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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
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`E. JEAN CARROLL,
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`
`
` -against-
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`
`
`Plaintiff,
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`
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`
`
`
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`Index No. _____________
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`COMPLAINT AND
`JURY DEMAND
`
`DONALD J. TRUMP, in his personal capacity,
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`Defendant.
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`
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`
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`Plaintiff E. Jean Carroll (“Plaintiff” or “Carroll”), by and through her attorneys at Kaplan
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`Hecker & Fink LLP, alleges as follows:
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`INTRODUCTION
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`1.
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`Nobody in this nation is above the law. Nobody is entitled to conceal acts of sexual
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`assault behind a wall of defamatory falsehoods and deflections. The rape of a woman is a violent
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`crime; compounding that crime with acts of malicious libel is abhorrent. Yet that is what Defendant
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`Donald J. Trump did to Plaintiff E. Jean Carroll.
`
`2.
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`Roughly 23 years ago, playful banter at the luxury department store Bergdorf
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`Goodman on Fifth Avenue in New York City took a dark turn when Trump seized Carroll, forced
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`her up against a dressing room wall, pinned her in place with his shoulder, and raped her.
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`3.
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`In the aftermath, Carroll confided in two close friends. One urged her to report the
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`crime to the police, but the other warned that Trump would ruin her life and livelihood if she
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`reported it.
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`4.
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`Carroll chose silence—and remained silent for over two decades.
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`5.
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`Carroll knew then that sexual assault was pervasive. She also knew that men have
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`been assaulting women and getting away with it since before she was born. And she knew that
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`while a woman who accused any man of rape was rarely believed, a woman who accused a rich,
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`famous, violent man of rape would probably lose everything. She therefore reasonably concluded
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`that if she accused Donald Trump of rape he would bury her in threats and lawsuits, and she would
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`probably lose her reputation, not to mention everything she had worked for and achieved.
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`6.
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`Near the end of the 2016 presidential election, Carroll watched in horror as
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`numerous women offered highly credible (and painfully familiar) accounts of Trump assaulting
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`them; Trump responded with insults and denials; the public fractured; and Trump not only won
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`the election, but grew more popular with some supporters as a result of the controversy.
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`7.
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`Carroll’s mother, a respected Republican official in Indiana, was dying during the
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`last six weeks of the presidential election. Carroll, wanting to make her mother’s last days as
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`pleasant as possible and avoid causing her any pain, decided to remain silent about what Trump
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`had done to her.
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`8.
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`But that all changed in late 2017, when the Harvey Weinstein scandal and its
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`aftermath signaled a profound shift in how American society responds to accusations of sexual
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`misconduct by powerful men. It suddenly seemed possible that even Trump could be held to
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`account.
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`9.
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`For Carroll, that project grew more urgent—and more personal—as the #MeToo
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`era prompted a flood of new letters to her advice column seeking her counsel about how to respond
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`to sexual assault and abuse. In her column, Carroll encourages her readers to be brave, to think
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`clearly, and to seek justice. When readers overcome with the doubt and anxiety have turned to her
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`seeking advice, Carroll has always advised taking action. But she never confessed her own
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`experiences. She never revealed that she, too, had been a victim of sexual assault. Over time, as
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`described below, the contradiction between Carroll’s words and her actions became increasingly
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`untenable.
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`10.
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`Carroll is a journalist. She watched as a throng of women came forward and accused
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`Trump of sexual assault, only to be denigrated and then brushed aside. When she felt she should
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`finally come forward herself, Carroll wanted to do it differently. She decided to describe Trump’s
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`rape in a book she had already begun to write about her experiences with various men. She did not
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`want to tell her story to the police, a newspaper, an elected official, or a fellow journalist, and be
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`treated as a “victim.” In other words, she wanted to tell her own story on her own terms.
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`11. When Carroll’s account was published, Trump lashed out with a series of false and
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`defamatory statements. He denied the rape. But there was more: he also denied ever having met
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`Carroll or even knowing who she was. Through express statements and deliberate implications, he
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`accused Carroll of lying about the rape in order to increase book sales, carry out a political agenda,
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`advance a conspiracy with the Democratic Party, and make money. He also deliberately implied
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`that she had falsely accused other men of rape. For good measure, he insulted her physical
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`appearance.
