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Epstein was found dead in his jail cell at the Metropolitan Correctional Center, where he was being held pending trial. Upon information and belief, New York City's medical examiner concluded Epstein died by suicide. 64. On August 15, 2019, Epstein's last will and testament (the "Will") was filed in the Probat
onduct perpetrated against Plaintiff when she was under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55. COUNT TWO Sexual Battery 74. Plaintiff incorporates by reference all preceding parag
he penny dropped: Mary suddenly felt like Epstein's prostitute, as one of many girls he treated as sexual objects. 12. She nearly immediately left New York City, returned to her parents' home across the country and never saw Epstein again. 13. Epstein's abuse devastated Mary. She isolated herself and had t
F Document 1 Filed 11/20/19 Page 17 of 19 injury suffered as a result of conduct that would constitute sexual offenses as defined in Article 130 of the New York Penal Law, and such acts and/or omissions were committed against Mary when she was less than eighteen years of age. FIRST CAUSE OF ACTION (Battery) 108. P
Epstein was found dead in his jail cell at the Metropolitan Correctional Center, where he was being held pending trial. Upon information and belief, New York City's medical examiner concluded Epstein died by suicide. 28. On August 15, 2019, Epstein's last will and testament (the "Will") was filed in the Probat
onduct perpetrated against Plaintiff when she was under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55. SECOND CAUSE OF ACTION (Sexual Battery) 38. Plaintiff incorporates by reference all
pstein sexually abused many minor girls, includin in his Manhattan townhouse. 26. On many occasions, Epstein and his agents made phone calls from New York to schedule appointments for minor girls to come to Epstein's residences outside of New York in order to perform commercial sexual acts for Epstein.
would constitute sexual 10 EFTA00084153 Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 11 of 13 offenses as defined in Article 130 of the New York Penal Law, and such acts and/or omissions were committed against when she was less than eighteen years of age. 70. Epstein's conduct constitutes "childhood
Entities connected to both New York and the New York Penal Law

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONDarren Indyke
PERSON
U.S. Virgin Islands
LOCATION
New York State
LOCATIONJane Doe
PERSON
Richard Kahn
PERSONthe State of New York
LOCATIONU.S. Virgin
LOCATION
Gloria Allred
PERSONthe Superior Court of the Virgin Islands
ORGANIZATIONthe Superior Court
ORGANIZATIONCarolyn P. Hermon-Percell
PERSONMAROKO & GOLDBERG
ORGANIZATIONN.Y. P.L.
ORGANIZATIONWANG LLP
PERSONDaniel Mullkoff
PERSONCUTI HECKER
ORGANIZATIONCuti Hecker Wang LLP
ORGANIZATION