Case 5:16-cv-00797-DMG-KS Document1 Filed 04/26/16 Page5of6 Page ID#:5 1 MATERIAL WITNESSES 2 18. Tiffany Doe, a former trusted employee of the Defendant, Jeffrey E. Epstein, has agreed to 3 || provide sworn testimony in this civil case and any other future civil or criminal proceedings, fully 4 || verifying the authenticity of the claims of the Plaintiff, Katie Johnson. Witness Tiffany Doe was 5 |lemployed by the Defendant, Jeffrey E. Epstein, for more than 10 years as a party planner for his 6 || underage sex parties. Despite being subject to constant terroristic threats by Defendants Epstein 7 |jand Trump to never reveal the details of these underage sex parties at which scores of teenagers, 8 land pre-teen girls were used as sex slaves by Defendant Epstein and Defendant Trump, witness 9 || Tiffany Doe refuses to be silent any longer. She has agreed to fully reveal the extent of the sexual 10 || perversion and physical cruelty that she personally witnessed at these parties by Defendants Epstein 11 jjand Trump. 12 19. Material witness Tiffany Doe fully confirms all of Plaintiff Katie Johnson's allegations of 13 || physical and sexual abuse by Defendants Donald J. Trump and Jeffrey E. Epstein. Tiffany Doe was 14 || physically present at each of the four occasions of sexual abuse by Defendant Trump upon the 15 || person of Plaintiff Johnson, as it was her job to witness all of the sexual escapades of Defendant 16 || Epstein's guests at these underage sex parties and later reveal all of the sordid details directly to 17 || Defendant Epstein. Defendant Epstein also demanded that Tiffany Doe tell him personally 1 || everything she had overheard at these parties explaining to her that "knowledge was king" in the 19 || financial world. As a result of these underage sex parties, Defendant Epstein was able to accumulat 49 ||inside business knowledge that he otherwise would never have been privy to in order to amass his 21 || huge personal fortune. oy) 20. Material