Mega Edition: Stacey Plaskett Is Ordered To Stand Trial For Her Alleged Role In Epstein's Enterprise (8/22/25)

In a March 2025 ruling, U.S. District Judge Arun Subramanian dismissed nearly all claims against every defendant except Congresswoman Stacey Plaskett, thereby ordering the case to proceed to trial against her in her individual capacity. The court found that Plaskett’s conduct—including soliciting campaign contributions from Jeffrey Epstein at his New York residence, accepting loans and political support, and approving substantial tax breaks for his businesses—created sufficient ties to New York to establish personal jurisdiction under the state's long-arm statute. Consequently, Trafficking Victims Protection Act (TVPA) and negligence claims against her were allowed to move forward, while related claims against other Virgin Islands officials were dismissed on jurisdictional and legal grounds.

The judge also rejected the plaintiffs’ request for jurisdictional discovery, concluding they had failed to make a prima facie showing to justify it. With all other defendants out of the picture, Plaskett stands as the sole defendant facing trial in this high-profile case. The court further invited motions from both sides regarding venue transfers and potential defenses such as immunity, providing a clear path for the next legal phase.


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Episode Transcript

Speaker 1 (00:00):
What's up, everyone, and welcome to another episode of the
Epstein Chronicles. Recently we had some movement in the USVII
when it comes to the lawsuit that was filed by
the Epstein survivors against the government of the USVII, And
in this episode, we're going to take a look at
the order that was passed down by Judge Aaron submarinean

(00:21):
case number twenty three DASH CV DASH one zero three
zero one. Jane does one through six first, the Government
of the United States Virgin Islands, first Lady Cecile DeJong,
Governor Kenneth Mapp, Senator Celestino White, Attorney General Vincent Fraser,
Governor John Dejeong, Senator Carton Dow, Delegate Stacy Flaskett, and

(00:43):
John Doe's one through one hundred. This case arises from
Jeffrey Epstein's notorious sex trafficking enterprise. The complained to alleges
that Epstein brought women to the United States Virgin Islands
to abuse them, and that the defendants, the United States
Virgin Islands and various USVI political figures were complicit in
Epstein sex trafficking. Defendants have moved to dismiss for the

(01:07):
reasons below. All claims other than those against Stacey Plasket
are dismissed. Background. According to the complaint, Jane Does one
through six were coerced into commercial sex acts by Epstein
and his associates. They initiated the lawsuit against the government
of the USVII Cecile Dejeong, Kenneth Mapp, Celestino White, Vincent Fraser,

(01:29):
Jean Dejean, Carlton Dow, Stacey Plaskett, and John doe'es one
through one hundred on November twenty second, twenty twenty three,
alleging that the defendants made the usvi I a safe
haven for Epstein sex trafficking. Defendant USVII is the territorial
government of the United States Virgin Islands. Defendant Cecile DeJong
was the first Lady of the USVII from two thousand

(01:51):
and seven to twenty fifteen, and her spouse, Defendant John Dejeong,
was the Governor of the United States Virgin Islands during
the same period. Defending Kenneth Mapp was the Governor of
the United States Virgin Islands from twenty fifteen to twenty nineteen.
Defendant Vincent Fraser was Attorney General of the United States
Virgin Islands from two thousand and six to twenty fifteen.

(02:14):
Defendant Celestino White and Carlton Doll were both senators in
the US Virgin Islands Legislature, White until twenty thirteen and
Dell from two thousand and one to two thousand and
four and from two thousand and seven to twenty thirteen.
Defendant Stacy Plaskett has been the United States Virgin Islands
Delegate to the United States House of Representatives since twenty fifteen. Previously,

(02:38):
she was general counsel for the Virgin Islands Economic Development Authority.
John Doe's one through one hundred were or are unnamed
employees of the USVII and the federal government. Plaintiffs sue
the individual defendants other than Secialed DeJong and both their
individual and official capacities because they committed the conduct of

(02:59):
alleged here before, during, and or after they left office.
Plaintiff filed the amended complaint on December thirteenth, twenty twenty three,
doc At Number seven, and a second amended complaint SAC
on May twenty fourth, twenty twenty four. The SAC states
that plaintiffs were solicited by Epstein while he was in

(03:20):
New York, transported from New York to the US Virgin Islands,
and held captive and abuse there. Defendants are accused of
facilitating the trafficking of the victims, including plaintiffs, and then
directing the payment of moneys and loans from Epstein's New
York bank accounts to them and or their designees. The
sac lays out defendants alleged roles in the Epstein scheme,

(03:42):
including labeling Epstein as a Tier one sex offender when
he should have been a Tier two, connecting with customs
officials to avoid scrutiny of Epstein's travel, modifying sex trafficking laws,
and arranging visas for young women. It also alleges he
rewards defendants received in including a fifty million dollars loan,
payment of financial obligations, campaign donations, and monthly retainer fees

(04:07):
based on this conduct. Plaintiff alleges that defendants violated the
Trafficking Victims Protection Act, US Code eighteen, Section fifteen ninety one,
and New York tort law legal standards. When faced with
a Rule twelve v two motion to dismiss for lack
of personal jurisdiction, courts construe all pleadings and affid davids
in the light most favorable to the plaintiff, and resolve

(04:30):
all doubts in the plaintiff favor. Penguin Group Usa Versus Buddha,
six poh nine, twenty ten. A plaintiff must make a
prima fossee showing of jurisdiction, including facts that, if credited
by the trier of fact, would suffice to establish jurisdiction
over the defendant. De Lorenzo Ver's Viceroy Hotel Group LLC

(04:51):
seven to fifty seven Second Circuit twenty eighteen conclusiony non
fact specific jurisdictional allegations are insufficient to make such a showing.
To survive a Rule twelve six B motion to dismiss
for failure to state a claim, a complaint must plead
enough facts to state a claim to relief that is
plausible on its face, a claim that has facial plausibility

(05:14):
when the plaintiff pleads factual content that allows the court
to draw the reasonable inference that the defendant is liable
for the misconduct alleged Ashcroft vers Ickbah, two thousand and nine.
A complaint may include conclusions about the law, but these
legal conclusions must be supported by factual allegations the complaints.