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`12.
`
`13.
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`Each of these statements was false. Each of them was defamatory.
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`Trump knew that these statements were false; at a bare minimum, he acted with
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`reckless disregard for their truth or falsity. Trump had recognized Carroll on sight at Bergdorf
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`Goodman. He knew who she was when he raped her, and he knew who she was in 2019. He
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`certainly knew that she was telling the truth. After he lied about attacking her, he surrounded that
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`central lie with a swarm of related lies in an effort to explain why she would invent an accusation
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`of rape. To do so, he smeared her integrity, honesty, and dignity—all in the national press.
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`14.
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`These lies were familiar to Trump. He had used them before, when other women
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`stated that he had grabbed, groped, or raped them.
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`15.
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`Trump’s defamatory statements injured Carroll. They inflicted emotional pain and
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`suffering, they damaged her reputation, and they caused substantial professional harm.
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`16.
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`Carroll filed this lawsuit to obtain redress for those injuries and to demonstrate that
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`even a man as powerful as Trump can be held accountable under the law.
`
`THE PARTIES
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`17.
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`Plaintiff E. Jean Carroll is a journalist, author, former writer for Saturday Night
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`Live, and advice columnist for Elle magazine. She is a resident of the State of New York.
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`18.
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`Defendant Donald J. Trump is currently the President of the United States, although
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`he is sued here only in his personal capacity. Since taking office, Trump has filed several lawsuits
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`in his personal capacity, including Trump v. Vance, Jr. et al., No. 19 Civ. 8694 (S.D.N.Y.), Trump
`
`et al. v. Deutsche Bank AG et al., No. 19 Civ. 3826 (S.D.N.Y.), Donald J. Trump for President,
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`Inc. et al. v. Padilla et al., No. 19 Civ. 1501 (E.D. Cal.), Trump v. Committee on Ways and Means
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`of the U.S. House of Representatives et al., No. 19 Civ. 2173 (D.D.C.), and Trump et al. v.
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`Committee on Oversight and Reform of the U.S. House of Representatives et al., No. 19 Civ. 1136
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`(D.D.C.). Trump is also defending a related case pending in this Court. See Zervos v. Trump, No.
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`150522/2017 (N.Y. Sup. Ct., N.Y. Cty.). Trump is a resident of the State of New York.
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`JURY DEMAND
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`19.
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`Plaintiff E. Jean Carroll hereby demands a trial by jury.
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`JURISDICTION & VENUE
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`20.
`
`21.
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`This Court has jurisdiction pursuant to NY CPLR § 301.
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`Venue is proper in this county pursuant to NY CPLR § 503 and § 509.
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`FACTUAL ALLEGATIONS
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`I.
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`TRUMP RAPES CARROLL AT BERGDORF GOODMAN
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`22.
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`One evening between the fall of 1995 and the spring of 1996, Carroll left work and
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`went to Bergdorf Goodman, the luxury department store on Fifth Avenue in New York City. She
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`was and remains a regular shopper at Bergdorf’s.
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`23.
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`That evening, Carroll did not find whatever she was looking for and prepared to
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`leave Bergdorf’s empty-handed. As she exited through Bergdorf’s revolving side door on 58th
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`Street, Trump arrived and entered through that very same door, which was cater-cornered across
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`from the Plaza Hotel.
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`24.
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`Trump instantly recognized Carroll on sight. They had met at least once before and
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`had long traveled in the same New York City media circles. In this period, Carroll was doing the
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`daily Ask E. Jean TV show, a small hit on the “America’s Talking” network started by Roger
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`Ailes. She was also on a frequent guest and commentator on the widely watched Today show.
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`25.
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`Trump put up his hand to stop her from exiting and said, “Hey, you’re that advice
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`lady!” Carroll, struck by his boyish good looks, responded by saying, “Hey, you’re that real estate
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`tycoon!”
`
`26.
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`Trump said that he was at Bergdorf’s to buy a present for “a girl” and asked Carroll
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`to come advise him. Carroll was surprised but thrilled that Trump would want her advice. She
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`stuck around, imagining the funny stories that she might later recount.
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`27.
