Civil Practice Law and Rules

New York permits contribution where two parties are subject to potential liability for damages for the same personal injury, injury to property, or wrongful death.

See NYCPLR Section 1401.

JPMC's contribution claims based on the TVPA fall squarely within that language, and the New York Common Law similarly recognizes its identification claim.

Staley fails to cite any case holding that the TVPA forecloses identification or contribution claims, nor could he.

New York permits contribution where two parties are subject to potential liability for damages for the same personal injury, injury to property, or wrongful death.

See NYCPLR Section 1401.

JPMC's contribution claims based on the TVPA fall squarely within that language, and the New York common law similarly recognizes its identification claim.

Staley fails to cite any case holding that the TVPA forecloses identification or contribution claims, nor could he.

Justice Adam Silvera recently held that it's evident upon both a plain reading and examination of purpose of the subject's statutes and local law that the GMVPA, which created a new civil rights cause of action where none existed at the time, is not and was not intended to be preempted by two revival statutes that were directed towards sexual assault cases and causes of action.

This court has personal jurisdiction over the defendants pursuant to New York CPLR Section 301 and 302.

Further jurisdiction is proper in the court pursuant to CPLR Section 301, 302 as defendant Frederick Fekai and plaintiff Christy Ferguson are domiciled in the state of Connecticut and Patrick Combs is domiciled in New York City, so there is not complete diversity of parties.

Venue is proper in this court pursuant to CPLR Section 503 because at all times herein mentioned, a substantial part of the acts and omissions alleged herein occurred in New York County in the City of New York, and defendant Patrick Combs is domiciled in New York County in the City of New York.

Defendant's conduct violated New York's GMVA that exists to protect and provide legal recourse to persons, including the plaintiffs herein, from acts of gender-motivated violence as perpetrated by Epstein and his associates.

Furthermore, any statute of limitation that would otherwise apply to plaintiff's claims herein is told in accord with the doctrine of equitable estoppel, as based on the deception, duress, fraud, and or threats of retaliation and misconduct that Epstein and his co-conspirators used to silence his victims, including plaintiffs.

Further, the GMVA is not preempted by any other law because it addresses all acts of gender-motivated violence, not merely conduct that constitutes a violation of the penal law.

The Child Victims Act, hereinafter CVA, pursuant to New York Civil Practice Law, and Rules Section 214G, hereinafter CPLR, and Adult Survivors Act, New York CPLR, Section 214J, and hereinafter ASA, revive common law assault, battery, negligence, and negligent hiring, retention, and supervision causes of action, while the GMVA's intro 1297 provides a cause of action pursuant to the GMVA for gender-motivated violence and includes explicit provisions for punitive damages, attorney fees, and junk of relief that the CVA and ASA do not.

See DeDeuce vs.

State of Jeffrey Epstein, New York Index, No. 151301, 2026.

Justice Adam Silvera recently held that it's evident upon both a plain reading and examination of purpose of the subject's statutes and local law that the GMVPA, which created a new civil rights cause of action where none existed at the time, is not and was not intended to be preempted by two revival statutes that were directed towards sexual assault cases and causes of action.

This court has personal jurisdiction over the defendants pursuant to New York CPLR Section 301 and 302.

Further jurisdiction is proper in the court pursuant to CPLR Section 301, 302 as defendant Frederick Fekai and plaintiff Christy Ferguson are domiciled in the state of Connecticut and Patrick Combs is domiciled in New York City, so there is not complete diversity of parties.

Venue is proper in this court pursuant to CPLR Section 503 because at all times herein mentioned, a substantial part of the acts and omissions alleged herein occurred in New York County in the City of New York, and defendant Patrick Combs is domiciled in New York County in the City of New York.

The amount of damages sought exceeds the jurisdiction of all lower courts which would otherwise have jurisdiction.

This action falls within exceptions to Article 16 of CPLR.

Count 4.

Violation of Gender Motivated Violence Act.

By reason of the foregoing, the plaintiffs are entitled to compensatory damages from defendants, in such sums as the jury would find fair, just and adequate, and the plaintiffs are further entitled, to punitive and exemplary damages from defendants, in such sums as the jury would find fair, just and appropriate, to deter said defendants and others from future similar misconduct.

The amount of damages sought exceeds the jurisdiction of all lower courts, which would otherwise have jurisdiction.

This action falls within exceptions to Article 16 of the CPLR.

Wherefore, plaintiffs demand judgment against defendants in such sum as a jury would find fair, adequate, and just.