A second amended complaint filed Friday in Manhattan federal court by six victims of Jeffrey Epstein who are suing the V.I. government for alleged violations of the Trafficking Victims Protection Act claims territory officials actively conspired with the late multimillionaire to perpetuate his sex-trafficking scheme for their own gain.
In effect, the U.S. Virgin Islands became “a government-sanctioned sanctuary” for wealthy men who paid Epstein “substantial” sums of money to travel from New York to engage in commercial sex acts with women also traveling from that state, the amended suit alleges. Epstein would then deposit the funds in his New York bank accounts, from which he paid the defendants in the USVI, it says.
It was a quid pro quo arrangement where Epstein could make a fortune providing wealthy men with women and girls to abuse at his private island off St. Thomas, and USVI officials could tap him for money for everything from political campaigns to Little League programs, legal bills and even a $50 million loan when the territory was short on cash, the lawsuit alleges. In return, Epstein had free rein to travel as he pleased between New York and the USVI, with whom he pleased, without any oversight from Customs, police, Coast Guard and other officials, it says.
It’s an allegation that is repeated throughout the amended complaint — which is 83 pages and also claims negligence and violations of the Racketeer Influenced and Corrupt Organizations Act — that seeks to show why the federal court in the Southern District of New York is the right venue and New York State the correct jurisdiction for the case.
The class action suit was first filed in November by Jane Does 1-5 and amended in December to add a sixth plaintiff. A registered sex offender who pleaded guilty to procuring a minor for prostitution in Florida in 2008, Epstein died by apparent suicide in August 2019 at age 66 while in detention in New York on federal trafficking charges. His primary residence was Little St. James, his private island off St. Thomas where for years he ran a complex web of shell companies registered in the USVI — and afforded some $300 million in tax breaks through the territory’s Economic Development Commission – that enabled his crimes.
The defendants — the V.I. government, former First Lady Cecile de Jongh, Delegate to Congress Stacey Plaskett, former Senators Celestino White and Carlton Dowe, former Attorney General Vincent Frazer, and former Governors Kenneth Mapp and John de Jongh — have argued in their motions to dismiss that none of them has ties to New York and had little to no interaction with Epstein in that state, let alone business dealings, according to court filings.
However, on Thursday Judge Arun Subramanian terminated those motions to dismiss and granted a motion the Does filed Thursday requesting permission to file the second amended complaint, ordering that they do so by Friday. He further ordered that the defendants now file motions on the amended complaint by June 3. The plaintiffs’ responses are due by June 24, and replies by July 8. An initial conference is scheduled for July 31 at 1 p.m.
The amended complaint, like the first, leans almost entirely on information gleaned from the V.I. government’s lawsuit against JPMorgan Chase, Epstein’s primary bank until 2013, which was settled for $75 million in September. The defendants were all deposed in that case, but the publicly available records are heavily redacted and much remains under seal. On April 29, the Does filed a motion seeking a court order granting them access to the full record. Presiding Judge Jed S. Rakoff had not rendered a decision as of Friday.
“It was not until the recent case where JPMorgan Chase disclosed that it had deposed members of the USVI government, that the Plaintiffs and public learned of the many acts committed by Defendants which contributed to and caused Plaintiffs’ injuries under the Trafficking Victims Protection Act,” the amended complaint states.
Much of the conspiring around the sex abuse that occurred in the U.S. Virgin Islands took place while Epstein was in his New York office or residence, the suit alleges. It notes that Plaskett twice met with him at his mansion to discuss political donations (which she said she ultimately returned), and that Cecile de Jongh stayed in one of his apartments for a month in 2017. In her deposition for the JPMorgan case, the former first lady said it was so she could recover from knee surgery. The amended complaint alleges it was “in order to advise and assist him in securing the USVI’s cooperation as a safe harbor for his sex-trafficking ring.”
“Defendants conspired, facilitated, accepted and encouraged the abuse and sex trafficking of the NY victims at the behest and hands of Epstein, a New York based individual, and his New York clients to occur, continue to occur, and flourish in the USVI,” the complaint alleges. After he and his clients sexually abused the victims at his island estate of Little St. James, the defendants then conspired to accommodate “the unencumbered transfer and/or travel of Epstein, his associates, his victims, and his clients from USVI to NY,” it says.
The suit singles out Cecile de Jongh — Epstein’s office manager from 2000 to 2019 — as the conduit through which the others were recruited into the scheme, listing for example her efforts to help Epstein influence sex offender legislation that was before the V.I. Legislature when Frazer was attorney general, or her suggestion that he pay White a monthly retainer for his support, or to help Dowe’s bid to become head of the V.I. Port Authority. In return, Epstein paid her children’s tuition to the tune of $625,000 and loaned the couple $215,000 to help John de Jongh settle a case over improvements to their private home using public funds when he was governor, it says.
“Cecile de Jongh purposely directed and coordinated the payments to Defendants or their designees from Epstein’s New York bank accounts to her and other Defendants,” the suit alleges. “The individual Defendants through emails and calls to individuals in New York, solicited and enticed Epstein and his co-conspirators and wealthy clients to bring business and investment income from New York to the USVI by promising tax breaks, unfettered access to women for purpose of commercial sex acts, tax incentives, privacy and freedom from investigation and or supervision by any and all government agencies, including federal agencies, through their promised coercion and influence over anyone who could interfere with the sex trafficking venture,” it says. “All defendants derived substantial revenue from these acts.”
This case does not involve mere fraud, according to the amended complaint. “Instead, Defendants’ conduct in obstructing enforcement of the TVPA was outrageous and intentional, because it was in deliberate furtherance of a widespread and dangerous criminal sex trafficking organization — for financial gain and political power. Defendants’ obstruction also evinced a high degree of moral turpitude and demonstrated such wanton dishonesty as to imply a criminal indifference to civil obligations,” it says.
