What is the full text of the 2016 'Katie Johnson'/'Jane Doe' complaints and affidavits filed against Donald Trump and Jeffrey Epstein?
Executive summary
The full text of the April 2016 federal complaint filed under the name "Katie Johnson" and subsequent New York complaints filed under the pseudonym "Jane Doe" are part of the public record: the April 2016 complaint (Katie Johnson) and attachments are archived on public court-docket mirrors and an Archive.org text reproduction (which includes the complaint language, damages demand and specific allegations) [1] [2]. Later New York filings that used the Jane Doe pseudonym — and that included supporting affidavits from an alleged witness called "Tiffany Doe" and others — were uploaded to document-hosting sites and reported on by multiple news outlets, though several of those suits were withdrawn or dismissed in 2016 [3] [4] [5].
1. Where the "full text" exists and what it contains
The complaint labeled Katie Johnson (filed April 26, 2016 in federal court) is available in full via archived docket reproductions; that document expressly seeks $100,000,000 and lays out allegations that the plaintiff was sexually assaulted by Jeffrey Epstein and Donald Trump as a 13‑year‑old at Epstein’s New York residence, with narrative detail about specific incidents such as being forced to disrobe and give massages while Epstein and, allegedly, Trump were present [1] [2]. Public docket entries and mirrors preserve that complaint text and the case metadata showing assignment to Judge Dolly M. Gee [2].
2. The later "Jane Doe" versions and the affidavits
Subsequent filings in New York used the Jane Doe pseudonym and reportedly included affidavits attesting to the plaintiff’s allegations — notably a witness affidavit attributed to someone called "Tiffany Doe," who, according to reporting, claimed to have procured girls for Epstein and corroborated parts of the complaint; those affidavits and the New York complaint text have been circulated on document-hosting platforms and summarized in news accounts [3] [5] [6]. News organizations and court reports note that the New York complaints were filed and then withdrawn or dismissed within months, and that a planned press conference by the plaintiff in November 2016 was canceled amid reported threats [4] [5].
3. Legal status and why copies mattered to the record
Courts recorded the filings and docket activity (including an in forma pauperis filing and a dismissal in the California case), which means the complaint text and docket entries remain part of the public case history even though the claims were not litigated to verdict — the April federal complaint was dismissed in May 2016 and later filings were withdrawn, according to contemporaneous court notices and news reports [2] [4] [6]. Several news outlets and archival repositories preserved the complaint and related documents precisely because the filings were short-lived but politically sensitive [1] [2].
4. Disputes about authenticity, identity and provenance
Beyond the documents themselves, reporting has flagged unresolved questions: some journalists and later investigations probed whether "Katie Johnson" was a real, identifiable person or a pseudonymous plaintiff coordinated by outside operatives, and whether parts of the narrative were promoted or monetized by intermediaries — lines of inquiry documented by the San Francisco Chronicle and other outlets that examined emails and public records tied to the matter [7] [8]. Coverage also stresses that while the complaint text contains grave allegations, the filings were never tested through a full trial and were withdrawn or dismissed, and subsequent unsealing of Epstein-related materials has neither validated nor fully explained every claim in those 2016 filings [5] [6].
5. How to obtain the "full text" and what is missing from public sources
For researchers seeking the verbatim filings: the Archive.org reproduction preserves the signed April 2016 Katie Johnson complaint including the demands and factual paragraphs [1], court‑docket mirrors like CourtListener list the case and attachments [2], and other uploaded PDFs and document sites host the New York Jane Doe complaints and accompanying affidavits [3] [9]. What cannot be asserted from the provided reporting here is any forensic conclusion about the authorship or real‑world identity of the plaintiffs and witnesses beyond what those documents and reporters stated; several reputable outlets emphasize the filings’ existence while also noting their withdrawal or dismissal and the resulting gaps in public record [4] [7].