ya Court fle: Document# 001 Filed: 08/21/2020 (submission) Page 1 of 11, UNITED STATES DISTRICT COURT NEWYORK Charlene Y, Latham, plaintiff 1 David G. Latham, plaintiff 2 Tracey Y. Latham, plaiatit! 3 Case No. Joha Doe (1-10) Case type: civil Doe (1-5) Judge xe PLAINTIRF’S STATEMENT 1. The 1983 Trust, Defen 2. Marv 3. Shawn Carter, defendant 4 Darren Indyke, defendant 5. Richard Kahn, defendant 6. The Weinstein Corporation, defendant Miramax, lic. (aka Miramax Films), defendant X. The Walt Disney Company, defendant 9. Def Jam Recordings, defendant scnation, Ue., defendant sal Music Group, defendant 12, Beyonce G Knowles, detendant 3. Kanye Q. West, defendant 14, Yerrence Thornton, defendan Weinstein, d OF THE CASE 18, Black Cube Itd.. defendant 16. Vivendi SA, defendant Bg 17, Dwayne Carter. dete = 2 18. Jean Luc Brunel, dever S xa 9. Young Money Enter 1, defendant 2 25 . 0. G.0.0.D. Music, defendant wm 2), Shelley Massenburg-Smith, defendant 2 22. David! Boies, defendeat g £3. Robert Kelly, defendant a Milton Brown, defendant . Marcello Claure, defendant sprint Corporation, defendant ViacomCBS. defendant 8. Virgil Abtob, defendatt 9, Quatar investment Authority, defendant 1. Lutor-Saliba Corporation, defendant J. Ghislaine Maxwell, defendant 2 Parkwood Entertainment. defendant 3 the City of New Vak: New York City Potice Department, defendant 4, Sir Philip Green, devendant 5, Sony Tntertainment, defendant 46, Jolin Does (1 ~ 100), defendant(s) ne Does (3- 1100), defendant(s) S Corporation Does (1 ~ 109), defendant(s) | gael a EY A ERCase 1:20-cv-07102-LLS Document 2 Filed 08/51/20 Paye 2 of Court file Documenta 001 Filed: 08/21/2029 (submission! Page 2 of a2 LAINTIFE'S STATEMENT OF THE CA’ Plaintif' #1 enters this statement as Formal statement of the case against ull efendants as captioned in page one of this statement 2. ‘The “Doc Defendants, ineluding corporations and their executive or involved personnel, are fully included in this action; The “Doe” Defendants represent employees, partners, collaborators, vendors, heirs, é related entities whose identities & specifi criminal rales have been intentionally third parti ‘concealed or withheld by the Defendants to prevent their being brought to justice by being named in this {and other) civil complaints while intentionally being made unavailable to the Plaintiff's) of this action 9 to avoidl redress, Corporate Defendants named or identified as “Does” are accused of aiding and abetting in the facilitation of the unlawful surveillance (spying), stalking and repeated drugging, abxtucting, hostape taking and kidnapping for the criminal intent of sexual assault, abuse, extortion and exploitation in the same eapacity as any Person named as Defendant & in their capacity as Corporations providing support aters/conspitators and to the criminal enterprise of the Defendants 1-1 as corporate purveyors, fil including by providing money laundering services to rouce payments to the parties of this large scale criminal enterprise of erimine! activity targeting the Plaintiffs 4. Some “Doe” Defendants’ identities are not revealed at the time of filing this Statement to protest er ions 0 preserve any ctiminal inw curring that may be jeopardized or undermined if the Plaintitf(s) reveal certain “Doe” Defendants identities at this stage of the proceedings. 5. Over the course of decades, the Defendants established a lucrative but sociopathic. criminal enterptt where the Delendants engaged in decades of human trafficking. sexual ussaults and various abuses including financial & economie exploitation, dragging for abduction, taking PlaintiM(s) #) and Plai Tobn & Jane Doc (1 -10) hostage. e¢ alCourt fie: Document# 001 Fil : 08/21/2020 (submission) Page 3 of 12 6. “The Defendants engaged in this criminal and sociopathic conduct as a form of specific criminal intentions designed as sexval harassment, extortion, physical torture, psychological torment and revenge targeting Plaintiff 43 for her refusal to sell her child. (Plaintiff #1) or children (John Doe & Jane Doe Plaintiffs) to the Defendants 1-3. 7. When Plaintif'#3 refused to sell or allow the Defendants, in any capacity, to sexually abuse or ‘inancially exploit Plaintiff 41 o any of her other children and grendehildren (represented as John & Jane Doe Plaintiff’ 1-10) at any time, the Defendants began targeting the family for economic abuses and financial exploitation that not only consisted of drugging the children of Plaintiffs 283 for sex trafficking, hostage taking and related abuse but also began exploiting the Plaintiffs for thefts of rade secrets, intellectual property and Cortious interference in the Plaintiffs’ carver and economic opportunities. 8. This extensive scheme of the Defendants was initiated by Jelfrey Lipstein, the decedent represented throughout this action by his estate The 1953 Trust, as revenge against Plaintiff #3. 