(05:34):
Well pleaded factual allegations must be taken true. At this stage.
When there are well pleaded factual allegations, a court should
assume their veracity and then determine whether they plausibly give
rise to an entitlement to relief. Discussion one. Release bars
all claims against Cecial DeJong. Cecile de Jong argues that

(05:54):
any claim against or is barred by the release plaintiff
agreed to in resolving claims against Nstein's estate. Dejen correctly identifies,
and plaintiffs appear to concede that the release language is
so broad that it should be read to include a
release of all claims, regardless of the capacity in which
he's being sued. Docket one twenty two and one at

(06:16):
ten A. The release may be considered on a twelve
B six motion to dismiss. On a motion to dismiss,
a court is typically limited to the complaint attached to
exhibits and documents incorporated in the complaint by reference or
integral to the complaint. See Peter f. Geito Architecture Versus
Simone Development Corporation, twenty ten, quoting McCarthy verus Done and

(06:42):
Bradstreet two thousand and seven, goal verse Bunge, twenty sixteen. But,
as this Court recently explained in another case arising out
of Epstein's sex Trafficking Enterprise, courts may take judicial notice
of an adjudicative fact that is not subject to reasonable
dispute because it can be accurately in a read determined
from sources whose accuracy cannot reasonably be questioned ben Ski Versendyke,

(07:05):
seven forty three, SDNY, twenty twenty four. Just as in Benski,
the release there was not in the complaint attached to it,
mentioning it or relied on by it. But nor do
plaintiffs dispute the release authenticity or that they signed it.
See Docket one forty eight at seventy six through eighty one,

(07:26):
arguing only that defendants do not fall within the language
of the release. So the court may take judicial notice
of the release and consider it on a motion to
dismiss see Benski. See also do Vers Deutsche Bank SDNY
twenty twenty three. Holding when the authenticity of a release
is not disputed and neither party has suggested that extrinsic

(07:48):
evidence would inform the court's interpretation of it. It's appropriately
considered at the motion to dismiss stage Roberts Verus Andrew,
five seventy nine SDNY twenty twenty two. Similarly, holding that
the wording of an agreement is accepted by both parties,
a court can take judicial notice and consider it on
a Rule twelve B six motion to dismiss b. The

(08:11):
release includes claims against Cecile de Jong. There is no
dispute concerning the language of Plaintiff's release. In each of
the plaintiff's settlement agreements, the release states that the claimant
releases and forever discharges any entities or individuals who have,
or ever have been engaged by, employed by, or worked
in any capacity for Jeffrey Epstein or the Epstein Estate

(08:35):
from any in all claims, demands, actions, and causes of action,
whether now existing, hereafter existing, or revived in the future,
including without limitation, any in all claims or causes of
action that arise or may arise from, or which otherwise
concerned acts of sexual abuse or sex trafficking by mister Epstein.

(08:56):
In a supplemental letter submitted at the court's request, plaintiff
appears to conceal need that toe Seal DeJong is covered
by the release. The letter says that the release is
playing terms define releases in the first paragraph, and all
defendants except Seceal DeJong are outside of this definition. This
underscores what the release playing language already makes clear. By

(09:16):
signing the release, plaintiffs of greed to release and forever
discharge any individuals who are or who have ever worked
in any capacity for Jeffrey Epstein from any and all claims.
This language is about as broad and categorical as it
gets Benski seven three, and it conspicuously does not include

(09:37):
any requirement that a release have worked for Epstein for
a specific length of time, or that the release not
have had any other employment while working for Epstein. All
that's needed is that the individual have worked for Epstein
in any capacity, and the sac itself pleads that DeJong
is an individual who worked for Jeffrey Epstein. It states

(09:59):
that if she worked for the Financial Trust Company and
for Southern Trust Company from two thousand to twenty nineteen,
entities in which Epstein conducted business. In addition, plaintiff's opposition
brief describes DeJong as being paid a salary by Epstein
for her office manager work, and refers to her as
his office manager and someone in Epstein's employ taking these

(10:21):
statements as true as the court must on a motion
to dismiss DeJong worked for Epstein and did so for
the entire period at issue in the sac As an
Epstein employee, she, like defendants in Benski, is covered by
the release. This Court's decision in Benski rejected many of
plaintiff's legal arguments for limiting the scope of the release. However,

(10:44):
plaintiffs have suggested that there are factual questions about whether
DeJong was employed by Epstein. Discovery is needed to determine
if DeJong was employed by an Epstein entity. We haven't
seen a W two. I'm all positive that our employment
status was These assertions are difficult to credit when plaintiff's
own complaint and other submissions quoted above describe DeJong as

(11:07):
an Epstein employee see Docket number one, alleging in the
original complaint that de Jong was employed by Epstein as
his office manager. But in any event, the release covers
any individuals who have ever worked in any capacity for
Jeffrey Epstein. That plainly covers DeJong the pleadings and plaintiffs'
arguments make clear that their claims against DeJong have been released.

