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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
herself by disobeying Epstein. She proceeded to move out of the 66'h Street apartment building and, having nowhere else to go, found shelter at the Salvation Army housing facility. 47. Jane Doe was deeply affected by her harrowing experiences at the hands of Epstein. She suffers extreme emotional distress fr
-t O(kc4cr) NIG\ - CRocMiNG or TPie -7ArzeeeTED vent, • 5119122.3:62 PM . Jeffrey Epstein - Wildpedia WIKIPEDIA TreffRE/ EPs-TEIK cettic p elt Jeffrey Epstein Rots.- viwco &'duCAkiE rgnmte NE:\.)1/41 YOk\c't P>r5aLk'n't% 0 1•11 k) as cry - pacresLtR ecepemic Jeffrey Edward Epstein (/' cpsti:n/ EP-st•e
xner, Bill Clinton, Alan Dershowitz, and Prince Andrew, , charge Duke of York IX37. • - . Contents Early life 'Career Penalty Partner(s) Jeffrey Edward Epstein January 20, 1953 New York City, New York, U.S. August 10, 2019 (aged 66) New York City, New York, U.S. Suicide by hanging (disputed) I. J. Mo
abus them Jskeibtfllt. ot jt,,, ecrffsn (,,z) c i sa - c.01/41 In 2005, police m palm_Beach, Florida, began ng Epstein plainaihil he ha he I Epstein pleaded -old daughter. 0OB-by a on and o olic months in custoT He was convicted of only these controversial plead al offs as 14 wh procurin
r inclusion in the Crime Vici-i-ns Where are they now? The 1, alleged in a sworn affidavit that at ale 17, (then known as biggest players in The Jeffrey Epstein case (tittps-fivirwim.youlabes; she had, hear sexually, trafficked :by Epstein_ and Ghislaine omiwatch2v=ytirt§reJesi). Maxwell for their
d when Drysdale Government Securities collapsed because of fraud.[431 EFTA00262653 19/22, 3:52 PM 7::.:IMS-ft lv (.c_ eat.tnefte_r:-. n ;:r Jeffrey Epstein - Wikipedia •-• ,ot Liquid Funding was initially so percent owned by Bear Stearns. Through the help of the credit rating agencies — Standard & Poor's, Fitch Ratings
to understand a lot of homelessness in the area is situational and if we give people the required help when they need it, they can au+ Sr" "Salvation Army will also contribute $5m and build more community housing: he said. "We know homelessness is more hidden in regions and a lot of people either c
9127/22. 10:57 Am Al \\ii ^Z4 e u'a -Y4-3ikccfilANc)lerNctiaLcreilirt— ICI. COW trelkivi ft im Andrew, Duked-Peary / INC PIA! Russian women at Epstein's New York residence during his last visit to the mansion in 2010, and of Irina's foot massage was His Royal Highness, Prince Andrew, the Duke of Yo
France, Spain, the United Kingdom, and Saudi Arabia in the 1980s. The passport showed his place of compact dis descriptio the safe were U.S. v. Jeffrey Epstein inclictmen0 EFTA00266224 Hu- GOV - COMMOK, NEACT-1/ {Fr Fl teS bESIGIOERS ,D/L:ao EMAIL mpooJeit_ • rfleclical al7rociation letter :1../
llegations.D4C 147)(148] Giuffre filed a defamation suit against Dershowitz, • External video I rE Where are they now? The biggest players in the Jeffrey Epstein case (htlps://www.youtube.c om/watch?v=yPjn6rcJqsl) Perversion of Justice, The Miami Herald, November 29, 2018. https://en.wikipedia.org
ent and failing to Otity Epstein's alleged victims aboutthis agreement-Iag Conviction and sentencing (2008-2011) External video Documents Who Is Jeffrey Eaatein accused of sexually abusing teen girls? qlttpa://www.you tulienorrtlwatch?v=11DPzW9C0sU) Perversion of Justice, Miami Herald, November 29, 2018.
