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UTHERN DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY E. EPSTEIN, Defendants. Case No. JURY TRIAL DEMANDED COMPLAINT EFTA00103496 Case 1:19-cv-08673 Document 1 Filed 09/18/19 Page 2 of 16 Plaintiff Jane Doe
18, 2019). Because Doe was a child at the time of her abuse, which took place more than 15 years ago, Doe is largely without documentary evidence of Epstein's crimes against her. However, we believe that in the course of your Office's criminal investigation and prosecution of Epstein's sex trafficking c
eir capacities as the executors of the ESTATE OF JEFFREY E. EPSTEIN, Defendants. Case No. JURY TRIAL DEMA
her claims in this action. FACTUAL ALLEGATIONS Defendant Epstein's Scheme of Exploitation and Abuse 15. Defendan
e in o interview her about her experiences with Mr. Epstein. We understand that, at t at time, counsel retain
eir capacities as the executors of the ESTATE OF JEFFREY E. EPSTEIN, Defendants. Case No. JURY TRIAL DEMAN
he Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 68. On September 6, 2019, Magistrate Judge Carolyn P. Hermon-Percell of the Superior Court of the Virgin Islands ordered that Epstein's will be admitted to probate and authorized Mr. Indyke and Mr. Kahn to administer
Hermon-Percell Superior Court of the U.S. Virgin Islands Magistrate Division Barbell Plaza South St. Thomas, U.S. Virgin Islands Re: Estate of Jeffrey E. Epstein Probate No. ST-19-PB-80 Dear Magistrate Percell: We write on behalf of Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jef
that the Court act in order to protect the Estate, its creditors and claimants, including scores of women currently seeking compensation through the Epstein Victims' Compensation Program. Respectfully submitted, Christopher Allen ICroblin Counsel for the Co-Executors cc: Counsel of record EFTA00105
St. Thomas, U.S. Virgin Islands Re: Estate of Jeffrey E. Epstein Probate No. ST-19-PB-80 Dear Magistrat
St. Thomas, U.S. Virgin Islands Re: Estate of Jeffrey E. Epstein Probate No. ST-19-PB-80 Dear Magistrate
g, 9053 Estate Thomas, Suite 101, St. Thomas, V.I. 00802 Telephone I 1.888.316.9269 Fax I www.kellfer.com September 9, 2020 By E-Filing Honorable Carolyn P. Hermon-Percell Superior Court of the U.S. Virgin Islands Magistrate Division Barbell Plaza South St. Thomas, U.S. Virgin Islands Re: Estate of Jeffrey E. Epst
SOUTHERN DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defendants. Case No. COMPLAINT FOR DAMAGES DEMAND FOR JURY TRIAL Plaintiff Jane Doe ("Doe" or "Plaintiff") a
N I. This case arises out of years of sexual abuse and exploitation of a girl by notorious pedophile and convicted sex offender Jeffrey Epstein ("Epstein"). It all started in when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a summer camp in Michigan. Jane Doe was t
n their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Def
n their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defe
irgin Islands, confirming that he and Defendant Richard D. Kahn arc the two Trustees of The 1953 Trust. 32. On September 6, 2019, Magistrate Judge Carolyn P. Hermon-Percell of the Superior Court of the Virgin Islands ordered that Epstein's will be admitted to probate and authorized Mr. Indyke and Mr. Kahn to administer
phone-, requested to file a complaint. After being made aware of the identity of the interviewing agent, GEORGE provided the following statement: EPSTEIN WAIVER GEORGE became the United State Virgin Islands Attorney General (AG) in 2019. Within the first two weeks of GEORGE becoming Attorney General,