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`Trump and Carroll began searching for a gift that Trump could give to the unnamed
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`girl. As they stood just inside the door, Carroll pointed to the handbags. Trump made a face; he
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`did not like that idea. Carroll instead suggested a hat. Trump walked over, going straight for a fur
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`hat, prompting Carroll to object that no woman would wear a dead animal on her head.
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`28.
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`As Trump cuddled the fur hat, Carroll asked how old “the girl” was. Trump did not
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`answer, instead asking Carroll how old she was. When Carroll replied that she was fifty-two years
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`old, he taunted her, “You’re so old!”
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`29.
`
`30.
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`Trump then had an idea: He would buy lingerie instead.
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`Trump and Carroll rode up the escalator to the lingerie department. When they
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`arrived, it was uncharacteristically empty, with no sales attendant in sight. Sitting on the counter
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`near them were two or three boxes and a see-through bodysuit in lilac gray.
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`31.
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`Snatching the bodysuit, Trump insisted that Carroll try it on. Bemused, Carroll
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`responded that he should try it on himself, adding that it was his color. Trump and Carroll went
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`back and forth, teasing each other about who should try on the bodysuit.
`
`32.
`
`33.
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`Suddenly, Trump grabbed Carroll’s arm and said, “Let’s put this on.”
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`Trump maneuvered Carroll to the dressing room. As they moved, Carroll laughed,
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`thinking to herself that she would make him put the bodysuit on over his pants.
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`34.
`
`35.
`
`36.
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`Strangely for Bergdorf’s, the dressing room door was open and unlocked.
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`Trump closed the door of the dressing room.
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`Immediately, Trump lunged at Carroll, pushing her against the wall, bumping her
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`head quite badly, and putting his mouth on her lips.
`
`37.
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`Carroll shoved him back. Utterly shocked by Trump’s unexpected attack, Carroll
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`burst out in awkward laughter. She could hardly process the insanity of the situation. She also
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`hoped, at least at first, that laughter would bruise his ego and cause him to retreat.
`
`38.
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`But Trump did not stop. He seized both of her arms and pushed her up against the
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`wall again, bumping her head a second time. While pinning Carroll against the wall with his
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`shoulder, Trump jammed his hand under her coatdress and pulled down her tights.
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`39.
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`Trump opened his overcoat and unzipped his pants. Trump then pushed his fingers
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`around Carroll’s genitals and forced his penis inside of her.
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`40.
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`Carroll resisted, struggling to break free. She tried to stomp his foot with her high
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`heels. She tried to push him away with her one free hand (as she kept holding her purse with the
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`other). Finally, she raised a knee up high enough to push him out and off her.
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`41.
`
`42.
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`Carroll ran out of the dressing room, out of Bergdorf’s, and onto Fifth Avenue.
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`The whole attack lasted two to three minutes.
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`II.
`
`CARROLL CONFIDES IN TWO FRIENDS ABOUT THE RAPE
`
`43.
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`As soon as she was outside Bergdorf’s, Carroll pulled her phone out of her purse
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`and called her friend Lisa Birnbach, the author, journalist, and correspondent on TV morning
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`shows.1 Carroll was breathless and still reeling from the assault. She kept laughing, manically—
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`her way of coping with the stress and trauma that she had just experienced.
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`44.
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`Carroll recounted to Birnbach how Trump had attacked her in Bergdorf’s dressing
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`room. She told Birnbach how Trump had pulled down her tights and put his penis inside of her.
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`45.
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`“He raped you,” Birnbach kept repeating. She begged Carroll to go to the police
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`and offered to accompany her. Still in shock and reluctant to think of herself as a rape victim,
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`Carroll did not want to speak to the police. She told Birnbach that it was just a few minutes of her
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`life and that it was over. She implored Birnbach never to tell anyone what had happened.
`
`46.
`
`47.
`
`Carroll drove home and crawled straight into bed.
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`Over the next few days, Carroll confided in a second friend, the New York City
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`journalist and news anchor Carol Martin. They sat together in the kitchen as Carroll described the
`
`
`1 Birnbach wrote a story about Trump’s Mar-a-Lago that was published in February 1996.
`See Lisa Birnbach, Mi Casa Es Su Casa, NEW YORK (Feb. 12, 1996). Birnbach has suggested that
`it was because of her work on that article that Carroll called her immediately after the assault.
