Katherine Wolf

@katherinewolf

Doctoral candidate in Society and Environment in the Department of Environmental Science, Policy, and Management at Berkeley attempting environmental epidemiology and critical disability studies. Disabled white queer. MPH/MESc. She/her.

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Katherine Wolf@katherinewolf· Nov 16

Page 9. 🧵 3/3

Case 1:16-cv-04642 Document 1 Filed 06/20/16 Page 9 of 9
B. That all costs of this action be assessed against Defendants, including all
reasonable attorney’s fees, costs and expenses of this action;
C. That an order of protection in favor of Plaintiff and all associated with her be
issued so as to protect them from harm and harassment from Defendants and their agents and
associates; and
D. Such other and further relief as the Court may deem just and proper.
JURY DEMAND
Plaintiff demands a trial by jury of all issues properly triable by jury in this action.
Respectfully submitted,
Dated: June 20, 2016
By: /s/ Thomas Francis Meagher
Thomas Francis Meagher
SDNY Bar Code TM6707
One Palmer Square
Princeton, New Jersey 08542
Telephone: (609) 558-1500
tmeagher@thomasfmeagheresq.com
ATTORNEY FOR PLAINTIFF
9

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Katherine Wolf@katherinewolf· Nov 16

Pages 5–8. Someone has covered this already, right? Does anyone know what the outcome of this case was? 🧵 2/3

Case 1:16-cv-04642 Document 1 Filed 06/20/16 Page 5 of 9
sexual and physical abuse of her or else, specifically, Plaintiff and her family would be seriously
physically harmed, if not killed. Exhs. A and B.
14. While still under threats of physical harm by coming forward and having no
reason to believe that the threats have ever been lifted or would ever be lifted, Plaintiff, who has
suffered from stress, emotional distress, mental pain and suffering, among other problems, ever
since the assaults, was subjected to daily painful reminders of the horrific acts of one of the
perpetrators, Defendant Trump, via mass media coverage of him starting on or about June 16,
2015 that, over a short period of time, became continuous and unavoidable. Exh. A.
15. As a direct and proximate result of the sexual assaults and rapes perpetrated by
Defendants upon her, Plaintiff has suffered stress, emotional distress, and mental pain and
suffering, as well as adverse physical consequences.
16. As a direct and proximate result of the sexual assaults and rapes perpetrated by
Defendants upon her, Plaintiff has suffered physical pain and suffering.
17. As a direct and proximate result of the sexual assaults and rapes perpetrated by
Defendants upon her, Plaintiff has been subjected to public scorn, hatred, and ridicule and has
suffered threats against her life and physical safety.
18. As a direct and proximate result of the sexual assaults and rapes perpetrated by
Defendants upon her, Plaintiff has incurred special damages, including medical and legal
expenses.
19. The sexual assaults and rapes perpetrated by Defendants upon Plaintiff were
intentional acts.
20. The conduct of Defendants demonstrates willful, reckless and intentional conduct
that raises a conscious indifference to consequences.
5

HOUSE_OVERSIGHT_026388

Case 1:16-cv-04642 Document 1 Filed 06/20/16 Page 6 of 9
21. At the appropriate time in this litigation, Plaintiff shall amend her complaint to
assert a claim for punitive damages against Defendants in order to punish Defendants for their
actions and to deter Defendants from repeating their conduct.
TOLLING OF STATUTE OF LIMITATIONS
22. Any statute of limitations applicable to rape, sexual misconduct, criminal sexual
acts, sexual abuse, forcible touching, assault, battery, intentional and reckless infliction of
emotional distress, false imprisonment of a minor, if any, is tolled owing to the continuous and
active duress imposed upon Plaintiff by Defendants that effectively robbed Plaintiff of her free
will to commence legal action until the present time. Cullen v. Margiotta, 811 F.2d 698, 722
(2nd Cir.1987); Ross v. United States, 574 F. Supp. 536, 542 (S.D.N.Y. 1983). More
particularly, Plaintiff was unrelentingly threatened by each Defendant that, were she ever to
reveal any of the details of the sexual and physical abuse caused to her by Defendants, Plaintiff
and her family would be physically harmed if not killed. The duress has not terminated and the
fear has not subsided. The duress is an element of or inherent in the underlying causes of action
complained of herein. The duress and coercion exerted by Defendants has been such as to have
actually deprived Plaintiff of her freedom of will to institute suit earlier in time, and it rose to
such a level that a person of reasonable firmness in Plaintiff's situation would have been unable
to resist. Exhs. A and B.
23. Both Defendants let Plaintiff 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 Plaintiff shouldn’t ever say anything if she didn’t want to disappear
like Maria, a 12-year-old female that was forced to be involved in the third incident with
6