4. Plaintiff #3 agreed to out of court multi-million dollar monetary settlement in the late 1980s/early 1990s to avoid a public criminal and eivil prosecution for Epstein’s sexual abuse of several of the Plaintiffs 2 & ¥'s children; Plaintiffs 2 & 3 share 6 children together (3 sons, 3 daughters & approximately 14 grandchildren) 1" After misappropriating Leslie Wexner's money to pay the settlement, Jeffrey Epstein devised a scheme of revenge and recovery of the money by targeting the Plaintiffs for dragging and tratlicking the children for continued abuse at his various orgies around the world where he was paid large sums by lite” attendees of the salacious events agd then used the money from abusing the Plaintiffs to repay hi det w Wexner 11. The decades of abuse and sexual assaults were equally to the benefit, entertainment and economic enrichment of the Corporations as well as facilitated, in whatever capacities, by the Corporations’their managers and personnel as by any Person named as defendant.Case 1:20-cv-07102-LLS Document? Filed 08/31/20 Paye4of 13 ~~ Court file: Document 001 Filed: 08/21/2020 {submission} Page 4 of 11 12 This action is in the US Southem District Court of New York because itis where the Defendants* id when she conspiracies to taffick and exploit for criminal sexual intent targeting PainGilT #1 oceur was a minor child belonging to and in the custody of Plaintiffs 2 & 3 13, Over the course of thirty years, since at least 1988 oF 1989 the Defendants did conspire to unlawfully surveil, drug and abduct for sexual assault, sex trafficking, and other exploitative abuse Plaintiff #1 around the world: specifically throughout the Southern District of New York. 14, This action is entered into the US Southem District Court of New York as it is one jurisdietinn in which the Defendants abducted Plaintiff #1 (0 at approximately age 13 to sexually assault & exploit sexually for financial gain. 15. The Defendants Harvey Weinstein, Shawn Carter, Jeffrey Epstein (represented in this action as defendant #1 The 1953 Trust) conspired together and with the other Defendants to illegally 1 misuet a “purchase agreement” giving them “ownership” of Plaintiff #1 while she was a minor child residing in the state of Tinois at approximately aged 5 or 6 years old in the custody of her Parents, Plaintiffs 2 & 3 \with the intent of committing criminal sex acts against the Plaintiff as a child and throughout the ourse of her entire adult life 16.The Defendants 1, 2, & 3 at no (ime communicated with not received permission from Plaintiffs 2 & 3 (ihe biological and custodial parents of Plaintiff #1) to purchase Plaintiff #1 or otherwise take possession of her at any time as a minor child 17. Over the course of at least thirty years and longer the Defendants conspired to surveil or stalk Plaintifl | & 3 inorder to track the female Plaintiffs with the intent to commit various sex acts, ef al. against them. 18. The Defendants 1,2, & 3 conspired with the various parties & corporations named as defendants to stalk the Plaintiffs in order to drug, abduct and traffick the Plaintiff #1 to various “events” known as “Sex parties” hosted by the now decedent, Jeffrey Epstein, (represented as Defendant #1) around the world for abuse by “elit igh profile/wealthy purveyors held at all of Defendant #1°s properties, including in the United States & Virgin {slands with the intention of commiting crimes against the PlaintiffsCourt file: ocument# 001 Filed: 08/21/2020 (submission) Page 5 of 11 19, Atage 13, specifically, the Plaintif #1 was stalked in the State of Missouri, drugged & tralficked to be sexually abused at an “event” at 9 Bast 71% Street Manhattan NY 10021 by the conspiring Defendants 2). Atihis piece of property owned by Defendant #1, Plaintiff #1 was sexually assaulted by various parties in attendance, specifically Harvey Weinstein and Shawn Carter 21, The Defendants #2 & 3 willfully & forcibly raped Plaintiff #1 and committed lewd and sexual acts against and upon her without consent of any Plaintiffs at this “event” held at the Manhattan property. 22, The Plaintiffs were repeatedly stalked, placed under unlaw{ul surveillance, dragged. abducted and trafficked for sexual assault, abuse and exploitation at regular interval over the course of the more than 20 years after the attack at the Manhattan townhouse owned by Defendant #1 25, Jeffioy Ppstein (represented as Defendant #1) conspired with Harvey Weinstein and Shawn Carter to initiate « system of stalking, surveillance, drugging, abducting and trying to physical control, abuse or Financially exploit and extort the Plaintiff #1 24. ‘This conspiracy was in revenge/retaliation for setiling 2 multi-million dollar lawsuit out of court with Plaintiff #3"s mother for Epstein’s crime of sexually abusing Plaintiff #1 and several of her siblings aboard the “Lolita Express” private jet with the currently deregistered tail number of N9U8IE and on “Pedophile Island” the privately owned Little St. James. Island in the late 1980s to carly 1990s after being entrusted with the unsupervised care of the children. 