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USITED STATES DISTRICT COURT l es 5 SOUTHERN DISTRICT OF NEW YORK a rcv 00m JILL HARTH HOURANEY Plaintft, DONALD J. TRUMP, NICK RIBIS and = - ROGER WAGNER, we JURISDICTION: |. This action is brought pursuant to 42 U.S.C. 1985 (2) (3), 42 U.S.C. 1986, Ninth and Thirteenth Amendments to the U.S, Constitution. Jurisdiction is founded on 28 U.S.C. 1331, 1332 and 1343 (3)(4) on the basis of diversity of citizenship. The plaimtft is 4 resident of the State of Florida and the defendant Trump isa resident ofthe State of New York and defendants Ribis and ‘Wagner are residents of the State of New Jersey 2 Plaintiff invokes the pendent jurisdiction ofthis Court pursuant to 28 U.S.C. 1367 to adjudicate state law claims as to violations ofthe State of New York Civil Rights Law, Sec. 40, the laws and constitution ofthe State of Florida, prima faci tort sounding in “outrageous conduct," defamation and intentional infliction of emotional distress. ‘The Piaintitt 3. The plaintif Jill Harh Houraney is citizen of the State of Florida and resides at 7134 San Sebastian Drive, Boca Raton, Fla ‘The Defendants ‘4 The defendant Donald J. Trump, at all times herinafter mentioned, isa citizen of the State of New York and resides at 721 Frith Avenue, New York, N.Y. Defendant Trump is being suod in defendant’ individual capacity 5. The defendant Nick Riis, tal times hercinafler mentioned is citizen ofthe Sate of New Jrscy and resides in New Jersey. Defendant Ribis, who is in charge of defendant Trumps casino interests in Atlantic City, is being sued in defendant's individual capacity 6 The defendant Roger Wagner, at al times hereinafter mentioned, is citizen ofthe State of New Jersey and resides at 93 Lagoon ‘Blvd. Brigatine, NJ. Wagner, formerly President of the Trump Castle casino in Atlantic City, NJ, is being sued in his individual capacity Statement of Facts 7 Onor about December 11th, 1992, the plaintiff aecompanied George Houraney to make a business presentation to defendant By DAN ABRAMS. ‘Gi (@) The American Dream Festival is an eventorinted affair that includes a "Calendar Girt” competition, whereby youns, ‘often vulnerable female contestants compete for prizes and tls. Additionally, musi, comedy and autmomotive design competitions area major pat ofthe festival (©) Defendant Trump expressed an interest in participating in American Dream's annual affair as a joint venture between Mr. Houraney and Trump. (©) George Houraney was and isthe principle owner of ll rights, ile and interest in American Dream Festival and its component "Calendar Git" competition. Defendant Trump, trough agreement between defendant and Mr. Houraney, became @ 0% partner in American Dream Festival a the main sponsor ofthe 1993 event (4) Plain Ji Harth Houraney was an employee of American Dream Festival, which was plain’ sole source of income, and as a result ofthe agreement between George Houraney and Trump, became subjected tothe control and authority of Trump. 8. That during the aforementioned meeting and presentation in New York, defendant Trump inquired of Mr. Houraney about the plain to wit: "Are you sleeping with her” and further demanded 1 know whether it was “ust for the night or what?" 9. On or about December 12th, 1992, aa subsequent business dinner/meeting al the Plaza Hotel to discuss the newly-formed venture between American Dream Festival, the defendant Trump repeatedly put his hands on plaintiff's thighs and violated plains “physical and mental integrity” by attempting to touch plaintiff's intimate private parts in violation of plaintiff's fundamental constitutional right o privacy and physical autonomy asa citizen ofthe United States 10. That the defendant Trump later onthe evening of December 12th, 1992, began introducing plaintiff to Trump business associates atthe Plaza Hotel as defendant's "new gilftiend.” though i fact plaintiff was only a business associate of defendant Trump. 4H. That in the presence of plaintiffs co-employer Mr. Houraney, the defendant Trump made denigrating, lewd comments about all women in general as "sex objets,” comparing the plaintiff with other women, and suddenly declared to Mr. Houraney: "You know, there's going o be a problem, I'm very atracted to your gilfiend.” 