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touched Plaintiff in an offensive and sexual manner without her consent. 81. Epstein and Maxwell's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to forcible touching as defined in Article 130.52, inasmuch as Epstein and Maxwell intentionally and for
filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 38. Epstein's will was entered into probate on September 6, 2019, and
touched Plaintiff in an offensive and sexual manner without her consent. 81. Epstein and Maxwell's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to forcible touching as defined in Article 130.52, inasmuch as Epstein and Maxwell intentionally and for
filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 38. Epstein's will was entered into probate on September 6, 2019, and
touched Plaintiff in an offensive and sexual manner without her consent. 81. Epstein and Maxwell's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to forcible touching as defined in Article 130.52, inasmuch as Epstein and Maxwell intentionally and for
filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 38. Epstein's will was entered into probate on September 6, 2019, and
Entities connected to both New York Penal and the Matter of the Estate of

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
New York
LOCATION
U.S. Virgin Islands
LOCATION
Jes Staley
PERSON
Southern District of New York
ORGANIZATION
Kenneth Marra
PERSON
United Kingdom
LOCATIONDarren Indyke
PERSON
Richard Kahn
PERSON
Martha Stewart
PERSON
New Mexico
LOCATIONSuperior Court
ORGANIZATION
Amber Sutherland
PERSON
Metropolitan Correctional Center
ORGANIZATIONN.Y. Post
ORGANIZATIONJames B. Stewart
PERSONthe Probate Division
ORGANIZATIONRichard Berman
PERSONMartel Colon Miro
PERSON