25, The Defendants conspiracy to operate this criminal enterprise targeting the Plaintiffs spanned the entire nation of the United States: anywhere the Plaintiffs traveled or resided. 26. The Defendants’ system of stalking, drugging and trafficking involved a complex, sophisticated criminal network established among and in tandem with all of the Defendants to traffick Plaintiff #1 for their abuse, exploitation, entertainment and criminal intentions of racketeering, extortion and sex crimes,Case 1:20-cv-07102-LLS Document 2 Filed 08/81/20 Page 6 of 13 Court file Document# 002 Filed: 08/21/2020 (submission) Page 6 of 11 27, This complex network of the eriminal enterprise targeting the Plaintiff involved the Defendants s. abducting and compensating the co-conspirator Defendants for their crimes of stalking, drupe 3 through use of various business transactions assaulting the PlaintitT 41 at the behest of Defendants 1 ~ including but not limited to offering and or facilitating employment contracts, lucrative partnership contracts such as record deals, fashion industry ventures and other assorted goods and services; such as ord company perks like lusury cars, hoasing/real estate gifts and large sums of cash disguised as advances” and other “legitimate business deals” for decades. 2. The Defendants engaged in intentional tortious interference, kidnapping and holding the offspring of Plaintift #3 ( specifically Plaintiff #1) hostage by routinely “hiring” Defendants to stalk and illegally surveil the Plaintitis and interact with the Plaintiff #1_under the disguise of “befriending” her or having CE “romantie” or “business” interest in any of the Plaintiffs so that they could use th facilitate exploitation, hostage taking and abuse targeting the aforementioned Plaintifts ‘This deception to commit iortious interference was done regularly to allow the Defendants case of cessing the Plaieniffs’ private life and spaces when Plaintiff #3 began violently demanding the ee Defendants 1-3 (Defendant | is representative of the Deceased, Jeffrey Epstein) immediately cease and desist their extensive harassment, stalking and kidnapping campaigns against her and her family. 30. Plaintift #3 was made aware of the Defendants activities by numerous witnesses who cofused to participate in the criminal operations after being solicited for hire to partake in the ¢riminal operations and receive very lucrative compensation packages including large sums of cash and high-profile entertainment contracts such as high visibility marketing and promotions opportunities. #3 did take 31. When informed of the conspiracy targeting her and her minor children, the Maint numerous and repeated action to demand the Defendants cease and desist all illegal or abusive conductCourt file: Document# 001 Filed: 08/21/2020 (submission) Page 7 of 14 32, 36 “The Defendants 1-3, however, engaged in establishing a thorough network of criminal operatives to facilitate their enterprise of spying, stalking, unlavwful surveillance, breaking and entering, tortious intetference, numerous sexual assaults, sexual battery, financial exploitation, physical abuse, emotional harm, psychological torture, sexual harassment, lewd conduet, kidnapping, human trafficking and extreme abuses for decades specifically targeting Plaintiffs 1 & 3 and their offspring rather than cease and desist their criminal enterprise. I his criminal enterprise orchestrated by the Defendants escalated beyond the sexual assaults, abuse, harassment and emotional harm into intense and extensive financial exploitation of the Plaintiffs I~ 3 and their offspring/ Jane & John Doe Plaintit ‘The Defendants repeated abduction and hostage taking of the children of Plaintiffs 2 & 3 caused therm emotional harm and caused finaneial damages in the course of regaining possession of the children. { other industries were forfeited in Lucrative career contracts in Professional sports, entertainment exchange for o consequence of redressing the crimes targeting Plaintitt #2 & # 's shared 6 (six) biological children; including but not limited to Plaintiff #1 When the Plaintifis could not be used for sex trafficking exploitation, the Defendants exploited the Plaintifis’ economic prowess and unique abilities to pick stocks, predict business/market trends, create very lucrative trade secrets, create lucrative intellectual property and develop very profitable business concepts and consumer products in a diverse array of industries. . The Defendants orchestrated a criminal enterprise valued at billions of dollars by the trafficking and economic exploitation of the Plaintiffs for which the trade secret thefts and related business/intellectual property crimes played a significant role in the profitability of the criminal enterprise and such crimes are being addressed in separate actions in the appropriate jurisdietion(s)Case 1:20-cv-07102-LLS Document 2 Filed 08/31/20 Page 8 of 13 Court file Document# 001 Filed: 08/21/2020 (submission) Page 8 of 12 38 — 29; 40. 