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`rape. This time, Carroll did not laugh. Nobody laughed. The gravity of the assault had finally
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`started to sink in.
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`48. Martin solemnly advised Carroll to tell no one. Recognizing that Trump was a
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`powerful man, Martin feared that if her friend came forward, disaster would ensue. Martin warned
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`Carroll, in sum and substance: “Tell no one. Forget it! He has two hundred lawyers. He’ll bury
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`you.”
`
`49.
`
`50.
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`Carroll took Martin’s advice. She knew how brutal and dangerous Trump could be.
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`Carroll was also afraid of being dragged through the mud if she reported the rape.
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`She was convinced that nobody would believe her if she came forward. And like so many other
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`survivors of sexual assault, Carroll also blamed herself. She called herself “stupid.” She told
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`herself that she “deserved it” for agreeing to go lingerie shopping with Trump. She struggled with
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`the guilt that, somehow, though she had fought to protect herself from his attack, it was her fault
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`that Trump had raped her because she had entered that Bergdorf dressing room.
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`51.
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`Fundamentally, Carroll was raised to believe that strong women get by in the world
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`with a stiff upper lip—i.e., by putting hardship and suffering behind them. She believed that strong
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`women laugh at disasters because feeling sad only doubles the burden. To Carroll, laughter is how
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`women have dealt with calamity for thousands of years. So Carroll put her chin up and tried to
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`move on.
`
`52.
`
`53.
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`Carroll thus chose silence.
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`Carroll did not mention the rape again for over twenty years. She did not want to
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`be seen—or to see herself—as a victim of sexual assault.
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`54.
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`Carroll has not had sex with anyone since that day when Trump raped her.
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`III. CARROLL REMAINS SILENT FOR TWENTY YEARS
`
`55.
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`For the next twenty years, Carroll pursued her career as a writer and advice
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`columnist. Over time, she built a loyal audience and enjoyed the support of her publisher. Her Ask
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`E. Jean advice column in Elle magazine became the longest, still-active advice column in
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`American publishing. Its success resulted in large part from the many letters sent to her by readers.
`
`56.
`
`Carroll’s column in Elle was about life and love. Readers’ questions ranged from
`
`the lighthearted to the deeply personal. From time to time, readers would ask questions about
`
`whether behavior that they experienced at work, at church, and in their relationships was
`
`appropriate. When Carroll detected sexism or abuse, she did her level best to call it out and to help
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`women protect themselves.
`
`57.
`
`One reader, for example, despaired in 1994, “My boss is always rubbing up against
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`me . . . . He scares me because he’s very powerful and could ruin me.” Carroll responded: “Darling,
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`if the old snake has done so much to help your career, why are you still an assistant? Sex harassers
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`are filthy yellow sneaking cowards and must be won over, or crushed . . . . If all else fails, next
`
`time the old waterhead touches you, give him a knee in the groin. You’ve got nowhere to go but
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`up.”2
`
`58.
`
`Another reader had been raped when thirteen years old and sought advice from
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`Carroll because her rapist had just been hired as a co-worker. Carroll responded: “[T]he gentleness
`
`of your [letter] speaks strongly for your forgiving nature; however, it makes my duty very difficult.
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`Because now I must harden your soul. I must twist a little bit of steel—I’d try a big block of metal
`
`
`2 Reprinted in E. JEAN CARROLL, A DOG IN HEAT IS A HOT DOG AND OTHER RULES TO LIVE
`BY 28-29 (1996).
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`if I could—around your backbone, and persuade you to report your friend to the police.”3 Carroll
`
`added:
`
`“First, call your rape crisis center and speak with a counselor. Second, join a group
`of rape survivors—with their hardy support, you’ll start constructing a world for
`yourself and leave the world the rapist built for you. And, third, find another job at
`once. (Do not tell your employer about the rape. Do not inform the rapist of these
`steps. Stay cool. He’s dangerous.)”4
`
`59.
`
`In her advice columns, Carroll sought to offer witty, wise, and worldly guidance,
`
`and to address her readers in a clear, straightforward manner. She often urged readers to speak the
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`truth and to recognize patterns of rationalization and abuse. Readers’ perception of Carroll as
`
`honest, thoughtful, frank, and well-meaning were essential to Carroll’s professional success.
