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November 29, 2025 25 mins
he document MJ v. Jeffrey Epstein, Case No. 9:10-cv-81111-WPD, filed on September 17, 2010 in the Southern District of Florida, involves a civil lawsuit brought by a plaintiff identified as “MJ” against Jeffrey Epstein. According to publicly available summaries of this and similar filings from the same time period, MJ was a minor at the time of the alleged abuse. The complaint accuses Epstein of sexually abusing and trafficking MJ while exploiting his wealth and power to silence and control her. MJ alleged that Epstein engaged in a pattern of recruiting underage girls under the guise of offering them money for massages, only for the encounters to turn sexually exploitative. The suit contends that Epstein used his Palm Beach residence as a base for this operation and that he was enabled by associates who helped him procure and manipulate the victims.

The complaint further claims that Epstein committed multiple violations of federal and state laws, including sexual battery, intentional infliction of emotional distress, and violations of civil rights statutes protecting minors. MJ's legal team argued that the long-term psychological damage from Epstein’s abuse warranted significant compensatory and punitive damages. The case forms part of a broader group of lawsuits filed by various women against Epstein around that time, many of whom described nearly identical patterns of abuse. These cases contributed to the growing body of evidence surrounding Epstein’s trafficking network long before his 2019 arrest and death.









to contact me:

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source:

gov.uscourts.flsd.365238.1.0.pdf

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Transcript

Episode Transcript

Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:00):
What's up, everyone, and welcome to another episode of the
Epstein Chronicles. Whenever we have a story like this one,
it's easy to get caught up in the day to day,
but when we're talking about Jeffrey Epstein and his criminal enterprise,
we have to understand that this spans back decades and
there are many voices that have never been heard, and
in my opinion, to understand the full scope of the

(00:22):
evil that we're dealing with, you have to dig directly
into the allegations that have been made, and the most
reliable way to do that is to dive into the
core documents. So in this episode, that's what we're gonna do.
We're going to dive into some more core documents, and
this time we're taking a look at the complaint filed
by MJ against Jeffrey Epstein and Sarah Kellen case number

(00:45):
nine ten CV DASH eight one one WPD complaint. Plaintiff
MJ buy And, through her undersigned counsel, sues the defendant,
Jeffrey Epstein and Sarah Kellen and alleges this is an
action in an amount of excess of fifteen million dollars

(01:05):
exclusive of interest and costs, and is within the jurisdiction
limits of this Court. This complaint is brought under a
fictitious name in order to protect the identity of the plaintiff,
because this complaint makes allegations of sensitive nature of offenses
against a then minor child. At all times material to
this cause of action, the plaintiff MJ. Hereinafter referred to

(01:28):
as plaintiff, was a resident of pom Beach County, Florida.
At all times material to this cause of action, Defendant
Jeffrey Epstein had a residence located at three point fifty
eight El Brio Way West, Palm Beach, Palm Beach County, Florida.
Defendant Jeffrey Epstein is currently a citizen of the United
States Virgin Islands. At all times material to this cause

(01:51):
of action, Defendant Jeffrey Epstein was an adult male born
in nineteen fifty three. Defendant Sarah Kellen is currently a
citizen of New York, where she currently resides. At all
times material The defendants Jeffrey Epstein and Sarah Kellen both
out of duty on the plaintiff to treat her in
a non negligent manner and to not commit or conspire

(02:13):
to commit intentional or tortious illegal acts against her. Factual allegations.
At all times material, Defendant Jeffrey Epstein was an adult
male over fifty years old. Defendant Epstein is known as
a billionaire, yet even those closest to him, including family members,
longtime employees, and those that he considers as close as friends,

(02:36):
have no idea what he does or did to earn
money to support his lifestyle. Defendant Epstein owns directly or
through nominy individuals used to conceal his interest, a fleet
of aeroplanes, motor vehicles, boats, and a helicopter. He owns
numerous properties and homes, including a fifty one thousand square

(02:57):
foot mansion in Manhattan, a thirty million, seventy five hundred
acres ranch in New Mexico, a seventy acre private island
formerly known as Little Saint James in Saint Thomas, US
Virgin Islands. He is alleged to have renamed the island
Little Saint Jeff's after himself, a mansion in London, England,
a home in Paris, and a mansion in Palm Beach County, Florida.