4 “The Defendants began stalking and surveilling the Plaintiff #1 as a child to misappropriote trade secret, intellectual property and other business and creative works of the Plaintlls over the course of at least 3 decades with no intention of stopping despite repeatedly being demanded to by the Plaintiffs | 3 this Financial exploitation became very luerative for the Defendants where hundreds of millions to billions of dollars have been collected/earned worldwide by the Defendants thr rough their decades of exploiting the Plaintiff's creative and intellectual abilities while under the intense of constant surveillance of the Defendants who used audio, visual, and conspiring to beftiend/date the Plaintiffs 1 & Ly to collect the private information or trade secrets and intellectual property in the furtherance of 3 sti this criminal enterprise expanding beyond the deseribed sex erimes, The Jiction for the extensive trade ‘aintift #1 is seeking civil redress in a separate complaint and juri secret infringement, economic espionage, economic terrorism, and assorted extreme financial exploitation and abuses committed by the Defendants against the Plaintiffs. Plaintiffs have only mentioned the Defendants worldwide abuse and unlawful use of (rade secret. intellectual peoperty initingements, abuse of Plaintiffs 1 & 3's likeness in the development and worldwide marketing of numerous high profile singers, rappers, entertainers und entertaizinent projects including but not limited to musical albums, music videos, television shows, ef ai, in this action to: provide scope of the ubuse endured when the Defendants were unable 10 drug, abduc/kidnap the Plaintiff #1 for repeated drugged sexual assaults or hold hostage for ransom by the Defendants and theit criminal enterprise, This action captioned in the header, filed in the US Southern District of NY is specifically redressing the t decades of sex erimes targeting the Plaintiffs and their offspring.Court file Document# 001 Filed: 08/21/2020 (submission) Page 9 of 11 43. 44, 46, When the Plaintifis were able to prevent the drugged. abductions for sexual assaults against the Plaintift ‘as a minor child and well into her adulthood, the Defendants 1- 3 responded by engaging in extreme (orms of harassment that they conspired with the other Defendants to initiate or facilitate, his harassment includes, but is not limited, to sexual assaults, feticide, sexual harassment, verbal ‘abuse, psychological torture/harassment such as “gaslighting” and paying Defendants to collect sexual data or other sexually explicit content featuring the Plaintiffs | & 3 by engaging in sex acts that would be classified as sexual battery in various jurisdictions on hidden cameras. The harassment includes ereating pedophilia where the Plaintift #1 (and other Doe Plaintiffs) were recorded in various states of undress as minors, in private spaces and when drugged & trafficked aboard the private jet owned by Defendant #1, as well as other spaces, for sexual assault where Plaintifl #1 (& other Doe Plaintiffs) were being present Hild prostitute(s)” to the “clients” of the Defendants. Plaintiff #1 submits this Statement of the ‘ase to obtain justice to disrupt the Defendants ongoing actions to obstruct such justice while retaining and or generating profits collected rom the abuse of the Plaintiffs as outlined above and throughout the detailed formal complaint pending submission into the ed by deceiving all parties, Defendants attempt at hiding all involvement in the Defendants’ sophisticated scheme of operating a criminal enterprise of human trafficking and trade secret thefl has been ongoing for more than thirty oe years and the ongoing criminal conduct indicates the Defendants spirited refusal to stop the conduct and their interest in continu 110 enjoy the lavish profits from the criminal enterprise that they report to the public and government as legitimate income. busin ss operations and or financial/economic gains. Plaintiff reserves the right w transfer the action or complaint to alternate jurisdictions, as necessary in the interest of justice, and amend the action to include the full/correet names and identities of anyCase 1:20-cv-07102-LLS Document 2 Filed 08/31/20 Page 10 of 12 Court file: Documenté 001 Filed: 08/21/2020 (submission) Page 10 of 1i PP plaintiffs), to add the Defendants whose names’ identities have been withheld or made unavailable ut the dime of this action and listed as “Doe Defendants” at the time of filing this statement wr for Re 4 For these reson ts oid i para aphs 1 - 48 the Plaintiffs are demanding pecuniary damages in the amount af $500, 000. (000 (five hundred million dollars) in puoitive or general damages in this action submitted in the US District Court of the Southern District of New York Plaintiffs demand court ordered permanent cease and desist restraining orders be issued against all of the of Defendants to cad any and all of the Defendants’ decades long and continuing criminal conduct as \ outlined in (his action where the Defendants have made a sociopathic, decades long scheme of human trafficking, criminal sexual assault, financial exploitation, psychological torture, harassment, sexual harassment into a eriminal enterprise targeting the Plaintiffs 1 & 2 by alleging the Defendants 1-3 have a cteated a purchase agreement for and are maintaining ownership of Plaintiff #1 and Plaintift 283° other offspring (some of whom are still minors). 