Mega Edition: Danielle Bensky And The Lawsuit Filed Against Indyke And Kahn (Part 9-11) (3/31/26)

What's up everyone and welcome back to the Epstein Chronicles.

In this episode we're getting back to the lawsuit filed by Daniel Bensky and Jando

III against Darren Indyke and Richard Khan.

Defendants failed to act objectively reasonably in failing to take precautions to prevent Epstein's

intentional tortillas conduct and sex trafficking and sex crimes and violation of Chapter 130,

which were committed against Daniel Bensky and Jando III and the class members.

If defendants had acted reasonably to prevent physical harm, they would not have supported

and allowed Epstein's tortillas conduct in sex trafficking and sex crimes to occur.

Defendants owed Daniel Bensky and Jando III and the class members a duty to act objectively

reasonably.

At the time of defendants' own negligent conduct, defendants both realized and should

have realized the likelihood that they were creating an opportunity for Epstein to commit

an intentional tortillas conduct and Chapter 130 crimes against Daniel Bensky and Jando

III and the class members.

Indeed defendants knew that their own conduct was necessary to create Epstein's opportunities

to engage in that conduct and commit those crimes.

Defendants owed Daniel Bensky and Jando III and the class members a duty not to create

those opportunities for Epstein.

Defendants breaches of their legal duties were direct, i.e. the but for cause of physical

and psychological injuries to Daniel Bensky and Jando III and the class members.

Without defendants breaches of legal duties, those injuries would not have occurred.

The injuries that occurred were readily foreseeable to the defendants.

Daniel Bensky and Jando III and the master class members were easily within the zone of

receivable harm from the defendant's negligent acts and omissions.

Defendants negligent acts and omissions for seeably created substantial risk of Jeffrey

Epstein and his co-conspirators committing sex crimes against young women with whom

he was in contact.

Tragically, Daniel Bensky and Jando III and the class members fell within that zone.

Because of defendant's negligent failure to prevent physical harm to Daniel Bensky and

Jando III and the class members, they are liable to Daniel Bensky and Jando III and the

class members for damages suffered as a direct and proximate result.

As a direct and proximate result of defendant's negligent failure to prevent physical harm,

Daniel Bensky and Jando III and the class members, have in the past and will in the future,

continue to suffer substantial damages from psychological and physical injury, including

extreme emotional distress, humiliation, fear, psychological trauma, loss of dignity,

and self-esteem, and invasion of privacy.

Defendants aiding a betting and facilitating Epstein's toward his conduct and sex crimes

in violation of Chapter 130 directly and approximately caused Epstein's sex crimes.

By virtue of acting intentionally, outrageously, and with a high degree of moral turptitude

and demonstrating such wanton dishonesty as to imply a criminal indifference to civil

obligations, defendants are liable to Daniel Bensky and Jando III and the class for punitive

damages.

Count IV.

Participation in a sex trafficking venture in violation of the Trafficking Victims Protection

Act, U.S. Code 18, Section 1591, A.2, 1595.

Plaintiffs Daniel Bensky and Jando III, reallege and incorporate by reference paragraphs

one through 198 as it fully said fourth in this count.

Daniel Bensky and Jando III bring this count individually and on behalf of the other class

members, they respectfully seek to represent.

Defendants knowingly and intentionally benefited financially and receiving things of value

from participating in, assisting, supporting, and facilitating and illegal coercive sex

trafficking venture, that was in and affecting interstate and foreign commerce together

with others in violation of U.S. Code Section 18, 1591, A.2.

Defendants took many concrete steps to aid and participate in Epstein's sex trafficking

venture.

Among the concrete steps that the defendants took to aid Epstein was providing legal accountants

services and business-related services and support, which made the sex trafficking

venture possible.

Defendants willingness to provide their legal, accounting, and business services was a

quid pro quo for them, receiving financial benefits from Epstein.

The services that the defendants provided was necessary for Epstein to the chorus Daniel

Bensky and Jando III, as well as other class members to engage in commercial sex acts,

the services directly formed part of the commercial nature of the sex acts.

