-l>b~>l\.) \OOO\]O`\UI Case 5:16-cv-OO797-D|\/|G-KS Document 1 Filed 04/26/16 Page 1 of 6 Page |D #:1 m ..< Name; KATIE ]oHNsoN Address; 6634 DEsERT QUEEN AVE. TWENTYNINE PALMS, CA. 92277 Ph()nej (760) 401-0192 ZI =ll HV 93 HdVg|UZ 13an NO FAX OR E-MAIL ln Pro Per UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CASE NUMBERZ ` §§ ,~ ' g KATIE IoHNsoN E D c Vlr v w ‘\. \< o e supplie by the Clerk of Plaintiff The United States District Court COMPLAINT FOR CLAIM RELIEF DUE TO: DONALD ]. TRUMP and 1. SEXUAL ABUSE UNDER THREAT OF HARM ]EFFREY E. EPSTEIN , 2. CONSPIRACY TO DEPRIVE CIVIL RIGHTS Defendant(s). Plaintiff Katie ]ohnson, for causes of actions against Defendants Donald ]. Trump and ]effrey E. Epstein, alleges as follows: ]URISDICTION 1. ]urisdiction is pursuant to the law of Diversity, 28 U.S.C. ; 1332, as plaintiff resides in the state of California While defendants reside in the state of New York and the action is for damages above $'75,000. VENUE 2. The venue is established as the Eastern Division of the United States Court Central District of California because the plaintiff resides in San Bernadino County, State of California UB`H:J CV-126 (09/09) PLEADING PAGE FOR A COMPLAIN'I` \OOO\]O\U\-J>.DJ[\)»~ N!\)!\)NNI\)Nl\Jl\)v-‘>-‘r-\>~r-\»-‘>-\\-d»-a»-~ OO\]O\Ll\-PUJNP*O\OOO\]O\LIIAL»JN*~O Case 5:16-cv-OO797-D|\/|G-KS Document 1 Filed 04/26/16 Page 2 of 6 Page |D #:2 PARTIES 3. The Plaintiff, Katie ]ohnson, resides in the State of California. 4. The Defendants, Donald I. Trump and Ieffrey E. Epstein, each reside in the State of New York. FACTUAL ALLEGATIONS 5. The Plaintiff, Katie Iohnson, alleges that the Defendants, Donald ]. Trump and ]effrey E. Epstein, did willfully and With extreme malice violate her Civil Rights under 18 U.S.C. ; 2241 by sexually and physically abusing Plaintiff Iohnson by forcing her to engage in various perverted and depraved sex acts by threatening physical harm to Plaintiff ]ohnson and also her family. 6. The Plaintiff, Katie ]ohnson, alleges that the Defendants, Donald ]. Trump and Ieffrey E. Epstein, also did Willfully and With extreme malice violate her Civil Rights under 42 U.S.C. ; 1985 by conspiring to deny Plaintiff ]ohnson her Civil Rights by making her their sex slave. 7. The Plaintiff, Katie ]ohnson, alleges she Was subject to extreme sexual and physical abuse by the Defendants, Donald ]. Trump and jeffrey E. Epstein, including forcible rape during a four month time span covering the months of ]une»September 1994 When Plaintiff Iohnson Was still only a minor of age 13. 8. The Plaintiff, Katie ]ohnson, alleges she Was enticed by promises of money and a modeling career to attend a series of underage sex parties held at the New Yorl< City residence of Defendant ]effrey E. Epstein and attended by Defendant Donald ]. Trump. 9. On the first occasion involving the Defendant, Donald }. Trump, the Plaintiff, Katie ]ohnson, Was forced to manually stimulate Defendant Trump With the use of her hand upon Defendant Trump's erect penis until he reached sexual orgasm. 10. On the second occasion involving the Defendant, Donald ]. Trump, the Plaintiff, Katie lohnson, Was forced to orally copulate Defendant Trump by placing her mouth upon Defendant Trump's erect penis until he reached sexual orgasm. CV-126 (09/09) PLEADING PAGE FOR A COMPLAINT \OOO\]O\U!-|>~WN)-\ l\.)[\.)[\)[\.)[\)[\.)[\.)[\.)[\.)>--‘)--l>-l)-1)-‘>-‘)~»--¢)--¢>--l OO\]O\LAJ>UJN*~“O\DOO\IO\LA-IAUJ[\)>-“O Case 5:16-cv-OO797-D|\/|G-KS Document 1 Filed 04/26/16 Page 3 of 6 Page |D #:3 11. On the third occasion involving the Defendant, Donald ]. Trump, the Plaintiff, Katie ]ohnson Was forced to engage in an unnatural lesbian sex act with her fellow minor and sex slave, Maria Doe age 12, for the sexual enjoyment of Defendant Trump. After this sex act, both minors Were forced to orally copulate Defendant Trump by placing their mouths simultaneously on his erect penis until he achieved sexual orgasm. After Zipping up his pants, Defendant Trump physically pushed both minors away While angrily berating them for the "poor" quality