51, Plaintitis demand court ordered, permanent cease and desist with restraining order issued against the Defendants be extended to Jude all members of the Plaintifts’ families: including children, grandchildren, extended family (cousins, aunts, uncles, grandparents, ete.) and the Plainti businesses business partnerviclients, friends and romantic partners such as spouses or unmarried lavers anywhere in the world due to the Defendants having shown a very specific interest and propensity for targeting with criminal intentions .ineluding but not Jimited to, of harassment, spying, stalking, tortious interferenc financial exploitation and criminal sexual intents the People and Businesses closely associated with the Plaintiffs. 52, Plaintiffs demand any and all fair & equitable relief as available to award by the court to red: damages the Plaintiffs" sustained through the decades of trauma from the exploitation, sex crimes, child abuse, sexual assaults resulting in Feticide, sexual harassment, financial ahuse’economic damages,Court fite: Document# 002. Filed: 08/21/2020 (submission) Page 14 of 11. discrimination, child sex/human trafficking for profit, numerous & repeated drugged sexual assaults, sexual battery, tortious interference in relationships (both business and personal), unlawful surveillance (spying), gross invasion of privacy, cross-country stalking of a minor, cross-country stalking of adults, psychological torture, repeated kidnappings/abduetions, hostage laking and emotional harm, et al, outlined in this civil action, The Plaintiffs sustained these damages that were caused intentionally or con sequentially from the numerous erimes & unlawful aets willfully committed against them by the Defendants in the Defenda reckless & wanton disregard for the law in perpetrating a lucrative criminal operation targeting the Plaintiffs. Despite the Piaintiffs numerous and repeated demands for the Defendants to cease & desist their extreme and egregious criminal misconduct since at least 1988 the Defendants extreme conduct has continued, in various forms, throughout the year 2020 with little to no intention of the Delendants willingness to stop their criminal conduct without lawsuit or their arrests on erimin Jharges to totally disrupt or disband the global criminal enterprise they’ve erected over three decades, I declare under the penalty of perjury that above statements contained in this filing in the United * States District Court in the Southern District of New York are true and understand the penalty of any ned in the County of Dalllas, State of Texas, August 20,2020 3:10pm See eee * Submitted rg fully e Char hr Charlene272@hotmail.com 14469,751.5068 4900 Airport Parkway Addison TX 7500!Case 1:20-cv-07102-LLS Document 2 Filed 08/31/20 Page ‘August 20, 2020 ‘Attn: USDNY COURT Pro Se Intake Unit (Room 200} 500 Pear! St NY NY 10007 AE: Latham(s) v. 1953 Trust, Harvey Weinstein, Shawn Carter & other defendants; Court Action: Plaintiff Statement of the Case Dear Court: lease allow this correspondance to explain that |, Charlene Latham, one of the Plaintifs, submitted the enclosed document “Plaintiff Statement of The Case” to initiate the action and obtain a case number, The pending formal complaint will be submitted separately. ‘Additionally, formally request permission to use the Electronic Case Filing system. | have experience in using the ECF system for other jurisdictions and did begin completing the required training course to use the New York ECF system, | have technical experience and legal experience to be permitted use and consent to receiving all case communication electronically via the email provided below. tis requested that all communication be sent electronically as the USPS mail delivery system has been extremely stisrupted and almost inoperable in use for me to receive mai in traditional formats for the past 27% years. The USPS failure to deliver or process mail for more than 2 years is a separate, but ongoing, issue that would also make it necessary to use the ECF system, Thank you for your attention Signesagspectiully, Charlene Y. Latham : (469) 751-5068 F, Charlene272@hotmail com Filed in US District Court of Southesn District of New York (08/20/2020ae +e ae @AVO-Z TVW ALRIONA as lAaS UNITED STATES DISTRICT COURT SOUTHERN DisTRICT OF New YORK Charlene Latham _ ‘Gio name of the lami ox pettioner applying (each person mist submit a separate ppliatior)) eo ; against [Droade doctet number, avaiable; Ting 0 your complar, you wil not yt havea