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OF NEW YORK JANE DOE 1000, Plaintiff, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, Defendants. COMPLAINT BOIES SCHILLER FLEXNER LLP 1 EFTA00023292 --- PAGE BREAK --- Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page
Page: EFTA00023292 →eir capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, Defendants. COMPLAINT BOIES SCHILLER
Page: EFTA00023292 →r Complaint against Defendants, Darren K. Indyke and Richard D. Kahn in their capacities as the executors of the Estate of Jeffrey Edward Epstein ("Epstein"), avers upon personal knowledge as to her own acts and status and upon information and belief and to all other matters as follows: NATURE OF THE A
Page: EFTA00023293 →was repeated numerous times with numerous young women. 4. As United States District Judge Kenneth Marra found, "From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls . . . at his mansion in Palm Beach Florida, and elsewhere in the United States and overseas. . . . In addit
Page: EFTA00023293 →eir capacities as the executors of the Estate of Jeffrey Edward Epstein ("Epstein"), avers upon personal k
Page: EFTA00023293 →pacity as an appointed executor of the Estate of Jeffrey E. Epstein. 18. Defendant Richard D. Kahn is sued
Page: EFTA00023296 →leaves out the fact that this is why we have laws in the United States to protect minor children who are groomed and sexually trafficked by adults.’ Epstein served 13 months in a Florida prison after pleading guilty in 2008 to soliciting a minor for prostitution. Allegations: The 31-year-old is currently
Page: HOUSE_OVERSIGHT_015529 →tember 21, 2015. /s/ David Boies David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice Pending) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 /s/ Ellen Brockman Ellen Brockman Boies
Page: HOUSE_OVERSIGHT_015542 →us about the circumstances of your first meeting Mr. Epstein. V: Ok. I was introduced to Mr. Epstein by Ghisl
Page: HOUSE_OVERSIGHT_015557 →aine Maxwell and Jeffrey Epstein when was under the age of eighteen. 9. Between 1999 and 2002, with the assistance and participation of Maxwell, Epstein sexually abused at numerous locations including his mansions in West Palm Beach, Florida, and in this District. Between 2001 and 2007, with the ass
Page: EFTA00015728 →e after being recruited by Ghislaine Maxwell and Jeffrey Epstein when was under the age of eighteen. 9.
Page: EFTA00015728 →tein's victims. As a consequence, the victims were not told about the NPA. 16. On July 7, 2008, a young woman identified as Jane Doe No. 1, one of Jeffrey Epstein's victims (other than 1, filed a petition to enforce her rights under the Crime Victims' Rights Act ("CVRA"), 18 U.S.C. ¶ 3771, alleging that the G
Page: EFTA00015729 →within this pleading. Dated September 21, 2015. /s/ David Boies David Boies Boies Schiller & Flexner LLP /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice Pending) Boies chiller & Flexner LLP /s/ Ellen Brockman Ellen Brockman Boies chiller Flexner LLP 12 EFTA00015737
Page: EFTA00015737 →Entities connected to both Jeffrey Epstein and Pro Hac Vice Pending

Ghislaine Maxwell
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
U.S. Virgin Islands
LOCATION
John Brockman
PERSON
Les Wexner
PERSON
David Boies
PERSON
Colorado
LOCATION
West Palm Beach
LOCATIONSigrid McCawley
PERSON
Lauderdale
LOCATION
New York Daily News
ORGANIZATIONDistrict Court for the Southern District of New York
ORGANIZATIONU.S. Attorney's Office
ORGANIZATIONSouthern District of Florida
LOCATION
Ross Gow
PERSONArmonk
LOCATIONSidney
LOCATIONEllen Brockman
PERSON