HOUSE_OVERSIGHT_026389

Case 1:16-cv-04642 Document 1 Filed 06/20/16 Page 7 of 9
Defendant Trump and that Plaintiff had not seen since that third incident, and that he was
capable of having her whole family killed. Exhs. A and B.
24. The duress had prevented Plaintiff from starting litigation before this year.
However, as soon as she surfaced, she received threats. More specifically, shortly after her first
complaint was filed in California on April 26, 2016, she started receiving threatening phone calls
on her cell phone. Exh. A.
25. Defendants are equitably estopped from arguing that any statute of limitations has
not been tolled as Defendants wrongfully forced Plaintiff to refrain from timely commencing this
action by threats, duress, and other misconduct. Exhs. A and B.
26. Moreover, this action has been brought before the facts giving rise to the estoppel
have ceased to be operational (i.e., while still under threats of physical harm by coming forward
and having no reason to believe that the threats have ever been lifted or would ever be lifted) and
since Plaintiff has decided to seek redress at this time, Plaintiff seeks an order of protection in
favor of Plaintiff and all associated with her so as to protect them from harm and harassment
from Defendants and their agents and associates. Exh. A.
DEFAMATION
27. On information and belief, on or about April 28, 2016, Defendant Trump
provided the following statement to American Media, Inc. and/or Radar Online LLC for
publication on at least their website RadarOnline.com regarding Plaintiff’s complaint ED CV 16-
797-DMG (KSx) filed in the United States District Court for the Central District of California:
“The allegations are not only categorically false, but disgusting at the highest level and clearly
7

HOUSE_OVERSIGHT_026390

Case 1:16-cv-04642 Document 1 Filed 06/20/16 Page 8 of 9
framed to solicit media attention or, perhaps, are simply politically motivated. There is
absolutely no merit to these allegations. Period.” The statement provided for publication by
Defendant Trump was published by said website and has been republished elsewhere in whole or
in part numerous times (and similar statements of an attorney for Defendant Trump were also
published). The statement provided for publication by Defendant Trump and that was published
by said websites is false as it pertains to Plaintiff.
28. The published statement is libelous on its face, and clearly exposes Plaintiff to
hatred, contempt, ridicule and obloquy.
29. As a proximate result of the above-described publication, Plaintiff has suffered
loss of her reputation, shame, mortification, and injury to her feelings, all to her damage in an
amount to be established by proof at trial.
30. The above-described publication was not privileged because it was published by
Defendant Trump with malice, hatred and ill will toward Plaintiff and the desire to injure her.
31. As a direct and proximate result of Defendant Trump’s defamation of Plaintiff,
Plaintiff has been subjected to public scorn, hatred, and ridicule and has suffered other injury.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for judgment against Defendants and for the
following relief:
A. That judgment be entered against Defendants for special damages, compensatory
damages, and punitive damages in an amount which shall be shown to be reasonable and just by
the evidence and in excess of Seventy Five Thousand Dollars ($75,000.00), exclusive of interests
and costs;
8

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Katherine Wolf@katherinewolf· Nov 16

Content note for child sexual abuse, rape. Plaintiff alleged that Trump raped her when she was 13. Case is 1:16-cv-04642, United States District Court Southern District of New York, filed June 20, 2016. HOUSE_OVERSIGHT_026384 to HOUSE_OVERSIGHT_026392. Hat-tip to @siarapita.bsky.social. 🧵 1/3

Case 1:16-cv-04642 Document 1 Filed 06/20/16 Page 1 of 9
IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
---------------------------------------------------------------
JANE DOE, proceeding under a pseudonym,
v.
Plaintiff,
DONALD J. TRUMP and
JEFFREY E. EPSTEIN,
Defendants.
---------------------------------------------------------------
)
)
)
)
)
)
)
)
)
Case No.:
JURY TRIAL DEMANDED
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.
Trump and Jeffrey E. Epstein, and alleges that:
PARTIES
1. 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.
JURISDICTION AND VENUE
3. Plaintiff is a citizen of the State of California for purposes of diversity jurisdiction
under 28 U.S.C. § 1332.
4. Defendants are citizens of the State of New York for purposes of diversity
jurisdiction under 28 U.S.C. § 1332.