docket number} 1953 Trust, Harvey Weinstein, Shawn Carter, & other defendants (Full namels) of the defondants)/respondent{s}) APPLICATION TO PROCEED WITHOUT PREPAYING FEES OR COSTS om a plaintff/pettioner in this case and declare that T am unable to pay the costs of these proceedings fand I believe that 1 azn entitled to the relief requested in this action. In support of this application to ‘proceed i jorna pauperis (TFP) (without propaying fees or cats), declare thatthe responses below are 1. Are yo incarcerated? Cl) ves No. Gi"No, goto Question 2) 1 aa being held at: na Ra Do you receive any payatent from thisinstitution? ["] Yee [7] Ne Monthly asnount /@ VW Taan a prisoner sce 28 US.C.8 19150), Thave attached to this document a “Prisoner Authorization” ldeecting the facility where I am incarcerated to deduct the bling fee from my account in installments tand to send to the Court certified copies of eny account statements for the past soc months, See 28 US.C 6 1915(a)0), 0b). Tunderstand that dhis aware: that 1 will he required to pay the ful filing fee. 2. Are you presently employed? —[] You No 11 'yen" my ecnployer'sruume and addres are Grosa monthly pay or wages: U8 Uno.” what was your last dateof employment? V/A Grose monthly wages at the me: VA 4, naddition to your income stated abave (which you should not repeat here), ve you or anyone else living at the same residence as you received more than $200 in the past 12 menths from any of the following sources? Check all that apply. {a) Business, profession, or other self-employment Cl ves Xe {t) Rent payatents interest or dividends Cl ves 58 No son tee: 15/2015, CO:OIMY 16 S9¥ 0202 7OI4sO 3S Od ANAS G3AI29ayCase 1:20-cv-07102-LLS Document 1 Filed {c) Pension, anmuty, of ie insurance payments X) ve (a) Disability oF worker's compensation payaesis BH No {6} Gifts or inheritances No @ Any other publictensfits (unemployment, social sewn Ci Ne food stamps, veteran's, ec) 2 Ox ( Any otter sources if you answered “est any qostion above deri Iniw an cepa pags ens sce of ae ie tngeangunt ut you reived nd what you papect to rceiye tthe [ay 408. in gtote unimpe ve bene wihl Dec. ldo 614, x SNAP bun hts 1 Dec: ABO , Fecleeol Pandetire inwmplayreun ti you unswored "No" to alc he quetions above explain how you are paying sour expenses: erein Foes vai Should be noted hat the Appicant sustained trata bran Ingury tn December 2017 Mal rested GGsamy and te nature cl the ams of compan rested mn severe fnanclaéPartsnips [C3163 4. How much money do you have in cash or in a checking, savings, or sanate account? nia; Applicant does not own any traditional checking accounts 5. Doyou own any automobile, real estat, stock, bond, security, trust, jewelry, att work, or ofbes Racrcad ietrument or thing of value, including any item of value held in someone else's name? If 30, describe the property and its approximate vale: ‘yes, 2000 Chevrolet Suburban owned value $1000 6. Doyou have any housing, transportation, ulti, of loan payments, or other regular monthly ‘expenses? If s0, describe and provide the amount of the manthly expense. ‘nausing and transpartaion expenses vary due to the Pander and hardships related tothe claims in the aeiin forces homelessness and Rhancial hardships) Average normal expenses total $2,500 per 7, LtPan people who are dependent an you for support, your relationship with ex persou, auch you contribute te their spport(oxly provide initial for usner» unter 18): ‘Appicaot provides fecal sopport to her Mother, 1 sister & ber 7 cheer, and 1 brotir, suppect drs bh typi moortay and covers cost including ition and domestic asista= 2 5. Doyouhave any debts of francal obligations not deseribed above? If so, describe the anvounts owed anal to whozn they are payable: ‘Approxemately $125,000 n scent oars Decliation; {declare under penalty of perpary that the tion is true, I understand that a false statement may sesclt in a dismissal of my claims. 8/20/2020 Dated re Reena tere latham, charlene y. ame (at Fi ih 5 aon eniticaion FE ereeraiedy ~ 4900 airport pk addison ~ 75001 naar a oy Smee us 469.751.5068 charlene272@hotmail.com Telephone Number 1EP Application, page ?UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CHARLENE Y. LATHAM: DAVID G, LATHAM: TRACEY Y, LATHAM: JOHN DOE (1-10); JANE DOE (1-5). Plaintiffs, | 20-CV-7102 (LLS) -against- ORDER OF DISMISSAL, ‘THE 1953 TRUST, et al., Defendams. LOUIS L. STANTON, United States District Judge: Plaintiff Charlene Y. Latham, a Texas resident, filed this pro se complaint alleging that the defendants conspired to violate her rights. Although the complaint lists other individuals as plaintiffs, only Latham signed the complaint o submitted a request to proceed without prepayment of fees, that is. in forma pauperis (IFP). The Court grants Latham leave to proceed IFP in this matter, but dismisses the complaint for the reasons set forth below. STANDARD OF REVIEW ‘The Court must dismiss an in forma pauperis complaint, or portion thereof, that