Ohio

Case 5:16-cv-00797-DMG-KS Document 1 Filed 04/26/16 Page 1 of 6 Page ID #:1

KATIE JOHNSON

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
CASE NUMBER ED CV16-00797

14 DONALD J. TRUMP and
15 JEFFREY E. EPSTEIN


COMPLAINT FOR CLAIM RELIEF DUE TO:

l. SEXUAL ABUSE UNDER THREAT OF HARM

2. CONSPIRACY TO DEPRIVE CIVIL RIGHTS


2 PARTIES
3 3. The Plaintiff, Katie Johnson, resides in the State of California.
4 4. The Defendants, Donald J. Trump and Jeffrey E. Epstein, each reside in the State of New York.

6 FACTUAL ALLEGATIONS
The Plaintiff, Katie Johnson, alleges that the Defendants, Donald J. Trump and Jeffrey E. Epstein, did willfully and with extreme malice violate her Civil Rights under 18 U.S.C. ; 2241 by sexually and physically abusing Plaintiff Johnson by forcing her to engage in various perverted and depraved sex acts by threatening physical harm to Plaintiff Johnson and also her family.

The Plaintiff, Katie Johnson, alleges that the Defendants, Donald J. Trump and Jeffrey E. Epstein, also did willfully and with extreme malice violate her Civil Rights under 42 U.S.C.; 1985 b conspiring to deny Plaintiff Johnson her Civil Rights by making her their sex slave.
The Plaintiff, Katie Johnson, alleges she was subject to extreme sexual and physical abuse by the Defendants, Donald J. Trump and Jeffrey E. Epstein, including forcible rape during a four month time span covering the months ofJune-September 1994 when Plaintiff Johnson was still a minor of age 13.

18 8. The Plaintiff, Katie Johnson, alleges she was enticed by promises of money and a modeling career to attend a series of underage sex parties held at the New York City residence of Defendant Jeffrey E. Epstein and attended by Defendant Donald J. Trump.

21 9. On the first occasion involving the Defendant, Donald J. Trump, the Plaintiff, Katie Johnson, was forced to manually stimulate Defendant Trump with the use of her hand upon Defendant Trump's erect penis until he reached sexual orgasm.
24 10. On the second occasion involving the Defendant, Donald J. Trump, the Plaintiff, Katie Johnson, was forced to orally copulate Defendant Trump by placing her mouth upon Defendant Trump's erect penis until he reached sexual orgasm.


1 11. On the third occasion involving the Defendant, Donald J. Trump, the Plaintiff, Katie Johnson 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.

7 12. On the fourth and final sexual encounter with the Defendant, Donald J. Trump, the Plaintiff, Katie Johnson, was tied to a bed by Defendant Trump who then proceeded to forcibly rape Plaintiff Johnson. During the course of this savage sexual attack, Plaintiff Johnson loudly pleaded with Defendant Trump to "please wear a condom". Defendant Trump responded by violently striking Plaintiff Johnson 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 J.Trump put his suit back on and when the Plaintiff, Katie Johnson, in tears asked Defendant Trump what would happen if he had impregnated her, Defendant Trump grabbed his wallet ans threw some money at her and screamed that she should use the money "to get a fucking abortion".

16 13. On the first occasion involving the Defendant, Jeffrey E. Epstein, the Plaintiff, Katie Johnson, 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 Johnson to touch his erect penis with her bare hands and to clean up his ejaculated semen after he
20 achieved sexual orgasm.