not

(18:59):
a council from its obligation not to assert baseless, speculative,
or untrue facts. Fleming versus Port Authority of New York
and New Jersey number twenty one DASH CV DASH one
one one two BMC twenty twenty one, WL eighty seven
eighty five fifty eight at two ed n Y March ninth,
twenty twenty one. Council was aware of these facts. They

(19:22):
were addressed in both the March nineteenth twenty twenty four
letter and the first motion to dismiss. The SAC also
makes the claim that Congresswoman Plasket received regular and routine
payments from Epstein disguised as campaign contributions. There were no
regular payments. The SAC identifies two campaign contributions in twenty sixteen,

(19:43):
one for the primary and one for the general, and
one campaign contribution in twenty eighteen. To say these are
regular and routine payments is at best a wild exaggeration.
Nor did that money go to the congresswoman. It went
to her campaign donations, to which her public record and
accessible on the website of the Federal Election Commission. There
is absolutely no evidence at all to suggest that Epstein

(20:05):
hosted a fundraiser for her, because he did not. Lawyers
may file documents containing inflammatory claims that would be considered
defamatory in any other context without fear of legal retribution
o' rouric versus Dominion Voting Systems Incorporated. Five point fifty
two Ft. Supp. Three d At one two zero four,
Dash zero five. But along with a law license and

(20:27):
the associated privilege to make arguably defamatory allegations in judicial
proceedings comes the sworn obligation of every lawyer as an
officer of the Court, and under Rule eleven, not to
abuse that privilege by making factual allegations without first conducting
a reasonable inquiry into the validity of those allegations. The
false allegations in the SAC are inflammatory and outrageous. Under

(20:52):
any circumstances, they would likely be subject to a defamation suit.
The misconduct permeates the SAC. Congresswoman Plasket has dedicated almost
the entirety of a professional life to public service. The
irresponsible and scurrilous allegations in the SAC obviously made it
bad faith are beyond the PILL. Council had no basis

(21:13):
to include her in this case solely because she worked
for a quasi government organization that gave lawful tax breaks
to Epstein years before sex trafficking was revealed, or because
she received campaign donations as did many other high profile politicians.
The filing of the SAC, even after being advised of
the violation from the first amended complaint, exasperated the misconduct

(21:35):
and is the pinnacle of bad faith. Council may not
damage and to fame the life and reputation of another
person with fabrication and deception in search of a quick
Settlement and Publicity Council violated Rule eleven B three. In
every possible measure, significant sanctions are appropriate. All right, We're
going to wrap up this episode right here, and in

(21:55):
the next episode we're going to pick up with B.
Council violated Rule eleven B two by asserting frivolous and
baseless legal claims. All of the information that goes with
this episode can be found in the description box. What's up, everyone,
and welcome back to the Epstein Chronicles. This episode, we're
getting right back to Stacey Plaskett and her motion for

(22:16):
Rule eleven sanctions against the Legal Council of the Survivors.
B Council violated Rule eleven B two by asserting frivolous
and baseless legal claims. A legal claim is frivolous where
it's not warranted by existing law or by a non
frivolous argument for extending, modifying, or reversing existing law, or

(22:37):
for establishing new law parc. Ninety one Ft. Fourth at
six fourteen. All five causes of action in the sac
are frivolous. One the negligence claim Count five is objectively
nonsensical and lacks any basis of law or fact negligence
derived from centuries of common law arises where there is

(22:57):
one illegal duty of care to the place ninet if
to a breach of that duty of care by the defendant, three,
constituting the factual or legal cause of four damages to
the plaintiff. Robbins versus Port of Sale Incorporated Number st
Dash twelve Dash CV Dash ninety twenty eighteen w L
five zero two four nine two zero at four Virgin

(23:20):
Island Superior Court, October tenth, twenty eighteen. There's no basis
to infer a legal duty of care ode by Congresswoman
Plasket to any of the plaintiffs or any potential class
members under any reading of the SAC. She had no
responsibility as a law enforcement officer, no supervisory responsibility over
any law enforcement and no role directly in the government