is frivolous or malicious, fails to state a claim on which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e(2B): see Livingston v: Adirondack Beverage Co., 141 F.3d 434, 437 (2d Cir. 1998), The Court must also dismiss a complaint when the Court lacks subject matter jurisdiction, See Fed. R. Civ. P. 12(h)(3). While the law mandates dismissal on any of these grounds, the Court is obliged to construe pro se pleadings liberally, Harris v. Mills, $72 F.3d 66, 72 (2d Cir. 2009), and interpret them to raise the “strongest [claims] that they sugrest.” Triestman x: Fed. Bureau of Prisons, 470Case 1:20-cv-07102-LLS Document 3 Filed 09/24/20 Pag F.3d 471, 474 (2d Cir. 2006) (internal quotation marks and citations omitted, emphasts in original). ‘A claim is frivolous when it “lacks an arguable basis either in law or in fact.” Neiteke ¥. Williams. 490 US. 319, 324-25 (1989), abrogated on other grounds by Bell Atl. Corp. v Twombly, $50 U.S. $44 (2007): see also Denton », Hernande=. 504 U.S. 25, 33 (1992) (holding that “Finding of factual frivolousness is appropriate when ihe facts alleged rise to the level of the irrational or the wholly incredible”); Livingston, 141 F.3d at 437 (2d Cir, 1998) (“[A]m action is frivolous’ when either: (1) the factual contentions are clearly baseless or (2) the claim is based on an indisputably meritless legal theory.”) (internal quotation marks and citation omitted), BACKGROUND Plaintiff Charlene Y, Latham filed this complaint on her own behalf (“Plaintiff #1”) and on behalf of her parents. David G. Latham and Tracey Y. Latham (“Plaintiffs #2 and # respectively), and their “other children and grandchildren” (“PlaintifTs John Doe 1-10" and “Plaintiffs Jane Doe 1-5.") (ECF 24 7.) The 35 named defendants include: the City of New York: individuals such as Harvey Weinstein, Shawn Carter, Beyoncé Knowles, Kanye West, Robert Kelly, Ghislaine Maxwell, and David Boies: and entities such as Miramax. the Walt Disney Company, Def Jam Recordings, Universal Music Group. Sprint, Viacom. Sony, and “the 1953 Trust.” which is the estate of Jeffrey Epstein. Plaintiff alleges that Epstein “initiated” the events giving rise to this complaint, Plaintiff accuses the named defendants, and hundreds of unidentified defendants. of -establish{ing] a lucrative. but sociopathic, criminal enterprise,” and “engag|ing] in decades of human trafficking, sexual assaults, and various abuses including financial and economic exploitation, drugging for abduction, and taking Plaintiff(s) #1 and Plaintiffs John and Jane Doe (1 ~ 10) hostage.” Ud. § 5.) She also alleges that the defendants engaged in “sexual harassment,‘exiortion, physical (orture, and revenge targeting” her mother “for her refusal to sell her” children to them, She further alleges that the defendants “druggfed] the children” for “s trafficking, hostage taking, and related abuse but also began exploiting the Plaintiffs for thefts of trade secrets, intellectual property and tortious interference in the Plaintiff's career and economic opportunities.” (Id. 7.) ‘The complaint continues: Plaintis? #3 (Plaintiff's mother] agreed to an out of court multi-million dollar ‘monetary settlement in the late 1980s/early 1990s to avoid a public criminal and civil prosecution for Epstein’s sexual abuse of several of the Plaintiffs 2 & 3s children; Plaintiff 2 & 3 share 6 children together (3 sons, 3 daughters, and approximately |4 grandchildren, ‘After misappropriating Leslie Wexner’s money to pay the settlement, Jeffrey Epstein devised a scheme of revenge and recovery of the money by targeting the Plaintiffs for drugging and trafficking the children for continued abuse at his various orgies around the world where he was paid large sums of money by “elite” attendees of the salacious events and then used the money from abusing, the Plaintiffs to repay his debt to Wexner. ‘The decades of abuse and sexual assaults were equally to the benefit, entertainment and economic enrichment of the Corporations as well as facilitated, in whatever capacities, by the Corporations/their managers and personnel as by any Person named as defendant. Ud. 9-11) Plaintiff seeks $500 million in damages and an order restraining the defendants from ‘engaging in the described conduct. Ud. $41 49-51.) DISCUSSION A. Charlene ¥, Latham Even when read with the “special solicitude” due pro se pleadings, Triestman, 470 F.3d at 474-75, Plaintiff's claims rise to the level of the irrational, and there is no legal theory on which she can rely. See Denton, $04 U.S. at 33; Livingston, 141 F.3d at 437.Case 1:20-cv-07102-LLS Document3 Filed 09/24/20 Page 4 of 5 District courts generally grant a pro se plaintiff an opportunity to amend a complaint to cure its defects, but leave to amend is not required where it would be futile. See Hill Curcione, Salahuddin v. Cuomo, 861 F.2d 40, 42 (2d Cir, 1988), 687 F.3d 116, 123-24 (2d Cir. 2011 Because the defects in Plaintiff's complaint cannot be cured with an amendment, the Court declines