(11:29):
All right, We're going to wrap up with part one
right here, and in the next episode we're going to
pick up with part two. The court lacks personal jurisdiction
over six of the seven remaining name defendants. All of
the information that goes with this episode can be found
in the description box. What's up, everyone, and welcome to
another episode of the Epstein Chronicles. In this episode, we're

(11:51):
picking right back up where we left off with the
order from Judge Submarinean dismissing the lawsuit in the USVII
against Everyone Buzz Stacey plaskid Part two. This court lacks
personal jurisdiction over six of the seven remaining name defendants.
The remaining defendants move to dismiss this case on personal
jurisdiction grounds. Plaintiff focus their response solely on specific jurisdiction.

(12:16):
To establish specific personal jurisdiction, two questions must be answered
in the affirmative. First, does the state long arm Statute
authorize jurisdiction? And second, does jurisdiction comport with constitutional due
process principles? Spetnervers Palestine Investment Bank seventy f four twenty

(12:36):
twenty three. As to the Long Arm Statute, plaintiff focuses
on the nycpl R Section three H two A one,
which allows a court to exercise personal jurisdiction over any
non domicillary defendant who, in person or through an agent,
transacts any business within the state or contracts anywhere to
supply goods or services in the state. Plaintiffs just that

(13:00):
jurisdiction under section THREEZ two A one is available directly
based on defendants on acts and also through Epstein's acts
based on a conspiracy based theory of jurisdiction. Conspiracy jurisdiction
generally requires that one the defendant had an awareness of
the effects in New York of its activity, two the
activity of the co conspirators in New York was to

(13:22):
the benefit of the out of state conspirators, and three
the co conspirators acting in New York acted at the
direction or under the control, or at the request of,
or on behalf of the out of state defendant. Tar
Savage Versidic three FSupp SDNY twenty fourteen A. A conspiracy

(13:44):
jurisdiction theory is not available under section three O two
a one. Although it appears the New York state courts,
if not weighed in on the precise question directly, numerous
district courts sitting in New York have held that section
three two A one does not provide for a conspirator jurisdiction.
This court, like another court in this circuit, could not

(14:04):
find a single New York State court decision recognizing conspiracy
jurisdiction under section three two A one. See Preswoman twenty
twenty three w L. Two five six two five three
seven at sixteen. The Court is unable to find any
New York case relying on a co conspirator theory to
establish personal jurisdiction under section three two A one, and

(14:28):
plaintiff failed to identify any case, state or federal that
supports conspiracy jurisdiction under three O two A one. In fact,
most of the cases they cite discussed the due process
requirements for conspiracy jurisdiction, not the New York Long Arm Statute.
The New York decisions that come closest to addressing the
question of conspiracy jurisdiction under section three O two A

(14:50):
one are Blue Water Communication Holdings, LLC for Seclstone First
Apartment twenty fourteen, which held that a plaintiff asserting conspiracy
jurisdiction under section three O two A one did not
meet the requirements because the business transactions at issue were
not a tort IDEA two thirty three and thirty four

(15:10):
and FIA Leverage Fund Limited US Grant Thornton, LLP. Fifty six,
twenty seventeen, which entertained the possibility of conspiracy jurisdiction in
a case involving business transactions only because using a New
York bank account for a fraudulent scheme constitutes a tort
within New York. These cases seem to confirm that under

(15:31):
New York law, conspiracy jurisdiction must be tethered to at
committed within the state. That's the province of section three
O two A two, which extends the State Long Armed
Statute to anyone who commits a tortious act within the state.
Or reminder here that plaintiff disavowed Section three O two
A two as a basis for jurisdiction for everyone excepts

(15:53):
to Seal DeJong, against whom all claims I've already been dismissed. Indeed,
when courts sitting in New York recognized conspiracy jurisdiction. It
has almost always been under Section three two A two
see Bangladesh Bank versus Result Banking Corporation, twenty twenty four.
This Court has long recognized that conspiracy is a type

(16:13):
of agency, and that the acts of the co conspirator may,
in an appropriate case, be attributed to a defendant for
the purposes of obtaining personal jurisdiction over that defendant under
CPLR first alteration in original United States versus Busnelli, twenty
eighteen five January sixteenth, twenty eighteen. In cases where courts

(16:35):
have considered conspiracy based jurisdiction over a non domicillary defendant,
jurisdiction over the alleged co conspirator has usually been premised
on three oh two A two. This makes sense. Out
of state parties may be liable for conspiring with an
in state defendant to commit a tourt in the state,
so it's understandable that courts have recognized a complementary theory

(16:57):
of jurisdiction to rope those defendants in But Section three
two a one focuses on business dealings and contracts with
no regard to their lawfulness or on lawfulness where notions
of conspiracy don't easily fit. Of course, Section three zero
two permits plaintiffs to establish jurisdiction over defendants through defendant's

(17:18):
actions in the state or are those done through an agent.
But here plaintiffs don't allege that Epstein acted as the
defendant's agent in transacting any business within the state. If anything,
it's the other way around. The complaint alleges that Epstein
utilizes the defendants as his agents in transacting business in
the Virgin Islands. With no cases or authorities of any

(17:39):
kind recognizing conspiracy jurisdiction in this context, and no convincing
argument for expansion of the doctrine, plaintiffs will have to
establish jurisdiction under section three two A one the old
fashioned way. The Court agrees that many federal decisions concluding
New York law does not support co conspirator jurisdiction under

(18:00):
section three O two A blue Water nine ninety six
at two thirty three and thirty four, rejecting the use
of co conspirator jurisdiction under section three O two A
one because, among other reasons, the purchase of shares was
not a tour Because Plaintiff's council stated at the September
thirtieth Conference that the sole basis for jurisdiction over Carlton

(18:22):
Dow is conspiracy jurisdiction, and the SAC does not allege
that he received any payments from Epstein. The Court does
not have jurisdiction over Dow. B Section three O two
A one does not reach John Dejean, Kenneth Mapp, Celestino White,
Vincent Fraser, or the USVII because conspiracy jurisdiction theory is unavailable.