The services were also necessary and required part of Epstein's recruitment of Daniel Bensky

and Jando III and other victims of his sex trafficking venture.

By providing legal, accounting, and business services, that the defendants knew would be

used to facilitate the sex trafficking venture, defendants actively participated in the recruitment

of victims of the venture.

The services that defendants provided went far beyond providing routine legal, accounting

and business services for a client.

This providing services like, for example, assisting in creating sham marriages, creating

sham companies to hide cash for the trafficking, assisting with withdrawal of large sums of

cash to facilitate the trafficking, and arranging payments for tuition for young girls all were

entirely inconsistent with the ordinary duties of a lawyer and an accountant.

The reason the defendants ignored the trafficking conduct was to receive financial benefits from

Epstein and his sex trafficking venture.

In concrete steps, the defendants took to aid and participate in the Epstein sex trafficking

venture, were opening numerous bank accounts and entities for Epstein, his related entities

and associates.

By opening these accounts and entities, defendants received many benefits from participating in

Epstein's venture.

The opening of these accounts and entities was affirmative conduct that caused defendants

to receive those benefits.

By taking the concrete steps outlined above, along with the other alleged in this complaint,

defendants knowingly participated in sex trafficking and further the Epstein sex trafficking

venture.

The concrete steps, above constituted taking part in the sex trafficking venture and were

necessary for its success.

The concrete steps, above constituted active engagement, by defendants in Epstein sex

trafficking venture.

Defendants knowingly and intentionally benefited financially from and received value for their

participation in the sex trafficking venture, in which Epstein, with defendants knowledge,

or its reckless disregard of the fact, that Epstein would use the means of force, threats

of force, fraud, coercion, and a combination of such means to cause Danielle Bensky and

Jane Doe III, as well as other class members, some of whom, or under the age of 18, to engage

in commercial sex acts.

Defendants knew, and were in reckless disregard of the fact, that it was Epstein's pattern

in practice to use the channels and instrumentalities of interstate and foreign commerce, to

entice recruits, solicit, harbor, provide, obtain, and transport young women, and underage

girls for purpose, of causing commercial sex acts and violation of U.S. Code section

18, 1591, A&1.

Despite such knowledge, defendants intentionally paid for, facilitated, and participated in

Epstein's violations of U.S. Code 18, section 1591, A, which defendants knew, and were

in reckless disregard of the fact, that Epstein would cause, defraud, and force, Danielle

Bensky and Jane Doe III, as well as other class members, to engage in commercial sex

acts.

Defendants affirmative conduct was committed knowingly, and in reckless disregard of the facts, that

Epstein would use cash procured by defendants, legal and accounting advice provided by defendants,

and other support provided by defendants, as a means of defrauding, forcing and coercing

sex acts from Danielle Bensky and Jane Doe III, as well as other class members.

Defendants conduct was outrageous and intentional.

In addition to actual knowledge that they were participating in and facilitating the Epstein

Sex Trafficking Venture, defendants also should have known that they were participating

in and facilitating a venture that had engaged in coercive sex trafficking, as covered by U.S.

Code 18, section 1595A.

Defendants knowing and intentional conduct is caused Danielle Bensky and Jane Doe III,

and other class members, serious harm, including without limitation, physical, psychological,

emotional, financial, and reputational harm.

Defendants knowing and intentional conduct is caused Danielle Bensky and Jane Doe III,

and other class members, harm that is sufficiently serious, under all the surrounding circumstances

to compel a reasonable person of the same background and, in the same circumstances,

to perform or continue performing commercial sexual activity in order to avoid incurring

that harm.

This case does not involve mere fraud, instead defendants' criminal conduct in violating

the TVPA was outrageous and intentional because it was in deliberate furtherance of a widespread

and dangerous criminal sex trafficking organization.

Defendants' criminal conduct also events the high degree of moral turptitude and demonstrated

such wanton dishonesty as to imply a criminal indifference to civil obligations.