HOUSE_OVERSIGHT_026384

Case 1:16-cv-04642 Document 1 Filed 06/20/16 Page 2 of 9
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.
RAPE, SEXUAL MISCONDUCT, CRIMINAL SEXUAL ACTS, SEXUAL ABUSE,
FORCIBLE TOUCHING, ASSAULT, BATTERY, INTENTIONAL AND RECKLESS
INFLICTION OF EMOTIONAL DISTRESS, DURESS, AND FALSE
IMPRISONMENT
7. Plaintiff was subject to acts of rape, sexual misconduct, criminal sexual acts,
sexual abuse, forcible touching, assault, battery, intentional and reckless infliction of emotional
distress, duress, false imprisonment, and threats of death and/or serious bodily injury by the
Defendants that took place at several parties during the summer months of 1994. The parties
were held by Defendant Epstein at a New York City residence that was being used by Defendant
Epstein at 9 E. 71st St. in Manhattan. During this period, Plaintiff was a minor of age 13 and
was legally incapable under New York law of consenting to sexual intercourse and the other
sexual contacts detailed herein. NY Penal L § 130.05(3)(a). The rapes in the first, second, and
third degrees; sexual misconduct; criminal sexual acts in the first, second, and third degrees;
sexual abuse in the first, second, and third degrees; and forcible touching (and, on information
2

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Case 1:16-cv-04642 Document 1 Filed 06/20/16 Page 3 of 9
and belief, predatory sexual assault) detailed herein are unlawful under New York law, e.g., NY
Penal L § 130.20-130.52, and 130.55-130.65 (and, on information and belief, 130.95) and
constitute the torts of, inter alia, assault, battery, false imprisonment, and intentional or reckless
infliction of emotional distress, including threats of force and serious bodily harm, under New
York law. Declaration of Plaintiff Jane Doe, Exhibit A hereto; Declaration of Tiffany Doe,
Exhibit B hereto. Jane Doe and Tiffany Doe are each pseudonyms as each woman wishes
anonymity. Tiffany Doe, a witness, was an employee of Defendant Epstein. Exh. B.
8. Courts have discretion to allow proceeding anonymously where the need for
privacy outweighs the public’s interest in knowing their identity and any prejudice to the
defendants. Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, 189 (2d Cir. 2008). This
litigation involves matters that are highly sensitive and of a personal nature, and identification of
Plaintiff would pose a risk of retaliatory physical harm to her and to others. Exh. A. All of the
ten factors that the Second Circuit articulated as relevant to this analysis favor anonymity,
especially factors 1-4, 7, and 10 (e.g., factors one and two: “whether the litigation involves
matters that are ‘highly sensitive and [of a] personal nature,’” and “’whether identification poses
a risk of retaliatory physical or mental harm to the ... party [seeking to proceed anonymously] or
even more critically, to innocent non-parties’”.), or are neutral with respect to anonymity.
Protecting Plaintiff’s anonymity is also appropriate as she is a rape victim.
9. Plaintiff was enticed by promises of money and a modeling career to attend a
series of parties, with other similarly situated minor females, held at a New York City residence
that was being used by Defendant Jeffrey Epstein. At least four of the parties were attended by
Defendant Trum…

Case 1:16-cv-04642 Document 1 Filed 06/20/16 Page 4 of 9
Trump had known Defendant Epstein for seven years (New York, 10/28/02), and knew that
Plaintiff was then just 13 years old. Exhs. A and B.
10. Defendant Trump initiated sexual contact with Plaintiff at four different parties.
On the fourth and final sexual encounter with Defendant Trump, Defendant Trump tied Plaintiff
to a bed, exposed himself to Plaintiff, and then proceeded to forcibly rape Plaintiff. During the
course of this savage sexual attack, Plaintiff loudly pleaded with Defendant Trump to stop but
with no effect. Defendant Trump responded to Plaintiff’s pleas by violently striking Plaintiff in
the face with his open hand and screaming that he would do whatever he wanted. Exhs. A and
B.
11. Immediately following this rape, Defendant Trump threatened Plaintiff that, were
she ever to reveal any of the details of the sexual and physical abuse of her by Defendant Trump,
Plaintiff and her family would be physically harmed if not killed. Exhs. A and B.
12. Defendant Epstein had sexual contact with Plaintiff at two of the parties. The
second sexual encounter with Defendant Epstein took place after Plaintiff had been raped by
Defendant Trump. Defendant Epstein forced himself upon Plaintiff and proceeded to rape her
anally and vaginally despite her loud pleas to stop. Defendant Epstein then attempted to strike
Plaintiff about the head with his closed fists while he angrily screamed at Plaintiff that he,
Defendant Epstein, rather than Defendant Trump, should have been the one who took Plaintiff’s
virginity, before Plaintiff finally managed to break away from Defendant Epstein. Exhs. A and
B.
13. The threats of violence against Plaintiff and her family continued, this time from
Defendant Epstein, who again reiterated that Plaintiff was not to reveal any of the details of his
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Katherine Wolf@katherinewolf· Nov 12