(18:44):
Under section three oh two A one, the SAC must
plead adequate facts that each defendant, either in person or
through an agent, transacted any business within the state or
contracted anywhere to supply goods or services in the state
nyc PLR Section three oh two A one. Under section
three oh two A one, two requirements must be met. First,

(19:06):
the defendant must have transacted business within the state, and
the second, the claim asserted must arise from the business activity.
One transaction in New York is enough even if the
defendant never enters New York, as long as the defendants'
activities were purposeful. Eads Versus Kennedy PC Law seven ninety
nine f Dot three D one sixty one second Circuit

(19:29):
twenty fifteen, quoting Chloe verse Queen B of Beverly Hills f.
Dot three d twenty ten. Plaintiffs argue that defendants receive
money from Epstein's New York Bank account and therefore transacted
business in New York. They say that receiving a single
payment in another state without maintaining a New York account
gives rise to jurisdiction under section three O two A one.

(19:53):
But in Timothy Coffee Nursery Landscape, Incorporated. Verse Suave seven sixty,
two thousand, nine teen, the Second Circuit held that the
only contact defendants allegedly had with New York is the
use of funds flowing from a New York Bank account
to defendants Canadian bank account, and some communication associated with
these wire transfers. The involvement of New York Bank account

(20:16):
was essentially adventuous and did not constitute transacting business id
at sixty. While Timothy Coffee was a non presidential order,
district courts in this circuit have followed the same approach. Ce.
Johannes Bomgartner versus Salzman, twenty ten three seven eight one

(20:37):
nine seven eight September seventeenth, twenty ten holding that merely
receiving a wire transfer from a New York Bank account
does not subject someone to a personal jurisdiction under section
three H two A one. Landau versus New Horizon Partners,
two thousand and three, wl AT six, SDNY two thousand
and three, holding that argument for jurisdiction based on funds

(21:00):
drawn from New York Bank account had no merit. Lung
Vist versus Rainy, Kelly Campbell, Rolf Young and rubacam SDNY,
October nineteenth, two thousand and one simply stated an agreement
to send payments to New York without more cannot constitute
transacting business under section three H two A one. Plaintiffs
failed to identify a single case in which merely receiving

(21:22):
money from a New York Bank account was considered transacting business.
Every case a site involved something more. C Leachy nine
eighty four two D, holding that a foreign bank's repeated
use of a correspondent account in New York on behalf
of a client was transacting business. Strauss First Credit Leone's

(21:42):
essay EDNY twenty sixteen similar, but defendant had also a
New York branch that was staffed with employees and licensed
to operate under New York banking laws. Scott Nick versus Messina,
Second Department, twenty nineteen, holding that a defendant who had
a New York Bank account and requested that plaintiffs send

(22:03):
money to the New York bank account transacted business First
Manhattan Energy Corporation versus Meyer, First Apartment, twenty seventeen. Defendant
was named in an escrow agreement as a New York
law firm's agent and accepted money as part of that agreement.
The only New York connections alleged for Senator John DeJong,
Matt Fraser, and White are based on Epstein's New York

(22:25):
Bank account. De Jong specifically is alleged to have, along
with his spouse, also solicited loans from Epstein with a
knowledge and intent that the money be transferred from Epstein's
New York bank accounts, and solicited college tuition payments from
Epstein that he knew would come from Epstein's accounts as well.
All defendants, according to the SAC, communicated with Epstein while

(22:48):
Epstein was in New York about payment of money to
them via telephone. As to these defendants, the only contacts
with New York alleged in the SAC are the one
defendants received money from Epstein that they knew was sent
from his New York bank account, and two they communicated
with Epstein about the payments while he was in New York.
This parallels the Facts and Timothy Coffee in other cases

(23:11):
in which courts have declined Section three zero two a
one jurisdiction, where defendants only contact with New York were
payments from New York and related communications. The SAC doesn't
claim that defendants specifically wanted New York money from New
York bank accounts. All they cared about was getting paid,
and the fact that the money was coming from New
York means little Leechy nine eighty four e too d.

(23:35):
At nine hundred plaintiffs have failed to satisfy their burden
of making a prima fosse showing that jurisdiction exists. Holmes
versus Apple Incorporated, seven ninety seven f. Second Circuit, twenty nineteen,
quoting Penguin Groups six poh nine Ft three d. At
thirty four and thirty five. The court also lacks jurisdiction

(23:55):
over the USVII. The SAC alleges at the USVII of
lease solicited and accepted payments for Epstein, including a fifty
million dollar loan that was paid for Epstein's New York
Bank account. Epstein extended the USVII a fifty million dollar
loan paid from a New York bank account. The USVII
denies that such a loan was ever solicited or made,

(24:17):
and says that there is no plausible allegations of the
country docket won fifty eight at nine, But even crediting
plaintiff's claim that the loan was made, a fifty million
dollar loan is not on its own sufficient for long
arm coverage. The SAC doesn't say anything about the loan
other than that it existed, was collateralized by the Islands,

(24:37):
and that it was four fifty million. The SAC includes
no allegations that the alleged solicitation occurred in New York
or that Epstein was in New York when the USVII
asked him for a loan. It says nothing about where
the alleged terms of the loan were negotiated or whether
there was a loan agreement. As with John DeJong, Mapp, Fraser,
and White, the only New York connection pleaded in the

(25:00):
SAC is that the money Epstein allegedly loaned to the
USVII in exchange for facilitating his sex trafficking came from
a New York Bank account. While the USVII allegedly received
more than the other defendants, plaintiffs don't point to a
single case that suggests larger amounts should be treated differently.
In fact, loans in the same ballpark have been held