Defendants' criminal conduct was directed specifically at Danielle Bensky, and Jane Doe III,

and other members of the class who were the victims of Epstein's sexual abuse and sex

trafficking organization.

Defendants outrageous and intentional conduct in this case is part of a pattern and practice

of defendants' profiting by undertaking illegal, high-risk, high-reward clients.

By virtue of these knowing and intentional violations of U.S. Code 18, Section 1591-A&2,

1595, defendants are liable to Danielle Bensky and Jane Doe III, and the class for the

damages they sustained and reasonable attorney fees.

By virtue of these intentional and outrageous violations of U.S. Code 18, Section 1591-A&2

1595, defendants are liable to Danielle Bensky and Jane Doe III, and the class for

punitive damages.

Alright, we're going to wrap up here and in the next episode we're going to pick up

with Count 5.

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 going to pick up where we left off with the Danielle Bensky and Jane

Doe III lawsuit that was filed against Darren Indyke and Richard Kahn.

Count number five, obstruction of the enforcement of the Trafficking Victim Protection Act,

U.S. Code 18, Section 1591-D.

Plaintiff Danielle Bensky and Jane Doe III re-elegiate and incorporate by reference paragraphs

1 through 198 as it fully said fourth in this count.

Danielle Bensky and Jane Doe III bring this count individually and on behalf of the other

class members they respectively seek to represent.

Defendants knowingly and intentionally obstructed, attempted to obstruct, interfered with, and

prevented the enforcement of U.S. Code Section 18, 1591-A1 and A2 all in violation of U.S.

Code Section 18, 1591-D.

This activity is here and after referred to collectively simply as obstruction.

Defendants obstruction of the enforcement of U.S. Code 18, Section 1591-A1 and A2 was

forbidden by U.S. Code 18, Section 1591-D and defendants thereby violated Chapter 77,

Title 18.

Defendants obstruction described here and in the preceding paragraph directly, approximately

and forcibly harmed Danielle Bensky and Jane Doe III as well as other members of the

class by directly resulting in them coercively being caused to engage in commercial sex

acts and in other ways.

As outlined above the United States Department of Justice including the U.S. Attorney's Office

for the Southern District of New York and the U.S. Attorney's Office for the Southern

District of Florida was investigating Epstein's federal criminal liability for violating

among other laws, the TVPA, up to and following the return of an indictment against Epstein

honor about July 8th, 2019.

Honor about that date the U.S. Attorney's Office for the Southern District of New York

indicted Epstein and unnamed associates for violating the TVPA.

Later on about June 29th, 2020, the same office indicted Epstein's co-conspirator Golan Maxwell

for conspiracy to entice minor victims to travel to be abused by Epstein.

The federal criminal investigation of Maxwell included investigation of possible violations

of the TVPA.

Defendants obstructed, interfered with and prevented the federal government's enforcement

of the TVPA against Epstein to the extent that the federal government was able to ultimately

charge Epstein with TVPA violations, the filing of those charges was delayed by defendant's

actions.

Because of that delay, Benzky and Jane Doe III as well as other members of the class

were coercively caused to engage in commercial sex acts.

As one example of how defendants obstructed, attempted to obstruct, interfered with and

prevented the federal government's enforcement of the TVPA, defendants structured with

jaws of large amounts of cash to Epstein and his associates, so that the coercive commercial

sex acts would escape the detection of federal law enforcement and prosecuting agencies.

Defendants provided large amounts of cash to further the Epstein's ex-trafficking venture,

and with the purpose of helping Epstein evade criminal liability for violating the TVPA.

By procuring large amounts of cash to Epstein and his associates, defendants, intended and

knew that Epstein's coercive commercial sex acts would escape the detection of federal

law enforcement and prosecuting agencies for some period of time.

Defendants provided large amounts of cash to further the Epstein's ex-trafficking venture,

and with the purpose of helping Epstein evade criminal liability for violating the TVPA.

As another example, defendants provided legal and accounting advice that created chat

marriages and corporate structures that helped Epstein escape scrutiny.