Reposted with alt text. Lest anyone still thought @harvard.edu was a meritocracy. www.hks.harvard.edu/faculty/lawr... Summers is still there!

Email screenshot reading

From: Larry Summers [email redacted]

Sent: 10/27/2017 3:10:13 PM

To: jeffrey E. [jeevacation@gmail.com]

Subject: Re: Trending Now: Friends for three decades, Trump whisperer says he is 'stunned' by president's rhetoric

Importance: High

Softbank deputy guy i liked and seemed aware and honest re Son.
Lots of slathering to saudis. I yipped about inclusion.

I observed that half the IQ In world was possessed by women without mentioning they are more than 51 percent of population....

Mnuchin plumbs new depths.

War seems more likely than I used to think

DjT is world s luckiest guy in terms of opposition, economy etc. still think his world will collapse.

I'm trying to figure why American elite think if u murder your baby by beating and abandonment it must be irrelevant to your admission to Harvard, but hit on a few women 10 years ago and can't work at a network or think tank. DO NOT REPEAT THIS INSIGHT

Katherine Wolf@katherinewolf· May 22

My dog Spike!

white miniature poodle mutt with a silver nametag reading “Spike“ lying on a white blanket looking pensive in front of a black stuffed animal, more blankets, and bookshelves

Katherine Wolf@katherinewolf· Apr 19

Reposting this SCOTUS order (from after midnight Eastern!) with alt text.

Order from the Supreme Court of the United States (black text on a white background) that reads as follows:

(ORDER LIST: 604 U.S.)

SATURDAY, APRIL 19, 2025

ORDER IN PENDING CASE

24A1007

A.A.R.P., ET AL. V. TRUMP, PRESIDENT OF U.S., ET AL.
There is before the Court an application on behalf of a
putative class of detainees seeking an injunction against their
removal under the Alien Enemies Act. The matter is currently
pending before the Fifth Circuit. Upon action by the Fifth
Circuit, the Solicitor General is invited to file a response to
the application before this Court as soon as possible. The
Government is directed not to remove any member of the putative
class of detainees from the United States until further order of
this Court. See 28 U. S. C. §1651(a).
Justice Thomas and Justice Alito dissent from the Court's
order. Statement from Justice Alito to follow.

Katherine Wolf@katherinewolf· Mar 13

Yeses 50.03%, nos 49.97%. 4,218-vote gap on Proposition 1 as of 7:01 p.m. last night.

Screenshot of the SOS site:

State Ballot Measure Statewide Results
Close Contest
31 Days Left
Unofficial Election Results
Results will be certified by April 12, 2024.

( 20,855 of 20,855 ) precincts partially reporting as of March 12, 2024, 7:01 p.m. Help icon: See FAQs for additional information on how precincts reporting information is determined.

Visit the County Reporting Status page to determine when a county has submitted its latest report.

Precincts are listed as “partially” reporting since vote-by-mail, provisional, and other ballots will continue to be processed and counted after Election Night.

Election results will change throughout the ballot counting canvass period as vote-by-mail ballots, provisional ballots (including conditional voter registration provisional ballots), and other ballots are tallied.

County Results
Other Links
Statewide Map

Table
Proposition Title: Bonds for Mental Health Treatment Facilities
Yes Votes: 3,164,593 50.0%
No Votes: 3,160,375 50.0

Katherine Wolf@katherinewolf· Feb 25

Last page! (Honestly IMHO the most helpful one with the connections between Proposition 1, CARE Court, and SB 43.)

Katherine Wolf@katherinewolf· Feb 25

Second four pages!

Katherine Wolf@katherinewolf· Feb 25

First four pages!