(25:21):
insufficient to support long arm jurisdiction. See da Wu International
Corporation vers O'Ryan, two thousand and three, SDNY, October twentieth,
two thousand and three, holding that a twenty million dollar
loan was not enough, even though the loan was dispersed
through interest payments made to a New York bank, because
wiring of money is insufficient to establish jurisdiction under New

(25:44):
York's long arm statute. Jean DeJong, Matt Fraser, White, Dal Plasket,
and John Doe's one through one hundred are all sued
in both their individual and official capacities. Ordinarily, a suit
against a state official interofficial capacity is deemed an action
again hence the state itself Williams versus Marinelli, nine eighty seven,
Second Circuit twenty twenty one, and so the personal jurisdiction

(26:07):
contacts of an individual suit in their official capacity should
be incorporated into the personal jurisdiction analysis as to the
government entity itself. See also Kentucky verus Graham, nineteen eighty five.
An official capacity suit is in all respects other than name,
to be treated as a suit against the entity. The

(26:27):
only John Doees the SAC alleges or USVII employees are
John Doees eleven through twenty air traffic controllers, John Doees
twenty through thirty, baggage check agents, John Doees thirty one
through forty USVII police officers, and John Doees forty one
through fifty Coastguard agents. Even assuming that these individuals were

(26:47):
USVII employees, which the USVII strongly contests, none of these
individuals alleged to have had any New York contacts during
part of the period at issue. Plasket was employed by
the the VIEDA, the Virgin Islands Economic Development Authority. Even
if the VIEDA was part of the USVII and Plasket
was a USVII employee from two thousand and seven to

(27:09):
twenty twelve, which is also disputed, the SAC fails to
allege that Plasket had any New York contacts while working
at the VIEDA. It states that Plasket received payments as
early as twenty fourteen, by which time she had already
left VIEDA. It also states that Plasket went to New
York to solicit donations, but for congressional campaigns that occurred

(27:32):
long after her tenure as VIEDA General Council. There is
simply no allegation whatsoever that Plasket transacted business in New
York or in fact, had anything to do with New
York while working at the VIEDA. Other than allegedly granting
tax breaks to Virgin Islands based businesses run by Epstein
and contacts by John DeJong, Matt Fraser, White, and Dal

(27:54):
don't change the analysis either. The most plaintiff say about
USVII is that it or its agents receive funds from
a New York bank account. Under the circumstances alleged here,
that isn't enough to constitute transacting business under New York's
Long Arm Statute. Plaintiffs suggest in the alternative that the
USVII availed itself of the New York courts by suing

(28:17):
JP Morgan and others involved in the sex trafficking venture
to reap one final reward from the very same illegal
venture that it had sustained for years. Plaintiffs don't argue
that the lawsuit constituted transacting business under section three ZHO
two A one, and in any event, contacts that occur
after the cause of action arises are irrelevant. Paterno Vers

(28:40):
Laser Spine Institute and Y twenty fourteen, citing Harlow Verus
Children's Hospital two thousand and five. The JP Morgan lawsuit
was filed in twenty twenty two, and the SAC clearly
states that all causes of action arose from two thousand
and one and continue until twenty nineteen, except for the
causes of action brought under the TVPA and the RICO Act.

(29:04):
The TVPA cause of action ran from two thousand and
three to twenty nineteen, and plaintiffs dropped the RICO claim,
so the JP Morgan lawsuit happened years after the causes
of action arose, and indeed, years after the offending conduct subsided. Further,
the USVII explains that it brought the prior case against
JP Morgan in New York because JP Morgan is headquartered here.

(29:28):
In argument that plaintiffs never addressed it's hard to understand
how a lawsuit could count as relevant jurisdictional contact under
these circumstances. In a supplemental letter, plaintiffs raised a consent
theory of personal jurisdiction for the first time, more than
five months after motion to dismiss briefing concluded. They argue
that the JP. Morgan lawsuit constituted the usvii's consent to

(29:52):
this court's jurisdiction in this action Docket one ninety seven
at two, citing the rules stated in General Contracting and
Raiding Company First Interpol Incorporated, nineteen ninety one. This argument
has long since been waived. In any event, the consent
theory wouldn't apply to the facts of this case. First,
plaintiffs were not parties in the JP Morgan lawsuit in Interpol,

(30:16):
the leading case on the issue. The First Circuit held
that there was personal jurisdiction because the lawsuit arose out
of the same transaction as another lawsuit brought in the
same district by the party challenging jurisdiction. The parties in
both cases were the same. The Ninth Circuit and now
Chemical Company versus Calderon two thousand and five later summarized

(30:37):
Interpol and its progeny as resting primarily on the conclusion
that there is nothing unfair or a volative of due
process about requiring a party that has affirmatively sought the
aid of our courts with regard to a particular transaction
to submit to jurisdiction in the same forum as defendant
with regard to the same transaction and the same party.

(30:58):
While the Second Circuit is not yet endorsed the consent theory,
it recently affirmed the district Court's decision holding that the
rule didn't apply to a case that did not involve
the same parties on both sides as a previous action
VA Collection First Guzini Props. Twenty twenty one, SDN Y
March fifteenth, twenty twenty one, observing that the defendant challenging

(31:19):
jurisdiction did not name the plaintiff as a party in
its previous lawsuit in this district. The USVII su JP. Morgan,
in its twenty twenty two lawsuit in this district, it
did not sue plaintiffs, and, just like the VA here,
plaintiffs attempt to intervene in the previous action was rejected.
There may be a case in which a consent theory

(31:39):
applies outside of litigation between the parties to the first lawsuit,
but especially where the defendants challenging jurisdiction explains why the
first case was filed in New York with no response
from the plaintiff. Holding that the defendant consented to jurisdiction
in the second case is a stretch. All right, We're
going to wrap up right here, and in the next
episode we're going to pick up with c the Court

(32:01):
has personal jurisdiction over Stacey Plasket. All of the information
that goes with this episode can be found in the
description box. What's up, everyone, and welcome to another episode
of the Epstein Chronicles. In this episode, we're getting right
back to the order from Judge Submarinean dismissing the allegations
down in the USVII against all defendants except Stacey Plasket.

