Epstein Survivors Amend Their Lawsuit Filed Against The U.S. Government (Part 6)

H.

The FBI's failure to investigate caused plaintiff's harm.

By failing to investigate credible allegations of CSAM, human trafficking, and sexual abuse, the FBI violated its own protocol and acted negligently.

The FBI's inaction and negligence allowed this abuse and trafficking, including to plaintiffs, to continue for over 20 years.

Had the FBI followed mandatory protocol and appropriately responded to that evidence, plaintiffs would not have been raped, molested, trafficked, and abused.

Epstein could not and would not have sexually trafficked, abused, assaulted, and battered plaintiffs in New York, Florida, New Mexico, the U.S. Virgin Islands, and elsewhere, but for the FBI's negligence.

Cause of action, count number one.

Negligence under the voluntary undertaking doctrine.

Plaintiffs incorporate by reference the allegations contained in all preceding paragraphs.

Duty.

Under the voluntary undertaking doctrine, one who undertakes gratuitously or for consideration to render services to another, which he should recognize as necessary for the protection of the third person or his things, is subject to liability to the third person for physical harm resulting from his failure to exercise reasonable care to protect his undertaking if, A, his failure to exercise reasonable care increases the risk of such harm, or B, he's undertaken to perform a duty owed by the other to the third person, or C, the harm is suffered because of reliance on the other or the third person upon the undertaking.

This duty applies to agents, servants, and or employees of the FBI and the Department of Justice.

Breach.

The FBI and the Department of Justice rendered law enforcement services to American citizens and failed to exercise reasonable care, A, in complying with mandatory investigative procedure that the FBI had adopted as a standard of conduct for handling information, B, in complying with non-discretionary duties not to falsely assure people possessing credible information and evidence about ongoing sex trafficking, C, in performing the task of investigating complaints and other information regarding Epstein's abuse of women and minors, and D, in the way it handled information regarding Epstein's abuse of women and minors.

The FBI failed to exercise reasonable care in the following ways, among other negligent acts and omissions already known and to be revealed in discovery, failing to properly investigate or follow up on a report received from Maria Farmer in 96 of sexual abuse, trafficking, and CSAM possession, B, failing to properly respond to tips and reports regarding sex trafficking of minors and sexual abuse of minors from 1996 to 2005, C, failing to investigate or follow up on Ms. Christensen's allegations of sexual abuse and trafficking in 2005, D, failing to follow up on the investigative reports and tips of suspicious banking activity from financial institutions, including payments to minor girls, E, failing to properly investigate evidence provided by the Florida Palm Beach Police Department, F, negligently investigating reports of a 14-year-old being sexually abused in Epstein's Palm Beach mansion, G, negligently failing to investigate child sexual abuse material during the 2005 raid of Epstein's Palm Beach mansion, H, negligently failing to interview and assist the victims whose names were on the important message from 2001 to 2005, J, negligently permitting Epstein to be a judge at a beauty pageant in the U.S. Virgin Islands in 2007, despite impending charges of sex trafficking of minors and sex abuse, J, negligently permitting via the clearing of background checks for passengers on Epstein's private jet, Epstein to traffic minors and young women, K, ignoring reports of violence and threats to victims if they cooperated with authorities, L, ignoring reports of child sex trafficking, M, ignoring evidence of minors procuring other minors for sex abuse, N, prematurely closing an FBI file in the face of evidence of sex trafficking and minor sexual abuse, O, ignoring reports of suspicious banking in SARS, P, ignoring child sexual abuse material and sea porn, and Q, failing to follow up on improper issuing of passports and federal passport fraud.

The FBI and the Department of Justice failure to exercise reasonable care increased the risk of such harm.

Indeed, if the FBI and the Department of Justice had exercised reasonable care, plaintiff would not have been trafficked or abused.

Plaintiff suffered harm because of the reliance on others on the FBI and the Department of Justice and its failure to properly act, including but not limited to Maria Farmer, Audra Christensen, Annie Farmer, J.P. Morgan, and the Florida Palm Beach Police Department.

Causation.

As a direct and proximate cause of the FBI and Department of Justice negligence, plaintiffs would not have been and or would not have continued to be sex trafficked, abused, raped, tortured, and threatened.

The FBI and the Department of Justice failure to investigate the tips and information it had received and failing to follow its mandatory established protocol was a direct and substantial cause of the plaintiff's damages.

If the FBI and Department of Justice had complied with its mandatory obligations to investigate and intervene based on the information it was receiving, Epstein would not have been able to continue to commit the heinous crimes he did against plaintiff.

The FBI's repeated and continued failures, delays, and inaction allowed Epstein and others to continue their sex trafficking conspiracy for almost twenty-five years.

Damages.

As a direct and proximate cause of defendant's negligence, plaintiffs were sexually abused, raped, assaulted, tormented, violated, harassed, intimidated, and suffered permanent injuries, including but not limited to severe emotional and physical pain and suffering, post-traumatic stress disorder, insomnia, anxiety, shock, fear, nightmares, shame, embarrassment, lost earnings, flashbacks, need for future medical and psychiatric expenses, and other severe injuries.