(23:41):
of the USVII. The claims of supervisory authority are also
objectively absurd, as has been pointed out to Council in
both the March nineteenth, twenty twenty four letter and the
first motion to dismiss. Among other areas, the SAC alleges
failures to supervise federal agents, United States Eights customs officers,
the United States Coast Guard and deer traffic controllers and

(24:04):
privately employed airline baggage handlers, federal officers or under the
control of their respective federal agencies, not Congresswoman Plasket. Only
the USVII Police are under territorial control, and Congresswoman Plasket
never had supervisory authority over the USVII Police. The negligence
claim is objectively frivolous. Two The civil Rico claims Count

(24:27):
four are objectively frivolous, as the sac fails to meet
even the basic prerequisites of a civil RICO claim. A
civil RICO claim has an almost inevitable stigmatizing effect on
those named as defendants Catsmen versus Victoria's Secret Catalog one
sixty seven FRD six forty nine six fifty nine SDN
Y nineteen ninety six, quoting Figueroa Ruiz versus Algeria eight

(24:51):
ninety six FT two D six forty five six fifty
First Circuit, nineteen ninety Consequently, Rule elevens de turns value
is per particularly important in the RICO context. Its clear
Council did not make any attempt to identify and parts
the elements of a RICO claim as a threshold matter.
Plaintiffs claim only personal injuries. A RICO claim requires an

(25:13):
economic injury as written in the statute. There is no
RICO claim for personal injury. US Code eighteen, Section nineteen
sixty four c. Any person injured in his business or
property by reason of a violation of Section nineteen sixty
two of this chapter may sue. Therefore, R JR. Nibisco
Incorporated Versus Eureka Community, five seventy nine US three twenty

(25:36):
five three fifty twenty sixteen, noting that the Rico private
right of action excludes personal injury claims. Bosconen versus Alaska,
eight seventy four FT three d eight oh six, eight seventeen,
Second Circuit twenty seventeen, noting a plaintiff cannot recover for
personal injuries under Rico. Second. Even the manufactured facts in

(25:57):
the sac do not coalesce into a cognit the bul
Rico claim, as would have been obvious to Council had
they done even the basic research into civil Rico. Most
of the missing elements are the subject of long settled
Supreme Court case law and not even arguably questionable. The
alleged enterprise lacks the basic, long recognized structural features necessary

(26:18):
to establish a Rico enterprise Boil versus United States five
point fifty six US nine thirty eight nine forty six,
two thousand and nine. A Rico enterprise must have at
least three structural features, a purpose, relationships among those associated
with the enterprise, and longevity sufficient to permit these associates
to pursue the enterprise's purpose. Penguin Brothers versus City National Bank,

(26:41):
five eighty seven f dot app x six sixty three
sixty sixty seven, Second Circuit twenty fourteen, noting participants in
Arico enterprise must have a common purpose and intent. Heinrich
versus Dan six fifty five f dot supp Dot three
D one eighty four one ninety sdn Y twenty twenty three.
Courts in the second Circuit look to the hierarchy, organization,

(27:03):
and activities of an association in fact to determine whether
its members function as a unit. The sac also does
not allege an organization distinct from its actors. First Capital
Asset Management Incorporated versus Satinwood three eighty five ft three
d one fifty nine one seventy three, Second Circuit, two
thousand and four, or the alleged predicate Acts United States

(27:25):
versus Turkeit four fifty two US five seventy six, five
eighty three, nineteen eighty one. See also Penguin Brothers, five
eighty seven, Federal Appendix, at six sixty eight. Plaintiff's complaint
gives us no basis for inferring that these two defendants,
in isolation formed an ongoing organization formal or informal, let alone,

(27:46):
a coherent entity, separate and apart from the alleged fraudulent scheme.
To the extent the SAC pleads anything substantative, it pleads
an operation run by Epstein for Epstein. The further Epstein's
goals into which others allegedly can attributed for their own purposes.
Ce Penguin Brothers, five eighty seven f at. Six sixty eight.
Finding no enterprise alleged in part because the complaint failed

(28:09):
to allege the defendants acted on behalf of the enterprise
instead of their own individual self interest, Council cannot make
a plausible claim that Congresswoman Plasket invested in, maintained an
interest in, or participated in any reco enterprise. The SAC
does not identify which RICO subsection it relies on. Problematic

