• SCE)
IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JANE DOE, proceeding under a
pseudonym,
JEFFREY E. EPSTEIN,
COMPLAINT FOR RAPE, SEXUAL MISCONDUCT, CRIMINAL SEXUAL ACTS,
SEXUAL ABUSE, FORCIBLE TOUCHING, ASSAULT, BATTERY, INTENTIONAL
AND RECKLESS INFLICTION OF EMOTIONAL DISTRESS, DURESS, FALSE
IMPRISONMENT, AND DEFAMATION
Plaintiff Jane Doe, proceeding under a
pseudonym, brings this action against Donald J.
J. Plaintiff is an individual residing in and a citizen of
the State of California.
2. Upon information and belief, Defendants Donald J. Trump and Jeffrey E. Epstein
each
reside in this District and
are citizens of
the State of New York.
IN AND V
3. Plaintiff is a
citizen of
the State of California for purposes of
diversity jurisdiction
4. Defendants are
citizens of
the State of New York for purposes of
diversity
jurisdiction under 28 U.S.C. § 1332.
Case 1:16-cv-07673-RA Document 4 Filed 10/03/16 Page 2 of 10
5. This Court has original subject matter jurisdiction with respect to this action
pursuant to 28 U.S.C. § 1332 as
there exists complete diversity of citizenship between Plaintiff
and Defendants and the amount
in controversy exceeds Seventy Five Thousand Dollars
($75,000.00), exclusive of
interest and costs.
6. Defendants are
each subject to the jurisdiction of
this Court pursuant to 28 U.S.C.
§ 1332 with proper venue pursuant to 28 U.S.C. § 1391 as both defendants are
residents of
and/or are
domiciled in this district and the events giving rise to the claims occurred in this
district.
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