Katherine Wolf@katherinewolf· Oct 29

I’m planning to go to this march on DC this Saturday, and I’d love to find other folks there. I hope that it will be huge. More info at peoplesforum.org/events/natio....

Poster for the Free Palestine March on
Washington taking place on Saturday, November 4 at 2:00 p.m. at
Freedom Plaza in Washington, DC. The headlines read, "BIDEN, NO MORE U.S. AID TO ISRAEL!", "LIFT THE SIEGE ON GAZA NOW!", and "THE PEOPLE DEMAND A CEASEFIRE!" The body of text reads, "Now is the the time to stand with the besieged people of Palestine! Gaza is being bombed by the hour. Its people are denied food, water and electricity by Israel. Tens of thousands on more people are likely to die. We must ACT! People are in the streets everyday in their local cities and towns. Now we must UNITE! Join the tens of thousands people, from every corner of the United States, who are converging for a truly massive National March on Washington D.C. on Saturday, November 4 at 2:00 p.m. at Freedom Plaza". A QR code in the bottom right corner titled "Get on the bus!" redirects to https:// www.answercoalition.org/nov4_bus
where organized transportation hubs and buses across the country are listed.

Katherine Wolf@katherinewolf· Oct 28

Thousands out in San Francisco for Palestine.

Mass of thousands of people holding signs and Palestinian flags in San Francisco.

Katherine Wolf@katherinewolf· Oct 22

Some media coverage of these thousands-big free-Palestine/ceasefire/anti-weapons-to-Israel/stop-the-genocide protests by the outlets politicians actually read would be REALLY GREAT.

A Twitter/X post from user @p_pod_ reading “several thousand rallied and marched on Ohlone land / Oakland today calling for an end to the US-backed zionist genocide and a free Palestine with the right of return” above a photo of a crowd of several thousand, many with flags of Palestine and signs, rallying in Oscar Grant Plaza

Katherine Wolf@katherinewolf· Oct 22

Really feeling this protest sign right now.

White person’s hand holding a white sign with “WHAT THE HELL, BIDEN?!?!” written on it in black marker in front of a brown office building in Oakland, California.

Katherine Wolf@katherinewolf· Oct 22

Genocide. The plan is genocide.

Twitter post from The Jerusalem post stating: “Defense Minister @yoavgallant stressed that this war needs to be the ‘last campaign in #Gaza, for the simple reason that after this #Hamas will not exist.’” Words above a photo with the text “The Jerusalem Post BREAKING NEWS” and a link to jpost.com.

Katherine Wolf@katherinewolf· Oct 22

I'd love to see folks today at noon in Oakland at Oscar Grant Plaza at 14th and Broadway if anyone is free! All (including non-Muslims) are welcome (in caps!) per the organizers at the Arab Resource and Organizing Center. Original Instagram post: www.instagram.com/p/CyoUL9iJ1rl/

A mosque on a grey background behind text that reads in yellow:
UNITED MUSLIMS FOR PALESTINE
[then repeated in Arabic, I believe]

Then the text reads in white:
NO US AID FOR GENOCIDE!
[then repeated in Arabic, I believe]

12PM Noon
Sunday, October 22nd
Oscar Grant Plaza (14th and Broadway)
Oakland, CA

Katherine Wolf@katherinewolf· Oct 22

The use of the passive was also poised to escalate. I'm impressed, @nytimes.com. Save an autonomous crisis, not an acting subject to be found.

Black text on a white background from the New York Times front webpage that reads:

Israel-Hamas War
First Shipment of Aid to Gaza Seen as Insufficient as Crisis Worsens
It remained unclear whether more aid would be allowed in. There were increasing signs that the fighting was poised to escalate, stirring fears of a wider war.

Katherine Wolf@katherinewolf· Oct 21

The White House seems to have closed their "Contact Us" form for a while this evening. Hmmm. (I know that BlueSky doesn't do hashtags, but they would be: No more deaths. No more genocide. End the occupation. Free Palestine. No US arms for Israel. Ceasefire now.)

Firefox website open to https://www.whitehouse.gov/contact/ showing a white webpage with the words "Contact Us" in blue above a pink box containing a red "X" in a circle below red text stating, "THIS FORM WILL REOPEN FOR SUBMISSIONS AT 11:00PM ET". A timestamp in the lower left corner reads "7:34 PM 10/20/2023".

Katherine Wolf@katherinewolf· Oct 19

I‘m going and I’d love to see folks there!