In the 15th Judicial Circuit Court

In and For Palm Beach County, Florida

Case No. 50 2016 CA 0 12 4 8 5 XXXX MB AB

TODD ANTHONY MEUIR

(Plaintiff)

V.

JEFFREY EPSTEIN AND

"DOES" I thru X
(Defendants)

Complaint​:

Comes now the plaintiff and his cause for action against the defendant(s) states the following:

1) The plaintiff is at present a resident within the state of Florida and was within the
jurisdiction of Florida and within the United States and territories under the control of the
United States at all times relevant within this complaint.

2) That cause of action herein occurred under the laws of the state of Florida, and at least
one of the defendants(s) reside(s) in, or may be found in Palm Beach County and within
venue of this court

3) That the true names of, and capacities of defendant(s) named herein as "DOES I
through X" are either unknown to plaintiff or must be, for now obfuscated until notification
of United States attorney of case in total(sic). Therefore, plaintiff sues DOES I thru X by
such fictitious names as used herein until plaintiff learns of such names and will ask
leave to amend this complaint to show their true names and capacities, or will ask leave
to amend this complaint when said US attorney's office has first received illumin of all
such. Plaintiff asserts that each defendant named as a DOE is as well responsible in
some manner for the events herein referred to, and have caused equally cataclysmic
emotional, mental, life, and being in total / damages proximately thereby to plaintiff as
alleged herein.

Complaint for Recompensation for the Ruined Life of the Plaintiff Under the Forces of the
Defendant(s)​:

The plaintiff asserts that upon either the direct forces of coercion, threat, duress by the
defendant(s) or the indirect forces of such ordered upon the plaintiff's life, by and through the
defendant(s), that the plaintiff has suffered intoto loss, deterioration, and theft of his life since
still within his teenage years.
This egregious malleability of this plaintiff's life has spanned from the state of Arkansas where
he was born and raised, to throughout the United States and territories both within the
jurisdiction of the United States and outside of such.

Since still within years of his teenagedom onto his late adulthood, the plaintiff has been utilized
by the defendant(s) and others so as to facilitate forth favorable malleabilities from a collection
of the state's and nation's most powerful / influential persons within political, judicial, financial,
etc. capacities via secretly recorded audio/visuals that capture this plaintiff and said collective of
powerful/influential persons while engaged in sexual activities.

These said audio/visuals would then be utilized by the defendant(s) so as to

coerce/threaten/blackmail/bribe the said collective of persons to act against their wills and
against the laws and rules of the United States so as to benefit the unlawful interests of the
defendant(s).

These said unlawful interests include but are not limited to local, state, and national political
decisions, local state and national judicial system decisions, and local state and national
financial decisions.

This plaintiff has been repeatedly utilized throughout his life at the forces of
coercion/threat/duress upon his life by and through the defendant(s) for the purposes of
facilitating cataclysm upon the lives and careers of many innocent people of whom too were
possessed of no choice but to bend the wills/wants of the defendant(s).

The lifetime of utterly sad corruptness(sic) that has been forced upon the life of this plaintiff by
the defendant(s) has indelibly imprinted upon the heart, soul, mind and body of this plaintiff a
level of self-loathe and self-shame that the resultant has been nothing less than the intoto
destruction of any/all life, dreams, goals, ability of the plaintiff to have been so much greater to
life, to society, to his family and to himself.

The Systemic Deterioration/Ruin of Plaintiff's Life At The Force and Will of Defendant(s)​:

The plaintiff attests to fact that his indoctrination into this cabal of corruption that began while he
was a teenager in Arkansas, and to where he became the fruit of the poison tree~ for the many
uses by a particular then Most Governmental-High, and spouse, and company. This plaintiff can
attest to fact of facilitating said particular persons in avoiding a collective of easily otherwise
indictable pitfalls via herein described malleables: LMA, Madison, Cap. Management, "White
Water" Development, etc…
This plaintiff can attest to and asserts fact of said malleables he was sent to facilitate by and
through the orders of above said particular persons:/ Corruption of judicial figures, jurors,
witnesses, investigators, etc… including those from the/within the (OIC) Office of Independent
Counsel.