yone needs to understand a lot of homelessness in the area is situational and if we give people the required help when they need it, they can "Salvation Army will also contribute $5m and build more community housing," he said. "We know homelessness is more bidden in regions and a lot of people either
deposition from "Jane Doe 3" that accused Maxwell of recruiting her in 1999, when she was a minor, and grooming her to provide sexual services for Epstein. Zs A 2018 exposé by Julie K. Brown in the Miami Herald revealed Jane Doe 3 to be yi_Tinia Giuffre, who was previously known as Virginia Roberts. G
Ces RJR \i‘..cTtri I aca 1 •,•••• ••••••••••ast ..••..ono • • The controversial non- prosecution agreement External video pocumentary: Who is Jeffrey. Epstein, accused of semelly abusing teen gins? (https:ilwww.you. tube,com/yuatcp?y=1.WPzW9g9sy) Perversion of Justice, lyliamttferall, November 2
74 b122122,1:31 Pm Er Atte) I 45P1 TORSS- • Jeffrey Epstein - Meech Non-prosecution agreement (NPA) (2006-20
Tickera EFTA00264416 News www.ypct.com.au 6 ct.) g1/4k! A Discussing homelessness and • -:--gs$6tommunity housingtacross YP. Ins LIDDY. "Salvation Army will also Youruit contribute $5m and build more community housing? be said. forllo Homelessness Housing, • in:totr)ef hidden in regions o ando
5(19/22, 3:52 PM SEA At. "250SC. fktmct JcereY Epsteh - Wildpedla Epstein a massage". She claims she was taken to his mansion, where he exposed himself and had sexual intercourse with her, and paid her $200 immediately af
the allegations .1-40[471(14-81 Giuffre filed a defamation suit against Dershowi External video th yVher, are they now? The, bigctes.1*y,rs in the Jeffrey Epstein case Thttps-J/www.youtube.c opywatch?v=yyjri§rolqs11 Perversion of Justice, The Miami Herald, November 29, 2018. (physically and-sexuall
hat he would not be present at the platinum Jubilee National Service of Thanksghting at St Paul's Cathedral on 3 June.M Allegations o sexual abuse Jeffrey Epstein and related associations Andrew was friends wit an American financier who was convicted ofjex traffickinp in 2008. BBC News reported in March 2011
yone needs to understand a lot of homelessness in the area is situational and if we give people the required help when they need it, they can "Salvation Army will also contribute S5m and build more community housing," he said. "We know homelessness is more hidden In regions and a lot ofpeople either c
pollo Investor Halts New Commitments Over Black's Epstein Ties <https://www.ft.corn/content/7aal5cae- 0baf-
the country since 2000." Deputy Attorney General Jeffrey Rosen "said that if the resolution wins court ap
IM), Miguel Almaguer said, "The new guidelines come as new outbreaks or superspreader events are tied to close gatherings. In Minnesota, at least 20 Salvation Army employees contracted the virus during a conference. At church events in North Carolina and in Maine, nearly 100 tested positive after few took prec
pollo Investor Halts New Commitments Over Black's Epstein Ties Washington Times: No October Surprise: Pot
the country since 2000." Deputy Attorney General Jeffrey Rosen "said that if the resolution wins court app
M), Miguel Almaguer said, "The new guidelines come as new outbreaks or superspreader events are tied to close gatherings. In Minnesota, at least 20 Salvation Army employees contracted the virus during a conference. At church events in North Carolina and in Maine, nearly 100 tested positive after few took prec
that molestered in Technical Engineering school and usine rship Refer to File 2. Legal Structure Stage 1 / Stage 1B Pattern of Targeting / File 5. Epstein - Maxwell - Modelling - John Olsen and Donald Trump EFTA00261694 Outspoken..., / the targeted victim of would not stop seeking justice concerni
wledge of his - a filialinikot like his sibling that the stated at of his the perpetrator of Sexual Molestation of his at age 11-14 year • Jeffery - Kadina - Died age 32 years of age - Between Bute and Kadina - Road accident - Driving home from his place of employment - Qualified En- gineer -
yone needs to understand a lot of homelessness in the area is situational and if we give people the required help when they need it, they can 'Salvation Army will also contribute S5m and build more community housing,' he said. "We know homelessness is more hidden in regions and a lot of people either
, Ca October 28, 2006 132. LE, Viron M, Johnson JE, Hudkins A, Samples G, Kliman G: A school-based m
g jury verdict against the Archdiocese of Dallas. In April, 1998, Dr. Kliman was interviewed by Channel Four anchorwoman, Linda Yee, concerning his Salvation Army project providing the Cornerstone form of psychoanalytic psychotherapy for homeless preschoolers and toddlers,. The Cornerstone project itself was
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 →Entities connected to both Jeffrey Epstein and Salvation Army

Richard Kahn
PERSONDarren Indyke
PERSONLarry Visoski
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Woody Allen
PERSON
John F. Kennedy
PERSON
Joi Ito
PERSON
Alan Dershowitz
PERSON
George Mitchell
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Lawrence Krauss
PERSON
Condoleezza Rice
PERSON
Stephen Hawking
PERSONJack Goldberger
PERSON
Joe Biden
PERSON