Case 1:16-cv-0642 - Doe v. Trump (1:16-cv-04642),
District Court, S.D. New York
DECLARATION IN SUPPORT OF PLAINTIFF'S REQUEST FOR PROTECTIVE
ORDER
I, Jane Doe, the Plaintiff in this matter proceeding under a
pseudonym, state as follows:
1. I am a competent adult over 18 years of age able to testify as
to personal knowledge. The facts in this declaration are true and
correct to the best of my knowledge, information, and belief, and
I am competent to testify to them if called upon to do so.
2. I was subject to extreme sexual and physical abuse by the
Defendants, including forcible rape, that took place at several
parties of Defendant Epstein during the summer of 1994 in New York
City at a residence used by Defendant Epstein. During this period,
I was 13 years old.
3. More particularly, I traveled by bus to New York City in June
1994 in the hope of starting a modeling career. I went to several
modeling agencies but was told that I needed to put together a
modeling portfolio before I would be considered. I then went to
the Port Authority in New York City to start to make my way back
home. There I met a woman who introduced herself to me as Tiffany.
She told me about the parties and said that, if I would join her
at the parties, I would be introduced to people who could get me
into the modeling profession. Tiffany also told me I would be paid
for attending.
4. The parties were held at a New York City residence that was
being used by Defendant Jeffrey Epstein. Each of the parties had
other minor females and a number of guests of Mr. Epstein,
including Defendant Donald Trump at four of the parties I
attended. I understood that both Mr. Trump and Mr. Epstein knew
that I was 13 years old.
5. Defendant Trump had sexual contact with me at four different
parties in the summer of 1994. On the fourth and final sexual
encounter with Defendant Trump, Defendant Trump tied me to a bed,
exposed himself to me, and then proceeded to forcibly rape me.
During the course of this savage sexual attack, I loudly pleaded
with Defendant Trump to stop but he did not. Defendant Trump
responded to my pleas by violently striking me in the face with
his open hand and screaming that he would do whatever he
wanted.
6. Immediately following this rape, Defendant Trump threatened me
that, were I ever to reveal any of the details of Defendant
Trump's sexual and physical abuse of me, my family and I would be
physically harmed if not killed.
7. Defendant Epstein had sexual contact with me at two of the
parties that summer. On the second occasion involving Defendant
Epstein, Defendant Epstein forced himself upon me and proceeded to
rape me anally and vaginally despite my loud pleas to stop.
Defendant Epstein then attempted to strike me about the head with
his closed fists while he angrily screamed at me that he,
Defendant Epstein, should have been the one who took my virginity,
not Defendant Trump, before I finally managed to break away from
Defendant Epstein.
8. Immediately following this rape, just like Defendant Trump,
Defendant Epstein threatened me not to ever reveal any of the
details of Defendant Epstein's sexual and physical abuse of me or
else my family and I would be physically harmed if not killed.
9. Both Defendants had let me know that each was a very wealthy,
powerful man and indicated that they had the power, ability and
means to carry out their threats. Indeed, Defendant Trump stated
that I shouldn't ever say anything if I didn't want to disappeifr
like Maria, a 12-year-old female that was forced to be involved in
the third incident with Defendant Trump and that I had not seen
since that third incident, and ~hat he was capable of having my
whole family killed.
10. The duress imposed on me by Defendants not to ever reveal any
of the details of the sexual and physical abuse caused to me by
Defendants has not terminated and the fear it has instilled in me
has not subsided. Unfortunately, making matters worse for me, I
was subjected to daily painful reminders of the horrific acts of
Defendant Trump via mass media coverage of him starting last
summer that, over a short period of time, became continuous and
unavoidable.
11. The duress had prevented me from starting litigation before
this year. However, as soon as I surfaced, I received threats.
More specifically, shortly after my first complaint was filed in
California on April 26, 2016, I started receiving threatening
phone calls on a cell phone I then owned. The calls were never for
more than 20 seconds or so before they hung up and they were
always from a blocked or unavailable phone number according to my
caller ID feature. Since I changed phone numbers, the threatening
calls have completely stopped.
12. This litigation involves matters that are highly sensitive and
of a personal nature, and I believe that identification of me
would pose a risk of retaliatory physical harm to me and to
others.
13. I have no reason to believe that the Defendants' threats have
ever been lifted or will ever be lifted and so I request that the
Court issue an order protecting me and my family from harm and
harassment by the Defendants.
I declare under penalty of perjury that the foregoing is true
and correct.