This plaintiff attest to fact of being creatively introduced into the Arkansas Department of
Corrections with sole intent by said particular persons and company to place this plaintiff in
close proximity to a one:/ Wayne Dumond, of whom was then incarcerated for the rape of a
Forrest City teenage girl in 1984. It was their intent and plan, including that of the then director
of the A.D.C., for this plaintiff to introduce a lethal contaminate into said: Dumond's food or
drink. Reason being: that Dumond, was loudly vociferous to anyone whom would listen that said
the particular Most Governmental-High and spouse were responsible for his (Dumond) being
literally castrated by intruders into his home while he was free on bail for this rape.

This plaintiff attests to as well fact as this same plan of action (introduction of lethal contaminate
into food or drink) was intended for a one: Yankee Hall and his co-defendant: McClendon, of
whom both were convicted for the murder of Alice MacArthur, the wife of prominent L.R.
attorney: Bill (William) MacArthur.

This plaintiff attest to fact that this plaintiff is not, nor has ever been, in any semblance, a violent
person and plaintiff loathes violence, violent/predacious people and therefore could not/would
not follow through with the orders/intents, much to the dismay of said then particular Most
Governmental-High and spouse and company. Additionally, this plaintiff can attest to fact as
being as well planned for the creative introduction into a Federal Carceral Facility for the sole
purpose of having unobstructed violence over this plaintiffs friend: James McDougal, so as to
discern of any possibility that James was breaking under the pressure from those within the
U.S. Attorney's Office/OIC/etc~ and would have given forth reveal of much meant to remain in
obscuro~

This plaintiff attests to fact of his being present within a suite @ The Excelsior Hotel in L.R. with
the then owner: Doyle Rogers, Danny Furguson, and the then said particular Most
Governmental-High as they were in view of herein described audio/visuals and were in
discussion as to best usages.

This plaintiff possessed a dear friendship with a one: Vince Foster, of whom too lost his life as a
resultant of corruptions that were intended to lie forevermore in obscuro- that Vince wanted to
pour Light upon. This plaintiff as well beloved friend: Calvin Walraven, of whom was utilized as
this plaintiff was met his wrongful/unlawful demise too so as to cover up so many crimes that
they felt he would give reveal of~

This plaintiff attests to fact of being repeatedly produced in D.C., Miami, etc., etc. to facilitate
planned malleables by the defendant(s) upon those including that of a Supreme Court Justice of
whom they had discerned of hidden proclivities and had set a stage within a park at night so as
to record such resultant which would later be utilized as a coercive against the jurist for
purposes of forcing forth the rendering of decisions favorable to them~

This plaintiff can attest to fact of him being many times an attendee at "Circuit Parties," that are
both incredibly vetted and secret as to "when's and where's." These modern day Bacchanalia's
would include a who's-who of those whom are powerful/influential within political, judicial,
financial, etc. Capacities and all of whom would engage in a buffet of most-illegal substances,
most-illegal lasciviousness, and most-illegal corruptive blueprinting. Those in attendance include
the defendant(s). This petitioner can attest as well to incredible lawlessness by and through a
defendant while within Florida and within/about his island residence~

This plaintiff asserts that this is but a mere paragraph of book and volume of what he has
endured and been forced to daily/nightly, bear the soul, mind, and heartbreaking shame of, and
all of which is given utter raze of this plaintiff's life because great griefs are mute and they
destroy from inside-out.

Whereof, Plaintiff Prays For Judgement Against Defendant(s), Jeffrey Epstein, DOES I
through X​:

1) Judgement in the sum of: $2,000,000.00, together with interest at the rate of 10.25
percent per annum from the date of judgement until paid.

2) That the other $1,000,000.00 of judgement be donated to the Cystic Fibrosis

Foundation,

3) That the other $1,000,000.00 of judgement be donated to a strictly No Kill animal

shelter/foundation of plaintiff's choosing,

4) For costs of suit incurred;

5) For costs of private/emotional mental therapies due to the devastating mental pain,
anguish, suffering and all other deterioration of his life that plaintiff has sustained under
such egregious circumstances of coerced, forced, duressed use of his life by
defendants, so that the plaintiff can possibly arrive at some semblance of peace, solace
and healing in his life. For such other and further relief as the Honorable Court may
deem just and proper. Plaintiff further demands jury trial.

Dated this 18th day of October 17, 2016

Respectfully submitted,
(Signed) Todd Anthony Meuir
Plaintiff in Probe
Filed: Palm Beach County, FL, Sharon R. Bock, Clerk. 11/8/2016 3:39:51 PM