Well, for defendants' egregious creative assistance of Epstein, he would not have been

able to escape detection liability for violating the TVPA.

Defendants obstruction, attempted obstruction, interference with, and prevention of the enforcement

of the TVPA were all done intentionally and knowingly.

For example, defendants helped Epstein set up the butterfly trust to facilitate his

abuse of women from Eastern Europe, specifically to escape the increased scrutiny Epstein faced

for U.S.-based victims after his previous arrest and conviction, which made Epstein a

high risk to violate the TVPA through continuing criminal sex trafficking activities.

Defendants were well aware that Epstein pleaded guilty and served prison time for engaging

in sex with a minor, a crime closely connected with sex trafficking and violation of the TVPA.

Defendants were also well aware that there were public allegations that as illegal conduct

was facilitated by several named co-conspirators.

Defendants continued their affirmative conduct supporting the Epstein's ex-trafficking venture

to continue receiving personal financial enrichment.

Defendants' intentional conduct obstructed, attempted to obstruct, in many ways and

referred with, and prevented the enforcement of the TVPA by federal investigators and

prosecuting agencies.

Defendants' obstruction of the federal government's TVPA and other law enforcement efforts was

intentional and willful, and therefore defendants intentionally and willfully caused Epstein's

commission of the Forcible Commercial Sex Acts, with Daniel Bansky and Jane Doe III and

other class members through its obstruction supporting the concealment of the Epstein

Trafficking Venture.

Defendants knew that Epstein and his other co-conspirators would use means of force, threats

of force, fraud, coercion, and a combination of such means to cause Daniel Bansky and Jane

Doe III and class members to engage in commercial sex acts.

Defendants knew, acted in reckless disregard of the fact, and should have known that their

obstruction and violation of U.S. Code Section 18, 1591D, would directly and proximately lead

to unlawful coercive commercial sex acts by Epstein, with young women and girls, including

Daniel Bansky and Jane Doe III and other class members.

Defendants' obstruction is caused Daniel Bansky and Jane Doe III and other class members

serious harm, including without limitation, physical, psychological, financial, and reputational

harm.

The harm was directly and proximately caused by the obstruction and the harm resulting

from obstruction.

That was foreseeable.

Defendants' obstruction is caused Daniel Bansky and Jane Doe III, harm that is sufficiently

serious under all the surrounding circumstances to compel a reasonable person of the same background

and in the same circumstances to perform or to continue performing commercial sexual activity

in order to avoid incurring that harm.

This case does not involve mere fraud, instead defendants, criminal, conduct, and obstructing

enforcement of the TVPA was outrageous and intentional because it was deliberate furtherance

of a widespread and dangerous criminal, sex trafficking organization.

Defendants' obstruction also events the high degree of moral turptitude and demonstrated

such wanton dishonesty as to imply a criminal indifference to civil obligations.

Defendants' obstruction was directed specifically at Daniel Bansky and Jane Doe III and other

members of the class who were the victims of Epstein Sex Trafficking Organization.

By virtue of these violations, the U.S. Code 18 Section 1591-D, defendants are liable

to Daniel Bansky and Jane Doe III and the class for damages they sustained and reasonable

attorney fees by operation of U.S. Code Section 181595.

Defendants perpetrated an obstruction of the TVPA and therefore perpetrated a violation

of Chapter 77, Title 18.

By virtue of its intentional and outrageous obstruction to prevent enforcement of the TVPA

and violation of U.S. Code 18 Section 1591-D, defendants are liable to Daniel Bansky and

Jane Doe III and the class for punitive damages by operation of U.S. Code 18 Section 1595.

On 6, conspiracy to commit violations of the Trafficking Victim Protection Act, U.S.

Code 18, Section 1594-C, 1591, and 1595.

Plaintiff Daniel Bansky and Jane Doe III reallege an Incorporate by reference paragraphs

1 through 198 as if fully said fourth in this count.