12, Defendant Trump began making repeated personal "sexual" demands of plain which included aempks to lure plant to ‘defendant's Trump Tower apartment for late-night meetings to talk and havea drink but in fact constituted defendants stated interest to exploit plaintias a "sex object and slave" to satisfy defendant’ sexual appetite asa self-described "stud" 13, Paint became emotionally distraught and feared reprisals because of plaintiff's rejection ofthe sexual demands of defendant, ‘who was unrelenting i his pursuit of plain asa "sex object." Plain was aware that Trump had a prior history of abusive and ‘sexual mistreatment of women in general, constituting a class-based invidious discriminatory animus towards all women, to wit: LAWNEWZ By DAN ABRAMS. ta (@) Defendant's ex-wife Ivana caught the defendant sneaking "sex object” Marla Maples into Trump Tower to cavort sexually with Maples in Ivana's marital chambers, (©) During divorce proceedings initiated by Ivana against the defendant Trump for engaging in sexual acts of fornication with Maples in violation of N.Y. Criminal Penal Law 255.17, which proscribes adultery as a Class "A* misdemeanor, Ivana accused ‘Trump of marital rape, spousal battery and physical abuse. (©) That defendant Trump consistently humiliated self-admittedadulterer/ paramour Marla Mapes, i that were possible, by ‘making « public spectacle of Maples through routine public announcements in press releases and statements to the media that ‘Maples was being, dumped, (@) That defendant Trump, after being the subject ofa negative article in the Village Voice, owned and published by Leonard Stem, spread false malicious "sexual innuendo" to the public about Stern's wife Allison, asserting that Mrs. Stern asked defendant for sex, which was Trump's way of retaliating against Stern for telling the truth about how Trump cheated his banks, bondholders, investors and the government, suggesting Trump should be jailed for tax evasion. (©) That defendant Trump made lewd, derogatory sex-oriented remarks about a British female broadcast journalist, who dared 10 criticize Trump as a baffoon, short-fingered vulgarian and womanizer who betrayed his ex-wife and three children with an adulterous affair. (That defendant Trump resorted to personal attacks on Justice Phyliss Gangel-lacobs of the Supreme Court ofthe State of ‘New York as a woman because Justice Gangel-Jacobs concluded that Trump was an adulterer who betrayed ex-wife Ivana and awarded substantial sums to Ivana. (8) ‘That defendant Trump spread racial slurs and malicious gossip about black actress Robin Givens to business associates and the media, including that Ms. Givens left marks from her “white (ccth" on defendant's genitals during alleged oral scx with defendant, 14. Defendant Trump subsequently engaged in further Svengali-type acts to control and subjugate plaintiff to defendant's will with demeaning and perverted communications demanding that plaintiff become defendant's sex slave: (@) On or about January 4th, 1995, defendant made numerous telephone calls to plaintiff in Boca Raton, Fla,, from New York demanding that plaintiff "sleep with him" (b) On or about January 9th, 1993, ata business dinner party at defendant's estate in Palm Beach, plaintiff out-of-fear of reprisals relented to defendant's demands that plaintiff be seated next to defendant, whereupon defendant again sought to violate Plaintiff's “physical and mental integrity" by depriving plaintiff of her constitutionally-protected fundamental right to privacy in plaintiff's physical autonomy by mancuvering his hand up plaintif thigh in an attempt wo touch plaintiff's private parts, LAWNEWZ By DAN ABRAMS. tea © Onor about January 24th, 1993, plaintiff had no choice with regard to defendant Trumps demand that plain atend a business mestng at defendants estate Mar-A-Lago in Palm Beach, Fla, After Trump busines associates lft, the defendant over Plaintiffs objection forcibly prevented plaintiff rom leaving and forcibly eemoved plaisff to a bedroom, whereupon defendant subjected plaintif to defendant's unwanted sexual advances, which included touching of plaintiff's private parts in an act constituting attempied "rape" (0 Before the defendant would allow plaintiff to leave the bedroom, defendant placed a cal o defendan/co-conspirator Roger Wagner in Atlantic City, New Jersey saying that defendant wanted to make defendant Wagner aware of how plaintiff "was so ‘beautiful and Roger loves beautiful women, too." (1 Defendant Trump proclaimed that defendant "did not want a scandal like Willie Smith had in Palm Beach,” inferring ‘that plaintiff should "keep her mouth shut." (GAs plaintiff attempted to lave the premise, defendant Trump again became sexually abusive by intimately touching, plaintifs person and unering Svengal-type proclamations of "love." Plaintiff immediately bocame nauseated and vomited profusely ©) Plaintiff fet degraded and humiliated asa female, human being. and citizen of the United States by defendant Trump's “eutrageous” conduct in violation of plaintiff's constitutionally-protected right to privacy in plaintiff's “physical and mental integrity" and "physical autonomy as a female” for defendants sole purpose of relegating andlor otherwise subjugating plaintiff tothe status of "sex slave" to satisty defendant's sexual pervisions, ignited by defendan’s general hatred and class-based, invidiously