(32:25):
See the Court has personal jurisdiction over Stacey Plasket. Plasket
is the last defendant standing, and while she may not
have had any New York contacts while she was acting
in her official capacity as an alleged USVII employee, she
did have sufficient contacts in her individual capacity. Plaskett is
the only defendant that the sac alleges ever traveled to

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New York and the only defendant alleged to have actively
solicited funds from Epstein in New York. CE Dockett, one twelve,
stating that Plasket visited Epstein at his New York mansion
to request political donations and held a fundraiser in New
York and specifically invited Epstein and any of his colleagues.
As plaintiffs argue, the repeated solicitation of donations in New

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York has been enough for transacting business in previous cases
see Sills versus Ronald Reagan Presidential Foundation, Incorporated, two thousand
and nine, SDNY May twenty seventh, two thousand and nine,
holding that the foundation transacted business through its concerted and
purposeful campaign of solicitation of charitable donations. Here, Plaskett traveled

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to New York on multiple occasions to access not only
Epstein but also his wider donor network based in the state.
The touchdown of this analysis is whether a defendant has
deliberately targeted New York to benefit from what this state
has to offer see Timothy Coffee. Jurisdiction is proper only
if the defendant through volitional acts, avails itself of the

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privilege of conducting activities in New York, invoking the benefits
and protection of its laws, quoting Fischburg versus Ducet eight eighty,
two thousand and seven, and Plasket's actions are clearly sufficient
under this standard. Unlike John DeJong, Matt White, Fraser, and
the USVII, who are not alleged to have specifically desired

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New York money from New York bank accounts, the sac
adequately pleads at Plasket traveled to New York and met
with Epstein in hopes of accessing the New York donor market.
Plasket's response quotes a different part of Sills, arguing that
it may not necessarily be the case that a defendant
satisfies section three oh two A anytime it's elicits a

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contribution two thousand and nine WL one four nine zero
eight five to two at eight. This is certainly true,
especially because Section three O two A one has two requirements.
A defendant must transact business, but the claim asserted must
also arise from the business activity. The Second Circuit has
rejected Section three oh two A one jurisdiction when the

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solicitation connection with the alleged wrongdoing is too attenuated. See
Best Van Lines Incorporated versus Walker, four ninety Second Circuit
two thousand and seven, holding that the nexus between allegedly
tortias conduct and the donations defendant solicited is so attenuated
that it cannot be alone be sufficient basis upon which
to establish jurisdiction over the defendant. See also Will versus.

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American University, two thousand and eight, SDN Y January two,
two thousand and eight. No personal jurisdiction Where a plaintive
failed to demonstrate that there is a nexus between the
business transactions and cause of action, What is required is
relatedness between the transaction and the legal claim, such that
the latter is not completely unmoored from the former, regardless

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of the ultimate merits of the claim Leitchi seven point
thirty two at one, sixty eight and sixty nine. In
Plasket's case, the money she solicited for Mepstein in New
York and eventually received is directly related to the alleged
quid pro quo to facilitate Epstein's sex trafficking enterprise. Because
Plasket transacted business in New York and the sac claims

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arise from the business activity long armed jurisdiction under section
three zero two a one has been established at this stage.
See Leachy seven thirty two one sixty eight. As for
constitutional due process, a defendant must have certain minimum contacts
such that the maintenance of the suit does not offend
traditional notions of fair play and substantial justice. First, courts

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decide if minimum contacts exist such that the defendant purposefully
aveiled itself of the privilege of doing business in the
forum and could foresee being held into court there id
at one seventy, quoting Bank Brussels, Lambert first Fiddler Gonzales,
Second Circuit, two thousand and two. Second, if there is
a minimum contact, courts must weigh factors like the burden

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that the exercise of jurisdiction will impose on the defendant,
the interests of the forum state in adjudicating the case,
and plaintiff's interest in obtaining convenient and effective relief to
decide if the assertion of personal jurisdiction would comport with
fair play and substantial justice given Section three two A
one's requirements. However, the Second Circuit expects cases in which

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personal jurisdiction is permitted under the long arm statute, but
prohibited under due process analysis to be rare and unusual. Here,
Plasket purposefully travel to New York on multiple occasions to
avail herself of the New York donor market, including Epstein,
and the benefits of soliciting donations in New York. This

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clearly satisfies the minimum contacts requirement, nor would exercising personal
jurisdiction over Plasket offend traditional notions of fair play and
substantial justice. While Plasket does not live or work in
New York dock at one eighteen at eight, she has
a home in Washington, d c. And will not need
to travel directly from the United States Virgin Islands. Contrary

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to Plasket's assertion that to the extent any forum has
an interest in this litigation, it is the USVII ideat eight.
New York has a strong interest in protecting its citizens
from sexual predators and those who enable them. Plaintiffs were
New York citizens at the time of the alleged wrongdoing
Docket one twelve at twenty four through twenty nine, and

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they were trafficked from New York. Finally, plaintiffs have a
strong interest in convenient and effective relief in New York
d jurisdiction discovery is inappropriate as to the defendants other
than plasket. Defendant suggests that jurisdictional discovery is warranted, but
no motion for jurisdictional discovery was made, Nor have plaintiffs

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explained for any defendant other than Cecil DeJong exactly what
discovery they want or what facts they believe they will uncover.
The Court notes that certain limited discovery has been ongoing
pending the resolution of these motions, and plaintiffs have still
not explained what they might find. Jurisdictional discovery is warranted
if a plaintiff has identified a genuine issue of jurisdictional

(39:07):
fact Wilson and Wilson Holdings Stny, May fifteenth, twenty twenty three,
quoting Davenport SDN Y two thousand and four. But where
a plaintiff fails to establish a prima fosi case for jurisdiction,
a district court may deny jurisdictional discovery. Her Live Ver
Sandal's Resort, Second Circuit twenty nineteen. See also shiad versus Mt.