Daniel Bansky and Jane Doe III bring this count individually and on behalf of the other

class members they respectively seek to represent.

This intentionally conspired with others by agreement and understanding the violate

U.S. Code Section 181591-A1 and A2 and 1591-D and the further Epstein and his co-conspirators

sex trafficking venture to coerce commercial sex acts from Daniel Bansky and Jane Doe

III and other class members all in violation of U.S. Code 18 Section 1594-C.

Defendants directly conspired with Epstein himself to further the sex trafficking venture.

Defendants conspiracy to violate U.S. Code 18, Section 1591-A1 and A2 was forbidden

by U.S. Code 18, Section 1594-C and defendants thereby violated Chapter 77, Title 18.

Defendants conspiracy directly, approximately and forcibly harmed Daniel Bansky and Jane

Doe III as well as other members of the class by directly leading to their forcibly

being caused to engage in commercial sex acts and in other ways.

Defendants conspiracy victimized Daniel Bansky and Jane Doe III and the other members

of the class.

Defendants conspiracy to violate U.S. Code 18, 1591-D was forbidden by U.S. Code 18, Section

1594-C thereby violated Chapter 77, Title 18.

Defendants conspiracy directly, approximately and forcibly harmed Daniel Bansky and Jane

Doe III as well as other members of the class by directly leading to their forcibly

being caused to engage in commercial sex acts and in other ways.

Defendants conspiracy victimized Daniel Bansky and Jane Doe III and other members of the

class.

Defendants conspired with Epstein and his co-conspirators to further the Epstein sex trafficking venture

and with the purpose of facilitating Epstein's illegal sex trafficking.

Defendants had actual knowledge of Epstein sex trafficking venture.

Defendants acted with the specific intent to violate U.S. Code 18, Section 1591-A1-N-A2.

That is, the consciousness of the nature of Epstein's sex trafficking venture and with

the specific intent to further the venture.

Defendants and Epstein had a meeting of the minds as to the essential nature of the plan.

The Epstein's sex trafficking conspirators had a shared and common purpose securing young

women and girls for Epstein to sexually abuse and to commercially sex traffic.

Defendants and other members of Epstein's sex trafficking venture associated together

for this common purpose.

As Quid Pro quo, in exchange for working towards this common purpose, Epstein rewarded

defendants.

The Epstein's sex trafficking conspiracy was an ongoing organization with the same hierarchy

and regularity of function.

Epstein was at the top of the hierarchy and effectively served as the CEO of the organization.

An in-dike served as Epstein's personal lawyer and accountant, handling all of Epstein's

personal affairs and business operations relating to his sex trafficking organization.

Defendant Khan was Epstein's personal accountant who handled all of his personal accounting

and financial services relating to the organization.

The sex trafficking conspiracy was itself in and affecting interstate and foreign commerce

and involved overt acts that were in and affecting interstate and foreign commerce.

So we're going to wrap this episode up right here and in the next episode we're going

to pick up where we left off and that's with in or around 1995.

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 picking up where we left off with the Danielle Bensky and Jane

Doe 3 lawsuit that was filed against Darren Indyke and Richard Khan.

Other actions regarding defendants' conspiracy to obstruct TVPA enforcement are outlined

in Count 5.

Within this district, defendants intentionally committed overt acts and furtherance of

the conspiracy, agreement and understanding the Violet U.S. Code 18, Section 1591A.

By knowingly playing an act of role in assisting supporting and facilitating the recruiting,

enticing, coercing, harboring, transporting and inducing and forcibly causing Danielle

Bensky and Jane Doe 3 and other class members to engage in commercial sex acts through

providing financial support for the Epstein sex trafficking venture.

Among the many overt acts intentionally committed by defendants and furtherance of the long-running

Epstein sex trafficking venture were providing the financial underpinnings for Epstein to

have ready and reliable access to resources including cash to recruit, lure, coerce and

entice young women and girls to cause them to engage in commercial sex acts and other

degradations within the district.