(03:22):
The allegations herein primarily concerned the defendant's conduct, while that
is mansion in Palm Beach County, Florida. Defendan Epstein as
a sexual preference and obsession for underage minor females, specifically
targeting female children age twelve to seventeen, and Defendant Epstein
acts on that obsession by luring underage girls to him,

(03:44):
where he attempts to sexually molest and batter these underage
minor females on an everyday basis, oftentimes two or three
different underage minor females on one day. Sometime prior to
ninety eight, Defendan Epstein divides the complex plan, scheme and
criminal enterprise to gain access to countless underage minor females,

(04:05):
some as young as twelve years old, for the purpose
of coercing the minor females into various acts of sexual
misconduct that he committed upon them. His enterprise operated with
a definite hierarchical structure, with his various employees, assistants, and
associates including defendant Sarah Kelln, Jean Luc Brunel, Glene Maxwell,

(04:27):
Leslie Groth, Adriana Ross, Nadia Marsenkova, various housekeepers, butlers, and
pilots performing their respective roles to ensure the goals of
the enterprise operate and organize an efficient system to maximize
the number of underage minor females for Defendant Epstein and
others to sexually abuse and exploit while avoiding law enforcement detection.

(04:51):
And for those of you who might think this is
a hoax, this was filed in twenty ten. Defendant Epstein,
with help from his assistant and associates, recruited and procured
underage minor females, lured them to one of his mansions,
had the underage minor female taken to a room to
be alone with them. Then he would appear naked or
wearing only a towel and sexually batter or otherwise sexually

(05:15):
exploit the underage minor female. He would then pay the
underage minor female for the sex acts he committed against her,
typically between two hundred and three hundred dollars per molestation session,
or as his criminal enterprise commonly refers to it, per massage.
Prior leaving defendin, Epstein's assistant would get the phone number

(05:36):
of the underage minor female and input it into his
computer system or otherwise keep it on file. He would
then offer the underage minor female to return to his
house to make money in exchange for him committing sexual
acts against her, and he also typically informed her of
another option make more money, recruiting and procuring other underage

(05:58):
minor females for him to sexually abuse. He would tell
the underage minor female that he would pay her for
each underage minor female that she brings to him again,
typically between two hundred and three hundred dollars, and he
encouraged and oftentimes forcefully demanded her to bring him as
many underage minor females as she was able. Through this

(06:20):
general pitch, defenden Epstein created a vast pyramid of underage
minor females, recruiting and procuring other underage minor females for
his purpose of coursing these underage females into sexual acts
for money. Defendan Epstein and Kellen and the criminal enterprise
specifically targeted underprivileged and economically disadvantaged children to sexually exploit

(06:43):
and molest and otherwise prey upon their vulnerabilities of these
young girls. It's unknown exactly how long defendan Epstein's aforementioned
criminal enterprise operated, although information and belief indicates that it
was continuously and actively in operation from at least nineteen
ninety eight through Defendan Epstein's criminal arrest in two thousand

(07:05):
and six. The complete list of underage minor females that
were sexually abused by defendant Epstein over the years is
believed to have been kept on a computer system controlled
by defendant Epstein and accessible by several of his employees,
including defendant Sarah Kellen. That's the real list, folks. People
want to talk about the list, the list, the list.

(07:27):
That's the list. Where's that list at? Who has that?
And how come nobody besides Jeffrey Epstein ever was really punished.
That's the real question you should be asking yourselves. Defendant
Kellen was listed in the federal non prosecution agreement related
to Defendan Epstein's criminal plea on sex charges against miners
as a criminal conspirator for her role in the criminal

(07:49):
activity that was committed by defendant Epstein against many underage
minor females. She was employed by defendant Epstein to maintain
his schedule, arrange for under arabisage minor females to be
with defendan Epstein, maintain contact with the underage minor females,
schedule the underage minor females transportation to and from defendin

(08:10):
Epstein's mansion, and greet the underage minor females at the
house before taking her upstairs to be alone with mister Epstein.
Upon information and belief, Defending Kellen remains employed by defendan
Epstein and continues to work for defending Epstein. In furtherance
of the goals of the criminal enterprise, defendin Epstein used

(08:31):
his vast wealth and power to lure underprivileged minor females
to him and to coerce them into prostitution. Once he
was alone with the underage minor female, he sexually, battered, molested,
committed lewd acts upon, and otherwise exploited numerous underage minor females,
and then gave them money. So long as the underage

(08:51):
minor female followed his demands and advances, he assumed the
role of a friend or a mentor or a father
figure to the minor female in an attempt the groom
the minor female. However, if any minor female resisted his
sexual advances, Defending Epstein became frustrated and angry and threatening
towards the underage minor. His intent was to groom each