of their sexual performance 12. On the fourth and final sexual encounter with the Defendant, Donald I. Trump, the Plaintiff, Katie ]ohnson, Was tied to a bed by Defendant Trump who then proceeded to forcibly rape Plaintiff ]ohnson. During the course of this savage sexual attack, Plaintiff ]ohnson loudly pleaded with Defendant Trump to "please wear a condom". Defendant Trump responded by violently striking Plaintiff ]ohnson in the face With his open hand and screaming that "he would do whatever he wanted" as he refused to Wear protection. After achieving sexual orgasm, the Defendant, Donald I. Trump put his suit back on and when the Plaintiff, Katie ]ohnson, in tears asked Defendant Trump what Would happen if he had impregnated her, Defendant Trump grabbed his wallet and threw some money at her and screamed that she should use the money "to get a fucking abortion". 13. On the flrst occasion involving the Defendant, ]effrey E. Epstein, the Plaintiff, Katie ]ohnson, Was forced to disrobe into her bra and panties and to give a full body massage to Defendant Epstein While he Was completely naked. During the massage, Defendant Epstein physically forced Plaintiff Iohnson to touch his erect penis with her bare hands and to clean up his ejaculated semen after he achieved sexual orgasm. 14. On the second occasion involving the Defendant, ]effrey Epstein, the Plaintiff, Katie ]ohnson, was again forced to disrobe into her bra and panties while giving Defendant Epstein a full body massage While he was completely naked. The Defendant, Donald ]. Trump, was also present as he was getting his own massage from another minor, lane Doe, age 13. Defendant Epstein forced Plaintiff ]ohnson to touch his erect penis by physically placing her bare hands upon his sex organ and again forced Plaintiff ]ohnson to clean up his ejaculated semen after he achieved sexual orgasm. CV-126 (09/09) PLEADING PAGE FOR A COMPLAINT \C>O<J\]O'\'~Jl-l>-L».>[\))-a l\)[\.)[\.)l\)!\)[\)!\)[\)!\.)»-\)-l)-\>~)-‘)-l>-\>-\i-a>-l OO\IO\M-l>'~)~>i\-)P-\O\OOO\]O'\U`IJ>LH[\J>-*O Case 5:16-cv-OO797-D|\/|G-KS Document 1 Filed 04/26/16 Page 4 of 6 Page |D #:4 15. Shortly after this sexual assault by the Defendant, ]effrey E. Epstein, on the Plaintiff, Katie ]olinson, Plaintiff Iohnson was still present while the two Defendants were arguing over Who would be the one to take Plaintiff lohnson's virginity. The Defendant, Donald I. Trump, was clearly heard referring to Defendant, ]effrey E. Epstein, as a "Iew Bastar " as he yelled at Defendant Epstein, that clearly, he, Defendant Trump, should be the lucky one to "pop the cherry" of Plaintiff ]ohnson. 16. The third and final sexual assault by the Defendant, ]effrey E. Epstein, on the Plaintiff, Katie Iohnson, took place after Plaintiff }ohnson had been brutally and savager raped by Defendant Trump. While receiving another full body massage from Plaintiff ]ohnson, While in the nude, Defendant Epstein became so enraged after finding out that Defendant Trump had been the one to take Plaintiff ]ohnson's virginity, that Defendant Epstein also violently raped Plaintiff ]ohnson. After forcing Plaintiff Iohnson to disrobe into her bra and panties, while receiving a massage from the Plaintiff, Defendant Epstein attempted to enter Plaintiff Iohnson's anal cavity with his erect penis while trying to restrain her. Plaintiff Iohnson attempted to push Defendant Epstein away, at which time Defendant Epstein attempted to enter Plaintiff ]ohnson's vagina with his erect penis. This attempt to brutally sodomize and rape Plaintiff Iohnson by Defendant Epstein was finally repelled by Plaintiff ]ohnson but not before Defendant Epstein was able to achieve sexual orgasm. After perverser sodomizing and raping the Plaintiff, Katie Iohnson, the Defendant, ]effrey E. Epstein, attempted to strike her about the head with his closed fists while he angrily screamed at Plaintiff ]ohnson that he, Defendant Epstein, should have been the one who "took her cherry, not Mr. Trump", before she finally managed to break away from Defendant Epstein, 17. The Plaintiff, Katie ]ohnson, was fully warned on more than one occasion by both Defendants, Donald ]. Trump and ]effrey E. Epstein, that were She ever to reveal any of the details of the sexual and physical abuse that she had suffered as a sex slave for Defendant Trump and Defendant Epstein, that Plaintiff ]ohnson and her family would be in mortal danger. Plaintiff Iohnson was warned that this would mean certain death for herself and Plaintiff ]ohnson's family unless she remained silent forever on the exact details of the depraved and perverted sexual and physical abuse she had been forced to endure from the Defendants. 4 CV-126 (09/09) PLEADING PAGE FOR A COMPLAINT \OOO\}O`\Ul-l>b~>[\.))-\ NI\)NNN[\)[\)N[\.))->-)-\»->-l>-l)-H)-l)-\ OO\)O\Ul-{>L»Jl\)>-*O\OOO\]O\UIJ>UJN*-*O Case 5:16-cv-OO797-D|\/|G-KS Document 1 Filed 04/26/16 Page 5 of 6 Page |D #:5 MATERIAL WITNESSES 18. Tiffany Doe, a former trusted employee of the Defendant, ]effrey E. Epstein, has agreed to provide sworn testimony in this civil case and any other future civil or criminal proceedings, fully verifying the authenticity of the claims of the Plaintiff, Katie ]ohnson. Witness Tiffany Doe was employed by the Defendant, ]effrey E. Epstein, for more than 10 years as a party planner for his underage sex parties. Despite being subject to constant terroristic threats by Defendants Epstein and Trump to never reveal the details of these underage sex parties at which scores of teenagers, and pre~teen girls were used as sex slaves by Defendant Epstein and Defendant Trump, witness Tiffany Doe refuses to be silent any longer. She has agreed to fully reveal the extent of the sexual perversion and physical cruelty that she personally witnessed at these parties by Defendants Epstein and Trump. 19. Material witness Tiffany Doe fully confirms all of Plaintiff Katie ]ohnson's allegations of physical and sexual abuse by Defendants Donald ]. Trump and ]effrey E. Epstein. Tiffany Doe Was physically present at each of the four occasions of sexual abuse by Defendant Trump upon the person of Plaintiff ]ohnson, as it was her job to witness all of the sexual escapades of Defendant Epstein's guests at these underage sex parties and later reveal all of the sordid details directly to Defendant Epstein. Defendant Epstein also demanded that Tiffany Doe tell him personally everything she had overheard at these parties explaining to her that "knowledge was king" in the financial World. As a result of these underage sex parties, Defendant Epstein was able to accumulate inside business knowledge that he otherwise Would never have been privy to in order to amass his huge personal fortune. 20. Material witness Tiffany Doe will testify that she was also present or had direct knowledge of each of the three instances on which Defendant ]effrey E. Epstein physically and sexually abused the Plaintiff, Katie ]ohnson. Tiffany Doe will testify to the fact that the Plaintiff, Katie ]ohnson, was extremely fortunate to have survived all of the physical and sexual horrors inflicted upon her by Defendants Epstein and Trump. CV-lZ6 (09/09) PLEADING PAGE FOR A COMPLAINT \OOO\]O\Ul-I>L»J[\)r-\ l\.)[\)[\)[\)[\.)[\.)!\.)[\.)[\.)>-\>-‘)-‘>-‘>-‘>-i>-\»-i>-\i_l OO\lO`\U'l-LL)JN*-‘O\OOO\\O\UI-§L)JN>-‘O Case 5:16-cv-OO797-D|\/|G-KS Document 1 Filed 04/26/16 Page 6 of 6 Page |D #:6 CLAIM FOR RELIEF 21. The Plaintiff, Katie ]ohnson, asks the court for relief against the Defendants, Donald ]. Trump and Ieffrey E. Epstein, in the amount of $100,000,000.00 (One Hundred Million Dollars) as a result of the Defendants aforementioned acts upon which they willfully and maliciously violated the Civil Rights of the Plaintiff as stated in 18 U.S.C. ; 2241 by sexually and physically abusing the then 13 year old Plaintiff johnson under threat of harm to her and her family, and 42 U.S.C. ; 1985 by the Defendants conspiring to deny the Civil Rights of Plaintiff ]ohnson by making her their sex slave, Dated: April 26, 2016 KATIE ]OHNSON 0 B . Y \ \! Plaintiff Katie ]o nson Appearing In Pro Per CV»l26 (09/09) PLEADING PAGE FOR A COMPLAINT