to grant her f leave to amend and dismisses the action as frivolous. See 28 U.S.C. § 1915(e(20BMI). B. Plaintiff's claims on behalf of others “The statutory provision governing appearances in federal court, 28 U.S.C. § 1654, allows two types of representation: “that by an attomey admitted to the practice of law by a ‘governmental regulatory body, and that by a person representing himself.” Eagle Assocs. v: Bank of Montreal, 926 F.2d 1305, 1308 (2d Cir. 1991). Generally, a person who is not an attomey may not represent anyone other than him or herself in federal court, See U.S. ex rel, Mergent Servs. v Flaherty, $40 F3d 89, 92 (2d Cir, 2008) (“[A]n individual who is not licensed as an attorney may not appear on another person's behalf in the other's cause.” (internal quotation marks and citation omitted)): Jannaccone ¥. Law, 142 F.3d $53, $58 (2d Cir. 1998) ("[B]ecause pro se means 10 appear for one’s self, a person may not appear on another person’s behalf in the other's eause.”) Even if the complaint set forth meritorious claims, Plaintiff does not appear to be an attorney, and thus she cannot assert claims on behalf of others in this Court F To proceed with a civil action, a litigant must cither pay $400.00 in fees or, to request authorization to proceed without prepayment of fees, submit a signed IFP application. See 28 U.S.C. §§ 1914. Also, Rule 11(a) of the Federal Rules of Civil Procedure provides that “[e}very pleading, written motion, and other paper must be signed by at least one attorney of record in the itiomey's name - of by @ party personally if the party is unrepresented.” Fed, R. Civ. P. Hay: sce Local Civil Rule 11.1(a). The Supreme Court has interpreted Rule !I(a) to require “as it did in John Hancock's day, a name handwritten (or a mark handplaced).” Becker v. Montgomery, 532 U.S. 757, 764 (2001). Because Plaintiff's family members did not sign the complaint or submit IFP applications, itis not clear that they intended to participate in this lawsuit 4CONCLUSION ‘The Clerk of Court is directed to mail a copy of this order to Plaintiff Charlene Y. Latham and note service on the docket. The complaint is dismissed as frivolous under 28 U.S.C. § 19152 1BMD. SO ORDERED, Dated: September 18, 2020 New York. New YorkUNITED STATES DISTRICT COURT —* SOUTHERN DISTRICT OF NEW YORK CHARLENE Y. LATHAM; DAVID G. LATHAM: TRACEY Y. LATHAM; JOHN DOE (1-10); JANE DOE (1-5), Plaintiff, 20-CV-7102 (LLS) -against- CIVIL JUDGMENT THE 1953 TRUST, er al, Defendants. Pursuant to the order issued September 18, 2020, dismissing the complaint, IT IS ORDERED, ADJUDGED AND DECREED that the complaint is dismissed under 28 USC. § 1915(e)(2BM). The Court certifies under 28 U.S.C. § 1915(a)(3) that any appeal from the Court's judgment would not be taken in good faith TIS FURTHER ORDERED that the Clerk of Court mail a copy of this judgment to. Plaintif¥ and note service on the docket. SO ORDERED. Dated: September 18, 2020 New York, New York bonis L. Standen. Louis L. Stanton USD.Pro Se Office (Room 200) 500 Pearl St NY NY 10007 Date: 12/2/2020 RE: REQUEST FOR APPEALS PACKET- case 200V7102 As of 12/2/2020 Plaintiff was given notice that the 20¢v7102 case was closed and she (CHARLENE LA THAN} would need to request an appeals packet to obtain a copy of the Order dismissing the No information was given regarding the nature of the dismissal Plaintiff requested permission fo submit documents and receive email communication for this matter af the time of filing the case. No notice of the Pandemic measures allowing email submissions from pro se filers was provided or made known despite Plaintiff asking for such information or perinission [rom the court prior to e and the attached consent form Hus is Jorma request for Appeals packet including the Order dismissing the uniting consent to electronic service, Signed in the County of Dallas, in the State of Texas 12/2/2020 2:25pm Charlene272@hotmai 14469.751L 4900 Airport Parkway Addison TX 75001Case 1:20-cv-07102-LLS Document 5 Filed 12/02/20 Fage 2! « Vaited States Disteiet Coan Southera District of New York Pro Se Ofive CONSENT TO ELECTRONIC SERVICE 1 hata consents noes and docu en fiom that sectronicvarice ot tance eae rap and wll inc Spies os ase hangs including motion! decstonserders, and other dome spy not she Coure theres any change in my parsonal daca such ns cane {ldechs ove ton address orl vsh wo eaneel this onsen to electronic service 15 undersea eat} must regularly recen the dock set of my ease mute 9p and 6 tweerrtanl shat this consent applies cy othe cas tad below az thas ie ‘ddivonal caves in which | woud like wo recaive electronic teriee of nolctt ot ‘Teoumerss | yt fl content forms for those emer ‘ivi case(s) fled in the Southern District of ew Yorks ‘Note: Thus consent wi apply to all canes that you have ied 1m hus court ve paass allot Jur pending sed terminated cases, Far ack cues incluta the ceze name ard Hock amber Ver example Jo Dee Hess Cy, O-CV-01234) 4900 airport ok __.addison