(09:15):
minor female into engaging in sexual acts with them, as
well as to work for him ie bring him other
underage minor females to sexually molest, batter, and exploit. He
was masterful in his exploitation and grooming of these minor females,
with an additional intent on gaining trust and cooperation from

(09:36):
these miners to prevent any one of them from reporting
his criminal acts to law enforcement. Certain of his many
co conspirator associates, including Glnne Maxwell and Jean Luke Brunell,
helped in this recruiting process by creating the impression that
legitimate modeling opportunities were available to minor females. Through information

(09:57):
and belief, defendan Epstein has been success useful in learning
hundreds of underage minor girls to him for the purpose
of him and sometimes others sexually abusing them. He intentionally
prays upon underage minor females that are in middle school
or high school children who are not working prostitutes, and
he takes pleasure in using his power and influence to

(10:18):
coerce these minor females and to acts of prostitution with
them personally, and sometimes with his friends and associates as well,
including but not limited to, Glenn Maxwell and Nadia marson Kova.
Over time, Defendant Epstein fine tuned his operation to further
his goals of gaining access to a greater number and
variety of underage girls while avoiding detection by law enforcement.

(10:43):
He also provided the roadmap for his enterprise. Should the
illegal sexual exploitation of the enterprise be detected, he or
the criminal enterprise would and did, retain legal representation for
each criminal enterprise member, who would instruct each member to
invoke his or her if the memory and rights. They
would hide behind the Fifth Amendment to avoid turning over

(11:03):
incriminating material ie computer system that logged information about the
underage sexual molestation victims, scheduling books, massage pads, and tangible
items such as vibrators and bildos. They would destroy evidence
and refuse all cooperation with law enforcement. The plan and
scheme was developed by defending Epstein, and he and his

(11:25):
assistants and associates carried it out with each underage minor
female in a well planned and ritualistic manner. Epstein ran
his criminal enterprise as an experienced mob boss would run
any organized crime family in a well planned, organized, arrogant,
and ruthless manner, with complete cooperation from his co conspirator,
associates and underlings, and an absolute dedication to carrying out

(11:50):
the illegal operation of the criminal enterprise. All right, we're
going to wrap up episode one right here and in
the next episode discussing the topic we're going to pick
up with episode two. 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 picking up where we

(12:12):
left off with the lawsuit filed against Epstein by mL
DOE Defendan. Epstein frequently traveled between his various mansions, and
either he or an authorized agent would call to inform
a recruiter, assistant, or scheduler at his next destination of
his arrival time. His scheduler, usually defendant Sarah Kellen, would

(12:34):
then contact an underage minor female and schedule her to
be at defend in Epstein's mansion or to bring another
underage minor female to his mansion at a particular time.
Once the minor female was brought to defend in Epstein's residence.
She was greeted at the door of the mansion and
let inside by one of Epstein's employees, oftentimes defending Sarah Kellen.

(12:59):
Defendant and Sarah Kellen would lead the underage minor female
up to defend in Epstein's room and leave the underage
minor female alone. Defendant Jeffrey Epstein himself would then appear
naked or only wearing a towel. He would then demand
the massage, and during the massage, he would attempt, usually successfully,
to perform one or more lewde sexual acts, including but

(13:22):
not limited to, masturbation, touching the underage minor female, sexual organs,
coercing or forcing the underage minor female to perform sex
acts with them, using vibrators or sexual toys on the
underage minor female, coercing the underage minor female into sexual
intercourse with himself or others, and digitally penetrating the underage

(13:44):
minor female. He would then give the plaintiff money for
engaging in this sexual activity, consistent with Defendant Epstein and
Kellen's foregoing scheme to plan in or around the summer
of two thousand and two. Plaintiff and economically poor and
vulnerable child was told by another one of Epstein's underage

(14:04):
miner's sex abuse victims that she could make three hundred
dollars cash by giving an old man a massage on
Palm Beach. Plaintiff's then minor acquaintance, also a sexual abuse
victim of Epstein, telephone defending Epstein in schedule for plaintiff
to go to defend in Epstein's house to give him
a massage. During that call, defendan Epstein himself got on

(14:27):
the phone and spoke with plaintiff MJ and asked her
personally to come to his mansion in Palm Beach. Plaintiff
then took a taxi cab to defend an Epstein's mansion
and was greeted by Epstein's top assistant defendant, Sarah Kellen.
Defending Kellen, in furtherance of this scheme to exploit plaintiff,
escorted plaintiff to defendin epstein large bathroom, where defending Kellen

