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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
st 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 Appointment of Loca
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
st 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 Executor and Appoi
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
st 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 Executor and Appoi
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
st 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 Executor and Appoi
el Miller, Steptoe & Johnson • Michael Scavelli, Steptoe & Johnson • Reid Weingarten, Steptoe & Johnson Beyond that, I can't send a list of all of Epstein's attorneys, since he has had dozens of attorneys over the years, but it doesn't sound like that's really what you're looking for. With respect to t
: Sent: Tuesday, June 8, 2021 4:51 PM To: Subject: Attorneys Good Evening EFTA00073694 We are trying to identify the attorneys who represented Jeffrey Epstein and visited him in prison. The MCC attorney log is either illegible or the attorneys listed just one name. The names I could read were "Colon" and "
trying to identify the attorneys who represented Jeffrey Epstein and visited him in prison. The MCC attorn
sound like that's really what you're looking for. With respect to the names "Colon" and "G. Tali", it was widely reported that Mariel Colon Miro and Gulnora Tali visited Epstein in jail in connection with his will. Hope that helps, but please let us know if you need anything else. Best, From: Sent: Tuesday
toe & Johnson • Michael Scavelli, Steptoe & Johnson • Reid Weingarten, Steptoe & Johnson EFTA00088196 Beyond that, I can't send a list of all of Epstein's attorneys, since he has had dozens of attorneys over the years, but it doesn't sound like that's really what you're looking for. With respect to t
! From: Sent: Tuesday, June 8, 20214:51 PM To: Subject: Attorneys Good Evening Jessica, We are trying to identify the attorneys who represented Jeffrey Epstein and visited him in prison. The MCC attorney log is either illegible or the attorneys listed just one name. The names I could read were "Colon" and "
trying to identify the attorneys who represented Jeffrey Epstein and visited him in prison. The MCC attorn
sound like that's really what you're looking for. With respect to the names "Colon" and "G. Tali", it was widely reported that Mariel Colon Miro and Gulnora Tali visited Epstein in jail in connection with his will. Hope that helps, but please let us know if you need anything else. Best, From: Sent: Tuesday
el Miller, Steptoe & Johnson • Michael Scavelli, Steptoe & Johnson • Reid Weingarten, Steptoe & Johnson Beyond that, I can't send a list of all of Epstein's attorneys, since he has had dozens of attorneys over the years, but it doesn't sound like that's really what you're looking for. With respect to t
From: Sent: Tuesday, June 8, 2021 4:51 PM To: Subject: Attorneys Good Evening Jessica, We are trying to identify the attorneys who represented Jeffrey Epstein and visited him in prison. The MCC attorney log is either illegible or the attorneys listed just one name. The names I could read were "Colon" and "
trying to identify the attorneys who represented Jeffrey Epstein and visited him in prison. The MCC attorn
sound like that's really what you're looking for. With respect to the names "Colon" and "G. Tali", it was widely reported that Mariel Colon Miro and Gulnora Tali visited Epstein in jail in connection with his will. Hope that helps, but please let us know if you need anything else. Best, EFTA00091033 From:
1 Floor, New York, NY 10004 ('ell: Sent: Tuesday, June 8, 2021 5:22 PM To: Cc: Subject: RE: Attorneys The defense attorneys who appeared in the Epstein case and filed notices of appearances were: • James Brochin, Steptoe & Johnson • Marc Allan Fernich, Law Office of Marc Fernich, • Martin Weinberg
uestions. From: Sent: Tuesday, June 8, 2021 4:51 PM To: Subject: Attorneys Good Evening We are trying to identify the attorneys who represented Jeffrey Epstein and visited him in prison. The MCC attorney log is either illegible or the attorneys listed just one name. The names I could read were "Colon" and "
trying to identify the attorneys who represented Jeffrey Epstein and visited him in prison. The MCC attorn
is information is available on the public docket. With respect to the names "Colon" and "G. Tali", it was widely reported that Mariel Colon Miro and Gulnora Tali visited Epstein in jail in connection with his will. This information comes from publicly available sources that you would find with a Google searc
From: To: Cc: (OIG)" (USANYS)" ecl .(OIG)" Subject: Re: Epstein's TruView Date: Sun, 18 Aug 2019 17:12:27 +0000 Both requests have been made Sent from mobile device, please excuse typos. Special Agent Office
owing people since 7/6/2019: from Darren Indyke, Jeffrey Schantz, Gulnora Tali, and/or Richard Kahn. Addit
possible to get the commissary records for anyone that received money from the following people since 7/6/2019: from Darren Indyke, Jeffrey Schantz, Gulnora Tali, and/or Richard Kahn. Additionally, can we get the commissary record for Efrain Reyes since 7/6/2019? Thanks, From: (OIG) Sent: Tuesday, August
Entities connected to both Jeffrey Epstein and Gulnora Tali

Richard Kahn
PERSON
Marc Rich
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
Jes Staley
PERSON
Harry Reid
PERSONJane Doe
PERSON
Martha Stewart
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON
New York
LOCATION
Reid Weingarten
PERSON
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
Michael Milken
PERSON