(28:30):
in itself, but it must be Section nineteen sixty two C,
as A and B clearly do not apply. See US
Code eighteen, Section nineteen sixty two A Investing racketeering proceeds
into a racketeering enterprise. US Code eighteen, Section nineteen sixty
two B Acquiring an interest in, an in or control
of a racketeering enterprise. The latest attempt to implicate the

(28:53):
Congresswoman cannot cobble together a remotely plausible claim that Congresswoman
Plasket participated in the opera, ration, or management of the
enterprise itself, a basic long settled element of pleading acclaim
under section nineteen sixty two Reeves versus Ernstein Young five
oh seven US one seventy one eighty five nineteen ninety

(29:13):
three United States Fire Insurance Company versus United Limousine Service Incorporated.
Three zero three f Dot supp two D four thirty
two four fifty one sdn Y two thousand and four.
Noting a rico defendant must do more than merely take
direction or take action that benefits the enterprise. The sac
fails to plead any predicate acts by the Congresswoman, much

(29:35):
less a pattern of racketeering activity consisting of at least
two predicate acts in a ten year period Satinwood, three
eighty five f. Dot three d at one seventy eight.
The SAC fails to plead the elements or even identify
the alleged predicate acts at all. Ce mackin fifty nine f.
Dot supp Three d. At five forty six, noting a

(29:56):
party must plead the elements of the predicate acts at best.
The SAC seems to be groping towards a violation of
the Federal Bribery Statute US Code eighteen, Section two one.
There is a non frivolous basis to assert a violation
of the Federal Bribery Statute in the SAC, not least
because the SAC fails to identify a single actual action

(30:17):
taken by Congresswoman Plasket on behalf of Epstein while she
held federal office. C. Mackin versus Auburger, fifty nine f.
Dot supp three d. Five twenty eight five fifty three
Western District of New York, twenty fourteen, noting that the
Federal Bribery Statute requires action by a federal official. The
SAC also fails to allege the required continuity of a

(30:40):
pattern of racketeering activity Satinwood three eighty five f dot
three d at one eighty. There can be no open
ended continuity. Epstein is dead and there is no threat
of ongoing criminal activity beyond twenty nineteen Seed DeFalco versus
Burness two forty four f dot three D two eighty
six three twenty three Second Circuit to the thousand and one.

(31:01):
To establish open ended continuity, the plaintiff must show that
there was a threat of continuing criminal activity beyond the
period during which the predicated acts were performed. There is
no non frivolous basis to allege close ended continuity, primarily
because the sac fails to allege a series of related
predicated acts extending over a substantial period of time amounting

(31:23):
to continued criminal activity. Finally, Rico conspiracy claim Count number
four is entirely frivolous. The substantative reco claim is frivolous,
so there can be no reco conspiracy without allegations amounting
to a substantative reco offense. Red Rock Sourcing LLC First
JGXLLC Number twenty one CIV ten fifty four JPC twenty

(31:46):
twenty four WL one two four three three two five
at twenty, SDN Y, March twenty second, twenty twenty four. Further,
Council cannot rely on speculative fantasies to allege a non
existent agreement. The SAC contains no substantiative allegation supporting even
an inference of an agreement. The claim is frivolous. Three.

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The claim for obstruction of enforcement of the TVPA Count
three is frivolous because the SAC alleges no action taken
to obstruct any enforcement. There can be no obstruction without
an enforcement effort to obstruct ce do one versus Deutsche Bank,
six seventy one supp. Three D three eighty seven four
oh nine, SDN Y, twenty twenty three, stating the elements

(32:29):
of obstruction the enforcement of the TVPA as one knowledge
of an effort to enforce the TVPA, and two an
intentional action to obstruct or attempt to obstruct enforcement. United
States vers. Agiar five point fifteen US five ninety three,
five ninety nine, nineteen ninety five, holding that obstruction under
US Code eighteen, section fifteen oh three requires intent to

(32:52):
obstruct a judicial preceding. Arthur Anderson, LLP. Versus United States,
five forty four US six ninety six seven ze oh seven,
two thousand and five, holding that obstruction under US Code eighteen,
section fifteen twelve requires a showing that the defendant at
least foresaw a proceeding. The SAC does not even attempt
to allege an effort to impede enforcement of a known effort.