(14:52):
set up the massage table and showed plaintiff different massage
lotions to use. Defending Kellen then left plaintiff alone in
the world. Plaintiff was alone in defending Epstein's bathroom until
defending Jeffrey Epstein emerged only wearing a towel. Defending Epstein
then walked to the massage table that was already open
in the room. He lied face down on the table

(15:13):
and told plaintiff to start massaging him, at which time
he engaged in a conversation with plaintiff. During the conversation,
defending Epstein asked plaintiff for age, and she told him
she had recently turned sixteen. Consistent with all of defending
Epstein's known under age minor female victims, plaintiff had no
massage experience whatsoever, and she informed him of that, and

(15:37):
Defending Epstein began instructing plaintiff on how he liked his massage.
After approximately fifteen minutes, defendin Epstein turned over onto his
back and he commanded plaintiff to massage his chest. Defending
Epstein then suddenly removed his towel and his penis was
already erect. He then commanded plaintiff to remove her shirt

(15:58):
a bro and began pinching his nipples as he began
masturbating with his right hand. As he was masturbating, defendant
Epstein began fondling Plaintiff's breasts. Defending Jeffrey Epstein, while masturbating
with his right hand, reached with his left hand and
grabbed plaintiff's vagina and but over her clothes. Plaintiff pushed

(16:18):
defendant's hand away and told him repeatedly not to touch
her like that. Epstein was persistent in his attempt to
grab a plaintiff's vagina and continued to grab her vagina
in but on multiple occasions after she told him not to.
Defendant Epstein continued to masturbate his exposed penis until he
ejaculated in front of the then minor plaintiff. Plaintiff was

(16:42):
shocked and embarrassed by the events, and defendan Epstein talked
to her to persuade her that everything he was doing
was normal. Epstein paid plaintiff three hundred dollars for allowing
him to grope her and masturbate in her presence. Plaintiff
returned to Epstein's home on approximately twenty occasions. On each occasion,
Epstein grabbed Plaintiff's bare breast, exposed his penis, masturbated and

(17:05):
ejaculated in plaintiff's presence, and paid her three hundred dollars
each time. Defend a. Epstein coorse plaintiff into acts of prostitution,
preying on her low economic status and troubled upbringing, complimenting
plaintiff for being special to him and having a very
pretty body, and making promises to plaintiffs, such as he

(17:26):
told plaintiff that if she graduated high school, he would
buy her a computer, something that she wanted yet couldn't afford.
On multiple occasions, defend an, Epstein pressured plaintiff to bring
them other underage minor females to abuse. He told plaintiff
that he would pay her three hundred dollars for each
girl that she brought them, but plaintiff refused to bring

(17:48):
other girls. Defendan Epstein told plaintiff that he would pay
her more money if she would give him oral sex,
and that he would pay her six hundred dollars for
actual sexual intercourse plaintiff if refused. Defendant Epstein personally called
plaintiff at least five times to tell her when she
should be at the house for work or give him

(18:08):
a massage. Epstein's criminal enterprise learned code words for paying
miners for Epstein and others to interact with them sexually
every other time. Approximately fifteen, Defendant Kellen called to inform
plaintiff of the date and time when she needed and
was expected to be at Epstein's mansion to work. The

(18:30):
acts referenced above, committed by defendan Jeffrey Epstein against the
then minor plaintiff, were committed in violation of numerous state
and federal criminal statutes condemning battery, assault, and the exploitation
of minor children, contributing to the delinquency of a minor,
and other crimes, specifically, including but not limited to, those

(18:52):
criminal offenses outlined in chapters seven ninety six, eight hundred
and eight twenty seven of the Florida Statutes, as well
as those designated as in Florida Statutes seven ninety six
dot three, seven ninety six oh seven, seven ninety six
forty five, seven ninety six oh four, seven ninety six

(19:12):
oh nine, thirty nine oh one four fifty dot one
five to one A two seven dot zero four. The
above described acts took place in Palm Beach County, Florida,
at the residence of the defendant, Jeffrey Epstein. Any assertion
by defendant Epstein and Kellen that they were unaware of
the age of the then minor plaintiff, are belied by

(19:35):
their actions and rendered irrelevant by the provisions of applicable
Florida statutes concerning the sexual exploitation and abuse of a
minor child. The defendants, Jeffrey Epstein and Sarah Kellen, at
all times material to this cause of action, knew and
should have known that plaintiff's minority, as plaintiffs specifically told

(19:55):
Epstein her age and defended Epstein and criminal organization had
the history of seeking out under age minor children to
sexually abuse. In fact, one primary goal of the organization
is to sexually abuse females who are under the age
of eighteen, and oftentimes, Defending Epstein has turned away females
i e. Refuse to engage in sexual acts with them