`
`60.
`
`But in responding to her readers, Carroll did not confess her own life experiences,
`
`including the sexual assault by Trump described above.
`
`61.
`
`During the last month of the election of 2016, Carroll watched a multitude of
`
`women reveal that Trump had engaged in sexual misconduct. She saw Trump brutally attacking
`
`his accusers on a national stage—denying their accusations, while also savaging their reputations
`
`and insulting their appearance.
`
`62.
`
`And as Carroll sat at the bedside of her dying mother in a Bloomington, Indiana
`
`hospital, watching numerous, credible women stun the nation with their stories of Trump’s sexual
`
`brutality, Carroll briefly considered whether she, too, should reveal that Trump had raped her. But
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`she feared—just as she had for decades—that Trump would lie his way out of it, while destroying
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`her life and reputation. He had done it before to plenty of women and, it seemed to Carroll, he
`
`would readily do it again. And, worst of all, coming forward with her story would also cause a
`
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`3 Id. at 141-42.
`4 Id. at 142.
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`media storm in Indiana and destroy her mother’s last happy days on the planet. Carroll feared that
`
`it would cost her and her family dearly without actually changing anything, especially since any
`
`accusation made during the presidential campaign would be characterized by Trump and his allies
`
`as a stunt to thwart his election.
`
`63.
`
`Indeed, Carroll worried that she might make Trump more popular in states like
`
`Indiana by revealing the rape, since his electoral fortunes had steadily improved despite credible
`
`allegations of sexual abuse. To Carroll, it appeared that some of Trump’s political supporters
`
`actually admired the fact that Trump was rich enough, macho enough, and powerful enough to be
`
`sued by—and to pay off—all these women he had groped and penetrated (especially porn stars
`
`and Playboy models).
`
`64.
`
`Carroll, in honor of her mother’s remarkable life, many years of which were spent
`
`as a local and loyal Republican elected official, and because she thought the publicity would help
`
`Trump win the election, warily persisted in her decades-old silence.
`
`65.
`
`Carroll’s mother died on October 11, 2016. In 2017, Carroll decided to write a book
`
`drawing on her observations as an advice columnist, but focusing specifically on her own life and
`
`trying to understand why so many Ask E. Jean letter-writers complained about men. On the
`
`morning of October 5, 2017, Carroll set out on a road trip, traveling to towns named after women.
`
`When she arrived in each town named after a woman (Angelica, New York, Tallulah, Louisiana,
`
`Marianna, Arkansas, and so forth), she spoke to women from all walks of life about their
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`relationships with men. She asked many of her subjects about the roles that men play in their lives.
`
`IV. CARROLL DECIDES TO SPEAK OUT
`
`66.
`
`On the very day Carroll began her road trip for her book, October 5, 2017, the New
`
`York Times revealed that Harvey Weinstein had sexually assaulted and harassed dozens of women
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`in the film industry.5 The news went off in Carroll’s mind like a bomb. She could not stop reading.
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`Painful memories of abuse at the hands of men, including Trump, swept over her.
`
`67.
`
`Days later, several women accused Weinstein of rape.6 It soon became clear to
`
`Carroll, and to the American people, that Weinstein’s abuses had been enabled for decades by a
`
`loose network of loyalists and lawyers, who had ensured that Weinstein evaded accountability for
`
`his exploitation of women—even though it was an open secret in Hollywood.
`
`68.
`
`As the Weinstein scandal persisted, Carroll saw society respond to the accusations
`
`with a seriousness and depth of self-reflection that she had never seen before; all too often, and as
`
`recently as the 2016 election, many Americans had brushed aside or marginalized accusations of
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`sexual misconduct by powerful men. Carroll also saw other women suddenly feel emboldened to
`
`come forward with their own reports of harassment, exploitation, abuse, violence, and rape.
`
`69.
`
`Carroll was moved by this experience. The walls that she had erected in her mind—
`
`the fear that Trump would emerge unscathed, the wariness of allowing him and his allies to come
`
`after her, the doubt that speaking up would actually matter, and the nagging anxiety that she was
`
`somehow to blame for being raped—began to crumble. Decades of deflection, diversion, and
`
`denial dissolved, resurfacing memories and feelings that she had hidden away.
