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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
sserted within this pleading. 13 EFTA00099188 Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 14 of 14 Dated: November 14, 2019. /s/ Joshua I. Schiller David Boies BOLES $CHILLER FLEXNER LLP 333 Main Street Armonk, NY 10504 (914) 749-8200 Joshua I. Schiller BOLES $CHILLER FLEXNER LLP 55 Hudso
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
of 19 JURY DEMAND Plaintiff hereby demands a trial by jury on all causes of action asserted within this pleading. Dated: November 12, 2019. Is/ Joshua I. Schiller David Boies Bows $CHILLER FLEXNER LLP Joshua I. Schiller BNB $CHILLER FLEXNER LLP Sigrid McCawley (Pro Hac Vice Pending) BOLES $CHILLER FLEXNE
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
9 of 19 JURY DEMAND Plaintiff hereby demands a trial by jury on all causes of action asserted within this pleading. Dated: November 12, 2019. Is/Joshua I. Schiller David Boies BOIES $CHILLER FLEXNER LLP 333 Main Street Armonk, NY 10504 (914) 749-8200 Joshua I. Schiller BOIES $CHILLER FLEXNER LLP 55 Hudso
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 →NEW YORK Plaintiff, CASE NO: 19-cv-10475-LGS-DCF 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. PLAINTIFF NOTICE OF DEPOSITION OF DEFENDANT GHISLAINE MAXWELL PLEASE TAKE NOTICE that, pursuant to Federal R
Page: EFTA00030306 →eir capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN and GHISLAINE MAXWELL, Defendants. PLA
Page: EFTA00030306 →ted: March 24, 2020 By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Boles Schiller Flexner LLP David Boles Boles Schiller Flexner LLP a Joshua I. Schiller Andrew Villacastin Sabina Mariella Boies Schiller Flexner LLP Mnal Counsel for EFTA00030307 --- PAGE BREAK --- CERTIFICATE OF SERVICE WE HE
Page: EFTA00030307 →Entities connected to both Jeffrey Epstein and Joshua I. Schiller

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