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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 →OR THE SOUTHERN DISTRICT OF NEW YORK JANE DOE 1000, Plaintiff, CASE NO: v. DARREN K. INDYKE and in their capacities as the execuorl. ESTATE OF JEFFREY EDWARD EPSTEIN, Defendants. COMPLAINT BOIES $CHILLER FLEXNER LLP 1 EFTA00099176 Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 2 of 14 Plaintiff
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
s to her own acts and status and upon information and belief and to all other matters as follows: NATURE OF THE ACTION 1. This suit arises out of Jeffrey Epstein's sexual abuse of Plaintiff. 2. Jane Doe 1000 was sexually trafficked by Epstein as part of his organized ring of procuring young and underage girls
criminalizing sex with teenage girls was a cultural aberration and that at times in history it was perfectly acceptable." James B. Stewart, The Day Je •ey Epstein Told Me He Had Din on Powerful People, N.Y. Times (Aug. 12, 2019), https://www.nytimes.com/2019/08/12/business/jeffrey-epstein-interview.html. II.
pacity as an appointed executor of the Estate of Jeffrey E. Epstein. 18. Defendant Richard D. Kahn is sued
pacity as an appointed executor of the Estate of Jeffrey E. Epstein. 18. Defendant Richard D. Kahn is sued
fectly acceptable." James B. Stewart, The Day Je •ey Epstein Told Me He Had Din on Powerful People, N.Y. Time
iff 30. Epstein's last will and testament (the "Will") was executed on August 8, 2019, at the Metropolitan Correctional Center. The witnesses were Martel Colon Miro and Gulnora Tali. The Will included affidavits from Darren K. Indyke and 1 in which they swear an "Oath of Willingness to Serve as Executor and Ap
OUTHERN DISTRICT OF NEW YORK Plaintiff, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL, Defendants. COMPLAINT BOIES $CHILLER FLEXNER LLP 1 EFTA00078311 Case 1:19-cv-10475-LGS-DCF Document 1 Filed 11/12/19
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") and Ghislaine Maxwell ("Maxwell") (collectively, "Defendants"), avers upon personal knowledge as to her own acts and status and upon information
cier told The Post yesterday. `It's the difference between a murderer and a person who steals a bagel,' said Epstein." Amber Sutherland, Billionaire Jeffrey Epstein: I'm a Sex Offender Not a Predator, N.Y. Post (Feb. 25, 2011), https://nypost.com/2011/02/25/billionaire-jeffrey-epstein-im-a-sex-offender-not-a-pre
pacity as an appointed executor of the Estate of Jeffrey E. Epstein. 20. Defendant Richard D. Kahn is sued
pacity as an appointed executor of the Estate of Jeffrey E. Epstein. 20. Defendant Richard D. Kahn is sued
ff. 34. Epstein's last will and testament (the "Will") was executed on August 8, 2019, at the Metropolitan Correctional Center. The witnesses were Martel Colon Miro and Gulnora Tali. The Will included affidavits from Darren K. Indyke and Richard D. Kahn, in which they swear an "Oath of Willingness to Serve as E
OUTHERN DISTRICT OF NEW YORK Plaintiff, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL, Defendants. COMPLAINT BOIES $CHILLER FLEXNER LLP 1 EFTA00105975 Case 1:19-cv-10475-LGS Document 1 Filed 11/12/19 Page
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") and Ghislaine Maxwell ("Maxwell") (collectively, "Defendants"), avers upon personal knowledge as to her own acts and status and upon information
cier told The Post yesterday. `It's the difference between a murderer and a person who steals a bagel,' said Epstein." Amber Sutherland, Billionaire Jeffrey Epstein: I'm a Sex Offender Not a Predator, N.Y. Post (Feb. 25, 2011), https://nypost.com/2011/02/25/billionaire-jeffrey-epstein-im-a-sex-offender-not-a-pre
pacity as an appointed executor of the Estate of Jeffrey E. Epstein. 20. Defendant Richard D. Kahn is sued
pacity as an appointed executor of the Estate of Jeffrey E. Epstein. 20. Defendant Richard D. Kahn is sued
ff. 34. Epstein's last will and testament (the "Will") was executed on August 8, 2019, at the Metropolitan Correctional Center. The witnesses were Martel Colon Miro and Gulnora Tali. The Will included affidavits from Darren K. Indyke and Richard D. Kahn, in which they swear an "Oath of Willingness to Serve as E
OUTHERN DISTRICT OF NEW YORK Plaintiff CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, i in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL, Defendants. COMPLAINT 3514.011 Page 1 of 19 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_000076
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") and Ghislaine Maxwell ("Maxwell") (collectively, "Defendants"), avers upon personal knowledge as to her own acts and status and upon information
ncier told The Post yesterday. it's the difference between a murderer and a person who steals a bagel,' said Epstein." Amber Sutherland, Billionaire Jeffrey Epstein: I'm a Sex Offender Not a Predator, N.Y. Post (Feb. 25, 2011), https://nypost.cont/2011/02/25/billionaire-jeffrey-cpstein-im-a-sex-offender-not-a-pr
pacity as an appointed executor of the Estate of Jeffrey E. Epstein. 20. Defendant Richard D. Kahn is sued
pacity as an appointed executor of the Estate of Jeffrey E. Epstein. 20. Defendant Richard D. Kahn is sued
ff. 34. Epstein's last will and testament (the "Will") was executed on August 8, 2019, at the Metropolitan Correctional Center. The witnesses were Martel Colon Miro and Gulnora Tali. The Will included affidavits from Darren K. Indyke and Richard D. Kahn, in which they swear an "Oath of Willingness to Serve as E
Subject: Google Alert - Bureau of Prisons From: Google Alerts <[email protected]> To: [email protected] Bureau of Prisons NEWS Was Epstein on Suicide Watch When He Died? The New York Times Under Bureau of Prison regulations, the government's jails and prisons must have one or more room
s designed for housing an inmate on suicide ... Jeffrey Epstein dies by suicide: Barr orders investigatio
s. So for the last few days, he's been eating snacks from the vending machines and no proper meal. Thank you in advance for your help. Sincerely, Martel Colon Miro, Esq. Law Offices of Michael Lambert 369 Lexington Ave. 2 floor PMB#229 New York, NY 10016 (917) 743-7071 NOTICE: This message may contain infor
Entities connected to both Jeffrey Epstein and Martel Colon Miro

Richard Kahn
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
Jes Staley
PERSONJane Doe
PERSON
Martha Stewart
PERSON
Kenneth Marra
PERSON
New York
LOCATION
U.S. Virgin Islands
LOCATION
Palm Beach
LOCATION
Les Wexner
PERSON
David Boies
PERSON
Metropolitan Correctional Center
ORGANIZATION
Southern District of New York
ORGANIZATIONSigrid McCawley
PERSON
United Kingdom
LOCATION
Alaska
LOCATIONThe New York Post
ORGANIZATION
Lauderdale
LOCATION
Edward Jay Epstein
PERSON