Indeed, the defendants organized, controlled and directed almost every aspect of the Epstein

sex trafficking venture, defendants approved and enabled and justified millions of dollars

in payments that fuel the Epstein sex trafficking venture, including payments to women who

are forced to have sex with Epstein and or recruited by others to be victimized.

Defending within this district and in furtherance of the Epstein sex trafficking venture, defendants

facilitated arranging sham marriages to keep Epstein victims available for his ongoing abuse.

As officers and signatories of the key entities in the Epstein sex trafficking enterprise, defendants

facilitated cash payments for immigration legal fees and recruitment compensation.

In furtherance of the Epstein sex trafficking venture, defendants were officers and virtually

every corporate entity that Epstein created to fund and conceal his activities.

They were deeply involved in the financial activities of Epstein and the entities.

In addition to being officer and directors of companies implicated in the Epstein sex

trafficking enterprise, defendants at least one of them but often both also had signatory

authority over virtually all of the accounts held by Epstein, which allowed them to personally

authorize the sign-off on payments, totaling hundreds of thousands of dollars to Epstein's

victims, including but not limited to recruiting compensation, legal fees, apartment rent,

and tuition.

In furtherance of the Epstein sex trafficking venture, defendants routinely withdrew cash

from Epstein's accounts in various ways, including ATMs, checks or by converting currency.

In many instances, defendants structured these transactions to evade banking reporting

requirements.

Defendants also worked together to make large cash withdrawals.

Even after Epstein died, defendants have continued to enrich themselves for their participation

in the Epstein sex trafficking conspiracy, having approved the release of Epstein's estate

funds through their role as executors to pay their legal fees and costs.

Defendants actions in furtherance of Epstein's conspiracy were intertwined with Epstein's

sex trafficking venture as the funding of the sex trafficking venture and particularly

cash for the venture were essential tools for Epstein to commit coercive commercial

sex acts.

It was part of the conspiracy that defendants would financially benefit from providing financial

support for the Epstein sex trafficking venture.

Defendants did financially benefit from its participation in the venture, including receiving

millions of dollars in compensation for their legal, accounting, business, and other services.

Defendants were paid through multiple entities, including but not limited to HBRK associates,

CO2, Enterprises, Birch Tree, BRLLC, Harlequin Dane, and Darren Kayn Dyke PLLC.

Defendants' participation in furthering Epstein's sex trafficking venture was intentional

and willful and therefore defendants intentionally and willfully caused Epstein's commission

of the forcible commercial sex acts with Danielle Bensky and Jane Doe 3 and the other

class members through its affirmative and overt acts of supporting Epstein.

Defendants knew, acted in reckless disregard of the fact, and should have known that its

conspiracy would directly and approximately lead to unlawful coercive commercial sex

acts by Epstein with young women and girls, including Danielle Bensky and Jane Doe 3 and

other class members.

The conspiracy that Defendants joined had specific knowledge that Danielle Bensky and Jane Doe 3,

as well as other class members were being coercively sex trafficked by Epstein.

The conspiracy's knowledge extended to the names of Epstein's victims because Epstein

and his co-conspirators knew the names of the victims.

Defendants conspired to violate U.S. Code 18 Section 1591A with Epstein and through its

affirmative acts and substantial support to Epstein committed, perpetrated, and directly

and approximately caused Danielle Bensky and Jane Doe 3 and other class members to engage

in commercial sex acts through a means of force, threats of force, fraud, coercion, and

a combination of such means.

In addition to acting with knowledge that they were conspiring to support the Epstein

sex trafficking venture, Defendants benefited financially from conspiring to participate

in the Epstein sex trafficking venture, which Defendants knew or should have known that

had engaged in coercive sex trafficking and violation of U.S. Code 18, Section 1591A,

1, and A2.

Defendants' conspiracy has caused Danielle Bensky and Jane Doe 3 and other class members

serious harm, including without limitation, physical, psychological, financial, and reputational

harm.

That harm was directly and approximately caused by the conspiracy and the harm resulting

from conspiracy was foreseeable.