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Meridia Marguerite shiff Art's six oh four Second Circuit twenty fifteen.
Where plaintiffs do not establish a prima facie case at
the district court as jurisdiction over the defendant. The district
court does not err in denying jurisdictional discovery. Fronterra rez
Iserbaijan Corporation for a State oil Company of the Iserbaijen Republic,

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five eighty two, Second Circuit, two thousand and nine, explaining
that a district court is typically within its discretion to
deny your dictional discovery when the plaintiff is not made
out a prima fossee case for jurisdiction. In this district,
where a plaintiff is not made a primal fossee case
for personal jurisdiction, jurisdictional discovery is generally not granted. Here

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there are no genuine issues of jurisdictional fact. The SAC
falls short of the requisite showing of personal jurisdiction, even
if the court credits the SAC's claims about defendants alleged
contacts with New York. As to the USVII is alleged
fifty million dollar loan, which the USVII denies was ever made.
The Court are you saying there are no such loans?

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Council for the USVII, there was no such loan. There
is no long arm coverage under Section three H two
A one. Even if what plaintiffs say about the loan's
existence is true, nothing in the SAC indicates that there
was a written loan agreement or that the loan was
negotiated in New York. All the SAC says is that
the loan was paid out from a New York bank account,

(40:58):
and it attaches an email chain in which potential collateral
is discussed. Jurisdictional discovery is not designed as a tool
to allow plaintiffs to fish for additional grounds of jurisdiction
that they have not alleged. Plaintiffs shaf First plead legally
sufficient allegations of jurisdiction Universal Trading First, Investment Company Credit
Swiss Guernsey Ltd. Five to sixty f Second Circuit, twenty fourteen,

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plaintiffs have not done so and cannot rely on jurisdictional
discovery to make new allegations that were not in the SAC. Furthermore,
where plaintiffs seek jurisdictional discovery, they have the burden of
demonstrating to the court why jurisdictional discovery is needed see
Haber versus United States, Second Circuit twenty sixteen. If plaintiff

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seeks additional information, they must show that the requested discovery
is likely to produce the facts needed to establish jurisdiction.
See also Home seven ninety seven f at five point sixty.
Jurisdictional discovery is inappropriate where the requesting party has not
shown how the requested discovery would produce facts necessary to

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a stand dismissal. Quoting Haber a twenty three ft three
d at seven fifty three, plaintiffs have not met this burden.
In their opposition brief, they merely say that even if
the court concludes that there are insufficient facts to establish jurisdiction,
jurisdictional discovery is needed. Docket one forty eight one at four.

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Discovery is mentioned at other points in the brief, but
usually referring to non jurisdictional discovery. In a supplemental letter,
plaintiffs say that jurisdictional discovery is a solution where SAC's
allegations plead the requisite facts, but the court finds the
details could be more extensive, and that oral argument on

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the motions to dismiss plaintiffs didn't discuss jurisdictional discovery with
any specificity. Nowhere do plaintiffs explain as to the defendants
other than Cecil DeJong, what jurisdictional discovery they seek, or
how it would support personal jurisdiction. The court rejects plaintiffs
ill explained invitation for a fishing expedition, especially after two

(43:08):
rounds of motions practice, where the defendant's personal jurisdiction arguments
were plainly a focal point. Three. The court rejects Plasket's
other grounds for dismissal. A the SAC provides adequate notice.
Complaints must provide sufficient specificity to the each defendant that's
on notice of the particular claims asserted against it, and

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grounds for such claims. Mid Cap Business Credit SDN Y
July thirty, first, twenty twenty four. If a complaint lumps
all the defendants together in each claim and provides no
factual basis to distinguish their conduct, it may be dismissed.
The SAC does sometimes refer to the defendants as a group,
but it also includes specific allegations against each defendant, such

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that individual defendants are given a sense of what they
are alleged to have done. Plasket is mentioned by name
six times in the SAC, and plaintiffs assert that she
engaged in unique conduct like traveling to New York to
solicit donations, and other defendants did not, and Plaintiff's use
of more general language in parts of the SAC is

(44:14):
not categorically unacceptable at this stage. Rule eight does not
necessarily require that the complaint separate out claims against individual defendants.
B Plasket's other arguments fail at the pleting stage. Plasket
makes brief generalized arguments for dismissal of each of plaintiff's
three TVPA claims against her, saying that plaintiffs have offered

(44:35):
only conclusiony allegations without any well pleated facts in support
Docket one eighteen at eleven to thirteen. Importantly, while the
SAC includes three causes of action under the TVPA, the
civil cause of action in US Code eighteen, section fifteen
ninety five doesn't distinguish between different violations, So if the

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complaint plausibly alleges one violation, the s fifteen ninety five
claims survives, and the court need not address the others
at this time. Bensk. Seven forty three three d at
five ninety nine. Here, the SAC includes plausible allegations at
Plasket violated section fifteen ninety five A when she knowingly
received a financial benefit or something of value from participating