`
`70.
`
`Carroll was struck by the fact that Weinstein, for all his wealth and power, could
`
`still be held accountable for his sexual misconduct. She saw how women had at last changed the
`
`public conversation by saying “Me Too” and by demanding accountability.
`
`
`5 Jodi Kantor & Megan Twohey, Harvey Weinstein Paid Off Sexual Harassment Accusers
`for Decades, N.Y. TIMES (Oct. 5, 2017).
`6 Ronan Farrow, From Aggressive Overtures to Sexual Assault: Harvey Weinstein’s
`Accusers Tell Their Stories, NEW YORKER (Oct. 10, 2017).
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`71.
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`These observations lead Carroll to reflect again on her column in Elle magazine,
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`and to ask whether she was a hypocrite. For decades, she had paired her trademarked wit with
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`steely resolve in confronting the everyday unfairness—and, all too often, the abuse—that her
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`(largely female) readers confessed. Carroll’s written persona was brave. But she still had not
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`confessed her own experiences of abuse, her fear of coming forward, or her creeping self-doubt.
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`72.
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`These internal reflections loomed larger in her mind—and became inescapable—
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`as more readers of Carroll’s advice column began asking, “Should I come forward with my account
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`of surviving sexual abuse or harassment?”
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`73.
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`Carroll finally decided that she owed her readers the truth. She also owed them (and
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`many other women) solidarity in their efforts to bring justice and accountability to powerful men
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`who had engaged in sexual assault and gotten away with it. She knew that it would be painful to
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`speak up. But she also knew that it was the right thing to do so.
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`74. While Carroll was on the road trip across the country talking to women as research
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`for her book, she started a list of the 21 most hideous men she had ever encountered—men who
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`had, each in his own way, left indelible and ugly marks on her story. This list grew into a book,
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`What Do We Need Men For?: A Modest Proposal. In that book, Carroll interspersed the stories of
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`women she had met while traveling the country with the men on her “Most Hideous List.”
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`75.
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`Two men on the Most Hideous List haunted Carroll the most. The first was Cam
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`Parks, the Waterfront Director at her Girl Scout camp, a man who sexually abused her every day
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`during a two-week period when she was twelve. The second was Donald Trump, the man who
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`raped her when she was 52. Carroll described that attack in detail.
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`76.
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`Carroll knew a book was the right place for her to come forward about Trump’s
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`assault. Writing is Carroll’s lifeblood; she writes to process the world around her and to reveal her
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`inner self. It’s her normal way of living: she writes about what happens to her, often in a
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`confessional, idiosyncratic manner. She also believed that a book would allow her to control her
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`narrative and speak directly to her readers. This was important. Carroll did not want to be, or to
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`act like, a victim. She wanted to tell her story on her terms, rather than as filtered through
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`journalists or social media. Her language was specific.
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`77.
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`In her book, Carroll truthfully described, in meticulous detail, the rape in Bergdorf
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`Goodman:
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`“The next moment, still wearing correct business attire, shirt, tie, suit jacket,
`overcoat, he opens the overcoat, unzips his pants, and, forcing his fingers around
`my private area, then thrusts his penis halfway—or completely—I’m not certain—
`inside me.”7
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`78.
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`She also explained why she had not come forward earlier:
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`“Receiving death threats, being driven from my home, being dismissed, being
`dragged through the mud, and joining the sixteen women who’ve come forward
`with credible stories about how the man grabbed, badgered, belittled, mauled,
`molested, and assaulted them, only to see the man turn it around, deny, threaten,
`and attack them, never sounded like much fun. Also, I’m a coward.”8
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`79.
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`At noon on June 21, 2019, New York magazine published Carroll’s account of the
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`rape on NYMag.com as an excerpt of her forthcoming book. The excerpt first appeared on The
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`Cut, a vertical on NYMag.com. The excerpt appeared on newsstands three days later in the June
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`24-July 7 print edition.
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`80.
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`Carroll’s book was released by St. Martin’s Press on July 2, 2019.
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`7 E. JEAN CARROLL, WHAT DO WE NEED MEN FOR?: A MODEST PROPOSAL 248 (2019).
`8 Id. at 244.
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`V.