(33:15):
The claim is frivolous. Four Counts one and two, the
SAC asserts claims for violations of the TVPA and conspiracy
to violate the TVPA without factual basis. Counts one and
two purport to allege violations of the TVPA and a
conspiracy to violate the TVPA. Council filed these allegations with
absolutely no factual basis. The SAC is full of offensive

(33:39):
conclusiony claims at Congresswoman Plasket knew of Epstein's sex trafficking
and agreed to facilitate it. Council had no factual basis
to make these claims and no factual basis to allege
a violation of the TVPA or conspiracy to violate the TVPA.
This is a violation of Rule eleven B two and
a dereliction of Council's obligations as a lawyer in fan

(34:00):
Common decency. See Council filed the SAC in bad faith
and with an improper purpose in violational Rule eleven B one.
The circumstances behind the filing of the SAC strongly imply
an improper motive. Council dumped into a public federal corpleting
allegations of a rego conspiracy that are utterly unmerited by

(34:21):
any evidence demonstrating substantial bad faith. O'Rourke versus Dominion Voting System,
five point fifty two supp. Three D eleven sixty eight,
twelve oh five Colorado twenty twenty one in Kunsler nine
fourteen ft two D five oh five five nineteen Fourth Circuit,
nineteen ninety repeated filings, The outrageous nature of the claims made,

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or as signer's experience in a particular area of law
under which baseless claims have been made, are all appropriate
indicators of an improper purpose. The SAC itself is so
baseless as to suggest that there is an ulterior motive
behind the lawsuit. Amen versus Share States Incorporated Numbers twenty
one h CV twenty seven sixty six, js ST twenty

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twenty four, WL one ninety five sixty two thirty seven
at three Eastern District of New York March twenty first,
twenty twenty four. Council actually refiled many of the factual
misstatements and frivolous legal claims from the first amended complaint,
even after being advised they were baseless and probably sanctionable.
Council went further and added an equally deficient and inflammatory

(35:27):
reco allegation c LCS Group LLC Verus shire Llc Number
eighteen SIV to twenty six eighty eight at twenty nineteen
WL one two three four eight four eight at fifteen SDNY,
March twenty nineteen. These are not errors of an inexperienced attorney.
Council here holds themselves out as a very experienced and

(35:49):
well regarded Mister Merson advertises himself as one of the
top lawyers in New York and the United States, according
to the Merson Law website. Mister Murson was named a
time Top one hundred lawyer in New York in twenty
twenty four, was recognized as one of the top two
hundred lawyers in America by Forbes, and was selected by
the New York Law Journal Hall of Fame in twenty fourteen.

(36:11):
Mister Merson appears on at least thirty nine cases in
PACER in this court alone. In this case, however, mister
Merson and his colleagues disregarded their obligations as officers of
the court. Perhaps they believed including the Congresswoman and their
complaint would garner publicity, or that some defendants would put
pressure on other defendants to settle quickly. Perhaps they just

(36:32):
wished to wound for some unknown insidious purpose. Certainly, the
fact that they are using their clients as a conduit
in their effort is reprehensible. Congresswoman Plasket submits that substantial
sanctions are warranted. Conclusion, Council made awful claims in the SAC,
alleging some of the worst forms of criminality based on
nothing but pure invention. It covered the fatal gaps in

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the SAC with figments of their imagination and took extreme
liberties with a few who actual facts they appear to
have gleaned from a single source. Councils simply ignored widely
known facts that controvert the allegations in the SAC. Doing
so not only damages Congresswoman Plascate, but damages the plaintiffs.
They have an obligation to represent They filed the second

(37:17):
amended complaint with no regard for the damage their action
could do or their obligations as officers of the court.
It is clear no reasonable inquiry into either the law
or the facts was undertaken. Sanctions are warranted. This was
signed by Dwayne Morris and it was dated July second,
twenty twenty four. All of the information that goes with

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this episode can be found in the description box.