the first two weeks of GEORGE becoming Attorney General, Albert Bryan (BRYAN), the newly elected Governor of the Virgin Islands, informed her that Jeffrey Epstein (EPSTEIN) wanted a waiver for a 21 day reporting requirement. Erika Kellerhals (KELLERHALS), legal representative for EPSTEIN, submitted a request
overnor of the Virgin Islands, informed her that Jeffrey Epstein (EPSTEIN) wanted a waiver for a 21 day re
CICO against the EPSTEIN estate. Approximately a few days after EPSTEIN died KELLERHALS filed a probate petition in Superior Court USVI with Judge Carolyn P. Hermon-Percell (PERCELL). Agent Note: [PERCELL was appointed by BRYAN on March 23, 2022 to a five year term as the Commissioner to Casino Control.] During the in
THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN **** ************* *************** 0 IN THE MATTER OF THE ESTATE OF JEFFREY E. EPSTEIN, ) ) PROBATE NO. ST-19-PB-80 o e-• ) 4-- 7-..73 Deceased. ) ACTION FOR TESTATE ) ADMINISTRATION rs, EXPEDITED MOTION FOR ESTABLISHMENT
Page: EFTA00018905 →rogram would provide all eligible claimants an opportunity to receive compensation and voluntarily resolve their claims of sexual abuse against Mr. Epstein through a confidential, non-adversarial alternative to litigation. To be designed and implemented by independent, nationally recognized claims admin
Page: EFTA00018905 →************* 0 IN THE MATTER OF THE ESTATE OF JEFFREY E. EPSTEIN, ) ) PROBATE NO. ST-19-PB-80 o e-•
Page: EFTA00018905 →ily resolve their claims of sexual abuse against Mr. Epstein through a confidential, non-adversarial alternati
Page: EFTA00018905 →OGRAM COME NOW the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and
Page: EFTA00018905 →FTA00018907 --- PAGE BREAK --- Estate of JeJj5-ey Epstein Probate No. ST- I9-PB-80 Motion for Establishme
Page: EFTA00018908 →opy of this Order shall be directed to counsel of record. Dated: ATTEST: ESTRELLA H. GEORGE Clerk of the Court BY: Court Clerk Supervisor / / CAROLYN P. HERMON-PERCELL Magistrate Judge of the Superior Court of the Virgin Islands EFTA00018917
Page: EFTA00018917 →21 22 23 24 25 26 27 28 JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defendants. Case No. COMPLAINT FOR DAMAGES DEMAND FOR JURY TRIAL PlaintiffJane Doe ("Doe" or "Plaintiff") al
Page: EFTA00019101 →This case arises out of years of sexual abuse and exploitation of a young girl by notorious pedophile and convicted sex offender Jeffrey Epstein ("Epstein"). It all started in 1994 when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a summer camp in Michigan. Jane Doe
Page: EFTA00019101 →n their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defe
Page: EFTA00019101 →y notorious pedophile and convicted sex offender Jeffrey Epstein ("Epstein"). It all started in 1994 when
Page: EFTA00019101 →irgin Islands, confirming that he and Defendant Richard D. Kahn are the two Trustees of The 1953 Trust. 32. On September 6, 2019, Magistrate Judge Carolyn P. Hermon-Percell of the Superior Court of the Virgin Islands ordered that Epstein's will be admitted to probate and authorized Mr. Indyke and Mr. Kahn to administer
Page: EFTA00019106 →Entities connected to both Jeffrey Epstein and Carolyn P. Hermon-Percell

Richard Kahn
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
United States
LOCATIONJane Doe
PERSONErika Kellerhals
PERSONthe Southern District
LOCATION
New York
LOCATION
U.S. Virgin Islands
LOCATION
Michigan
LOCATIONthe State of New York
LOCATIONDistrict Court for the Southern District of New York
ORGANIZATIONU.S. Virgin
LOCATIONRoyal Palms Professional Building
ORGANIZATIONthe Superior Court
ORGANIZATIONthe Superior Court of the Virgin Islands
ORGANIZATIONInterlochen Arts Camp
ORGANIZATIONthe New York Penal Law
ORGANIZATIONN.Y. P.L.
ORGANIZATION