(45:19):
in a venture that she knew or should have known
was a violation of the TVPA. Here, there is no
dispute that Epstein operated a sex trafficking venture that violated
Section fifteen ninety one. As to Plasket's liability under section
fifteen ninety five, the SAC alleges that Plasket received a
position at a law firm affiliated with Epstein's lawyer Keller

(45:40):
Haul's Ferguson and Kroblin, that Epstein made the maximum contributions
to her campaigns, that Epstein hosted a fundraiser for her,
and that Epstein gave her thirty thousand dollars loan In exchange.
The SAC alleges that Plasket approved over three hundred million
in tax breaks for Epstein's companies and used her political
influence as a congresswoman to ensure that Epstein's clients, co conspirators,

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and co defendants travel freely and add access to victims
and plaintiffs. She also allegedly agreed to be Epstein's friend
and knew that her actions were in service of Epstein's
sex trafficking scheme at the time that Plasket agreed to
use her influence as the attorney on the eedc Plasket
knew that she was doing so in order that the

(46:24):
sex trafficking venture would flourish, and when payments were received,
Plasket knew that they were in exchange for her using
her influence to ensure that the sex trafficking venture could continue.
These allegations have not been tested against the evidence, and
the Court credits them solely for the purpose of evaluating
the motion to dismiss, But at this stage the sac

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adequately pleads a violation of Section fifteen ninety five. Plaskett
also argues for a dismissal of the TVPA counts on
limitation grounds. First, she relies on the tvpa's ten year
statute of limitations to urge dismissive of any claims arising
out of alleged arms committed before twenty thirteen. But, as

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this Court stated in Benski, the TVPA involves a continuing tourt,
so a single act occurring within the limitations period will
preserve a claim based on all acts that were part
of the original pattern ed n Y March twenty seventh,
twenty twenty four. Plaintiff's original complaint was filed on November
twenty second, twenty twenty three, and it and the SAC

(47:28):
alleged wrongdoing until twenty nineteen. A motion based on the
Statute of limitations is an affirmative defense and can only
be granted if the defense is apparent on the face
of the complaint Benski, seven forty three at six oh
one and oh two. Given that the SAC alleges wrongdoing
until twenty nineteen, it's not clear from the face of

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the SAC that the defense is meritus. Second, Plasket moves
to dismiss the TVPA claims for violations before two thousand
and three, when the civil right of action was created,
that the SAC clearly states all causes of action arose
from two thousand and one, except for the causes of
action brought under the TVPA, which are claimed to have

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occurred between two thousand and three through twenty nineteen Docket
one twelve at two eight, So there is no real
dispute here. Both Plasket and plaintiffs agree the TVPA claims
begin in two thousand and three. As to the SAC's
negligence claim, Plasket argues that she has no duty to
plaintiffs based on her alleged lack of authority over customs officials,

(48:30):
the coast Guard, air traffic Control, and the police. But
Plasket owed plaintiffs an ordinary duty of reasonable care just
like everyone else in Deutsche Bank. It was enough that
plaintiff's alleged that JP Morgan and Deutsche Bank helped set
in motion Jeffrey Epstein's sex trafficking venture. Here the sac
adequately alleges that Plasket helped facilitate that venture. Plaskett also

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makes the fleeting one sentence argument that plaintiff fails to
allege any injury within two year statute limitations for negligence.
She never mentions it again. Such a single conclusiony one
sentence argument is insufficient to raise an issue. See SOH
Incorporated Versentis Foods, SDNY, November twentieth, twenty fourteen. Issues averted

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to the perfunctory manner, unaccompanied by some effort at developed
argumentation or deemed waived alteration in original quoting Tolbert Verus
Queen's College, two thousand and one, plaintiff claims that equitable
estoppel overcomes any limitation issues here, and there is some
question of what law applies New York's or USBIS to

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the extent that Plaskett believes the negligence claim is plainly
time barred, she may file a renewed application for dismissal
of that claim, hopefully devoting more than one sentence to
the issue. Finally, the Court notes that, in a supplemental
letter sent to the court after her motion to dismiss
was fully briefed and the Court heard argument, Plasket for
the first time, attempted to join the relevant motions of

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other defendants. The key question is whether allowing Plasket to
join will raise any new issues of law or fact
that would prejudice plaintiffs. Perez VARs, City of New York
at five, SDN Y, February twenty ninth, twenty twenty four.
See also Democratic National Committee, First Russian Federation, three ninety
two SDNY, twenty nineteen. Allowing a defendant who had not

(50:24):
otherwise responded to a complaint to join another defendant's motion
to dismiss because there would be no prejudice to that plaintiff. Here,
Plasket identifies two arguments that she would like to adopt,
improper venue and sovereign immunity. Docket one seventy five at five.
The Court rejects Plasket's attempt to join other defendants' arguments
after two rounds of briefing and argument. In this case,

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of course, if Plasket has arguments that she wished to
adopt but failed to do despite two rounds of briefing,
she may raise them in a subsequent application. The court
will consider the timing of the application, the prejudice to plaintiffs,
and the substance of Plasket's arguments in deciding it conclusion
for the reasons above. The motions to dismiss file by

(51:08):
Cecil de Jong the USVII, John Dejean, Kenneth Mapp, Vincent Fraser,
Celestino White, and Carlton Dower granted. All claims against them
are dismissed, including those against Plasket in our official capacity
as an alleged USVII employee. Stacy Plaskett's motion to dismiss
is granted as to the Rico claim, but denied as

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to all other claims. If any party wishes to move
to for transfer to another district in light of the
Court's decision, they should make the appropriate application to the
court within fourteen days. This document was dated March twenty first,
twenty twenty five, and it was signed by Judge Aaron Submaranean.
All of the information that goes with this episode, including

(51:51):
my contact information, can be found in the description box.