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`TRUMP REPEATEDLY DENIES RAPING CARROLL AND MAKES A SLEW OF
`FALSE, INSULTING STATEMENTS ABOUT HER
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`81.
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`In three statements—published on June 21, 22, and 24 respectively—Trump
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`responded to Carroll by publicly, falsely, and maliciously smearing her reputation.
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`82.
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`On June 21, 2019, Trump issued the following public statement:
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`“Regarding the ‘story’ by E. Jean Carroll, claiming she once encountered me at
`Bergdorf Goodman 23 years ago. I’ve never met this person in my life. She is trying
`to sell a new book—that should indicate her motivation. It should be sold in the
`fiction section.
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`Shame on those who make up false stories of assault to try to get publicity for
`themselves, or sell a book, or carry out a political agenda—like Julie Swetnick who
`falsely accused Justice Brett Kavanaugh. It’s just as bad for people to believe it,
`particularly when there is zero evidence. Worse still for a dying publication to try
`to prop itself up by peddling fake news—it’s an epidemic.
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`Ms. Carroll & New York Magazine: No pictures? No surveillance? No video? No
`reports? No sales attendants around?? I would like to thank Bergdorf Goodman for
`confirming that they have no video footage of any such incident, because it never
`happened.
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`False accusations diminish the severity of real assault. All should condemn false
`accusations and any actual assault in the strongest possible terms.
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`If anyone has information that the Democratic Party is working with Ms. Carroll or
`New York Magazine, please notify us as soon as possible. The world should know
`what’s really going on. It is a disgrace and people should pay dearly for such false
`accusations.”
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`83.
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`Upon information and belief, Trump’s June 21 statement was first given to the
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`press, including Laura Litvan of Bloomberg News, who posted it on Twitter at 2:17 p.m.9
`
`
`9 See Laura Litvan
`(@LauraLitvan), Twitter
`https://twitter.com/LauraLitvan/status/1142179819075121154.
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`
`(June 21, 2019 2:17 PM),
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`84.
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`Trump’s June 21 statement was subsequently shared online by other journalists and
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`covered by many leading news sources as Trump’s statement in response to Carroll.10
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`85.
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`86.
`
`87.
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`In the June 21 statement, Trump falsely stated that he did not rape Carroll.
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`In the June 21 statement, Trump falsely stated that he had never met Carroll.
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`In the June 21 statement, Trump falsely implied and affirmatively intended to imply
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`that he had no idea who Carroll was.
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`
`10 See, e.g., AFP News Agency, US Writer Says Trump Sexually Assaulted Her in Mid-
`1990s, AL JAZEERA, (June 21, 2019); Alexandra Alter, E. Jean Carroll Accuses Trump of Sexual
`Assault in Her Memoir, N.Y. TIMES (June 21, 2019); Jenna Amatulli, Trump on E. Jean Carroll
`Rape Allegation: “I’ve Never Met This Person in My Life”, HUFFINGTON POST (June 21, 2019);
`Amber Athey, Trump Responds to Rape Accuser: “People Should Pay Dearly for Such False
`Accusations”, DAILY CALLER (June 21, 2019); Brian Bennet, Trump Says He “Never Met” Author
`Who Has Accused Him of Sexual Assault, TIME (June 21, 2019); Ellie Bufkin, Trump Issues
`Blistering Denial of E. Jean Carroll's Rape Allegation, WASH. EXAMINER (June 21, 2019); Adam
`Carlson, Noted Advice Columnist Says Trump Raped Her in Manhattan Department Store in the
`’90s—“Never Happened,” Trump Responds, PEOPLE MAG. (June 21, 2019); Matthew Choi, Trump
`Dismisses New Sexual Assault Allegation, POLITICO (June 21, 2019); Casey Darnell, Writer Says
`She Was Raped by Trump in 1990s, YAHOO! NEWS (June 21, 2019); EJ Dickson, E. Jean Carroll
`Alleges President Donald Trump Assaulted Her, ROLLING STONE (June 21, 2019); Vivian Ho &
`Lauren Gambino, Evening Summary: Trump Responds to E Jean Carroll’s Allegations, GUARDIAN
`(June 21, 2019); Colby Itkowitz, Magazine Columnist Accuses Trump of Sexual Assault More than
`Two De