This conspiracy has caused Danielle Bensky and Jane Doe 3 harm that is sufficiently serious

under all the surrounding circumstances to compel a reasonable person of the same background

and in the same circumstances to perform or to continue performing commercial sexual activity

in order to avoid incurring that harm.

This case does not involve mere fraud, instead, Defendants' criminal conduct and conspiring

to violate the TVPA was outrageous and intentional, because it was in the deliberate further

incidence of a widespread and dangerous criminal sex trafficking organization.

Defendants' conspiracy also evins the high degree of moral turptitude and demonstrated such

wanting dishonesty as to imply a criminal indifference to civil obligations.

Defendants' conspiracy was directed specifically at Danielle Bensky and Jane Doe 3 and other

class members who were the victims of Epstein's sex trafficking organization.

By virtue of these violations of U.S. Code 18, Section 1594C, Defendants are liable

to Danielle Bensky and Jane Doe 3 and the other class members for damages they sustained

and reasonable attorney fees.

By virtue of its intentional and outrageous conspiracy to violate U.S. Code 18, Section 1594C,

1595, Defendants are liable to Danielle Bensky and Jane Doe 3 and other class members

for punitive damages.

Count 7, Gender Motivated Violence Protection Act, Administrative Code of the City of New

York, Section 10, Dash 1101, Plaintiff Danielle Bensky and Jane Doe 3, Reallege and Incorporate

by a reference paragraphs 1 through 198, as it fully said fourth in this count.

The above described conduct of Defendants constitutes a crime of violence and a crime

of violence motivated by gender and the act against Danielle Bensky and Jane Doe 3 and

other class members as defined by New York City Gender Motivated Violence Protection

Act and Y.C. Admin Code, Section 8-903, 2017.

The above described conduct of Defendants constitutes a crime of violence against Danielle

Bensky and Jane Doe 3 and other class members motivated one by gender, two on the basis of

gender and or three do at least in part to an animus based on gender. Defendants committed

a crime of violence against Danielle Bensky and Jane Doe 3 and other class members because

they are women and at least in part because defendants willingly participated enabled

and conspired in the Epstein Enterprise and a legal operation steeped an unlawful animus

towards women and engaged in violent sexual acts against Bensky. Jane Doe 3 and the class

in New York including but not limited to rape, forced oral sex, digital penetration,

enforceable touching and sex trafficking. Defendants conduct as part of the Epstein Enterprise show

their gender-motivated animus towards women as they knowingly, individually and personally

facilitated a decades-long international sex trafficking operation. As a direct and

proximate result of the aforementioned gender-motivated violence, Danielle Bensky and Jane Doe 3

and the other class members have sustained in the past and will continue to sustain monetary

damages, physical damages, pain and suffering, and serious psychological and emotional distress

entitling the class to an award of compensatory damages. Defendants egregious and intentional gender

motivated violence against Danielle Bensky and Jane Doe 3 and other class members

entitles the class to punitive damages and an award of attorney fees and costs.

7. Request for Relief. Danielle Bensky and Jane Doe 3 respectfully requests that the court

enter judgment in her favor and against defendants as follows. A that the court certify the class,

name Danielle Bensky and Jane Doe 3, as class representative, and appoint her lawyers as class

counsel. B that the court award plaintiff and other members of the class compensatory,

consequential, general nominal, and punitive damages against defendants and an amount to be

determined that trial. C that the court award punitive and exemplary damages against defendants

in the amount to be determined at trial. D that the court award the plaintiffs the cost and

disbursements of the action along with reasonable attorney fees, costs and expenses. E that the

court award pre-imposed judgment interest at the maximum legal rate and F that the court grant

all such other and further relief as it deems just and proper. Jerry Demand plaintiffs demand

a trial by Jerry on all claims so trialable dated February 16th, 2024 and signed by David Boyz.

All right, so that's going to do it for this one and the document overall. So like usual,

we'll keep a push and we'll move on to the next document. But until then, all of the information

that goes with this episode can be found in the description box.