(20:18):
for being too old once she reaches eighteen years of age,
and he has reprimanded girls for bringing them other girls
who are over the age of majority. In June two
thousand and eight, in the fifteenth Judicial Circuit in Palm
Beach County, Florida, Defending Epstein enter please of guilty to
various Florida State crimes related to his exploitation of miners

(20:41):
for sex as a condition of the plea in exchange
for the Federal government entering into a non prosecution agreement
with Defendan Epstein, wherein the Federal government agreed to effectively
stay any prosecution of Jeffrey Epstein, Sarah Kellen, and any
other co conspirators Nadia Marsenkova and Leslie Groff. Defending Epstein

(21:02):
agreed to admit that approximately forty underage minor females whose
names were provided to defendin Epstein were his victims. Plaintiff
was not included in that list, as she moved away
from West Palm Beach area in part to escape from Epstein,
and she has lived in fear of Epstein in his
organization and has not yet been contacted by law enforcement.

(21:25):
Beginning in or about June two thousand and eight and
continuing to the present time, Defending Epstein has been aware
he faces significant financial liability for sexual offenses both to
MJ and to many other similarly situated girls whom he abused.
MJ and these other girls are creditors of Epstein in

(21:46):
that they have filed and can filed toward actions against
them under both Florida and federal laws. Accordingly, Epstein has
conveyed substantial assets and property into the names of other
persons and into overseas bank acou ounts and other financial institutions.
These assets and properties could have been attachable and used

(22:07):
to pay the debts oh to MJ and to the
other girls that Epstein has abused. As an example of
the fraudulent conveyances that Epstein has attempted, in approximately October
two thousand and nine, Epstein placed his personal seven to
twenty seven aircraft up for sale with the intent that
the proceeds of that sale be hidden, so that MJ

(22:27):
and other creditors of Epstein would not be able to
secure a payment from that substantial asset. While Epstein is
clearly distinct from the criminal enterprise that he oversees, that asset,
as well as the other airplanes and helicopters and other assets,
have been used continuously and repeatedly to further the interest
and endeavors of Epstein and his criminal enterprise. As another

(22:51):
example of fraudulent transfers that Epstein has made, Epstein has
titled a Ford one fifty truck in the name of
Larry Vasaski Epstein's personal pilot. Vasaski was unaware that the
truck was titled in his name when he was questioned
under oath in a deposition. In approximately two thousand and nine,
Defended Jeffrey Epstein purchased a sixty eight thousand dollars land

(23:13):
Rover and registered it in Vasoski's name with the intent
to hide his asset from MJ and other creditors. In
approximately two thousand and nine, Defending Epstein purchased the Mercedes
Benz two thousand and five by wiring funds to Vasaski
and then placing the car in Vasoski's name. In approximately

(23:34):
two thousand and nine, Defending Epstein bought a Jaguar X
Type two thousand and five so that he Epstein would
have another car around Palm Beach available for his friends
to use, and then place the car in Vasaski's name.
In approximately September two thousand and nine, Vassoski attempted to
sell a Ferrari owned by Epstein for one hundred and
fifty nine thousand dollars. Epstein intended for the sale to

(23:58):
hide the value of this Ferrari and prevent and other
creditors from recovering from them. Epstein is concealing a substantial
asset through a new corporation, Schmidtge Air Incorporated, whose representative
is Larry Vasoski. In September twenty ten, Epstein attempted to
sell in nineteen ninety nine Bell helicopter for approximately one million,

(24:21):
nine hundred thousand dollars. The sale was an attempt to
prevent MJ and other creditors from recovering from them. Epstein
is also concealing substantial assets through an entity known as
Jege Incorporated. He is currently attempting to sell an aircraft
for ten million through that entity in an attempt to

(24:41):
prevent MJ and other creditors from recovering from them. Through
information and belief, Epstein and or his criminal enterprise provides
the financial support for his various employees, co conspirators, other
criminal enterprise members and associates. In addition to Epstein's various houses,
he owns or controls other condominiums, including approximately eight to

(25:04):
ten units at three ZHO one East sixty sixth Street,
New York City, where certain of his or his criminal
enterprise associates live or reside, including Jean lu Brunel Nadia Marsonkova,
Sarah Kelln, and at times various underage minor girls are
stashed at this location as well. All Right, we're going

(25:24):
to wrap up right there, and in the next episode
dealing with the topic, we're gonna pick up where we
left off. All of the information that goes with this
episode can be found in the description box.
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