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K x Plaintiff, Case No. 19 Civ. 10788 COMPLAINT -against- AND JURY DEMAND DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, Defendants. x Plaintiff by and through her attorneys, Cuti Hecker Wang LLP and Allred, Maroko & Goldberg, for her Complaint alleges as follows:
Page: EFTA00025109 →king full-time to support herself, Jeffrey Epstein preyed open her, manipulated her to be completely dependent on him, and sexually abused her. 2. Epstein was presented to as someone who had learned about her challenging circumstances and had the resources and interest to assist her — including by hel
Page: EFTA00025109 →d RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, Defendants. x Plaintiff by and thro
Page: EFTA00025109 →er own and working full-time to support herself, Jeffrey Epstein preyed open her, manipulated her to be c
Page: EFTA00025109 →DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, Defendants. x Plaintiff by and through her attorneys, Cuti Hecker Wang LLP and Allred, Maroko & Goldberg, for her Complaint alleges as follows: NATURE OF THE ACTION 1. When Plaintiff was just seventeen years old, living
Page: EFTA00025109 →DOE, Case No. 19 Civ. 10758 Plaintiff, COMPLAINT -against- AND JURY DEMAND DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, and Defendants. x Plaintiff Mary Doe', by and through her attorneys, Cuti Hecker Wang LLP and Allred, Maroko & Goldberg, for her Complaint alleg
0066988 Case 1.19-cv-10758-PAE-DCF Document 1 Filed 11/20/19 Page 2 of 19 important and powerful he was. 4. Mary felt very fortunate to have met Epstein. She was amazed that such a powerful man wanted to help her, and believed that she could trust him. Because they had hours of conversation about he
d RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, and Defendants. x Plaintiff Mary Do
d RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, and Defendants. x Plaintiff Mary Doe
DYKE and RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, and Defendants. x Plaintiff Mary Doe', by and through her attorneys, Cuti Hecker Wang LLP and Allred, Maroko & Goldberg, for her Complaint alleges as follows: NATURE OF THE ACTION 1. Beginning when Plaintiff Mary Doe was sixteen years
ITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, -against- DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, Defendants. Case No. 19 Civ. 10788 COMPLAINT AND JURY DEMAND Plaintiff by and through her attorneys, Cuti Hecker Wang LLP and Allred, Maroko
ase 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 3 of 13 11. brings this action seeking, at last, some remedy for the egregious abuse that Epstein inflicted when she was a child. PARTIES 12. Plaintiff.] an individual who resides 13. Defendants Darren K. Indyke and Richard D. Kahn are the E
d RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, Defendants. Case No. 19 Civ. 10788
d RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, Defendants. Case No. 19 Civ. 10788 C
TORS OF THE ESTATE OF JEFFREY E. EPSTEIN, Defendants. Case No. 19 Civ. 10788 COMPLAINT AND JURY DEMAND Plaintiff by and through her attorneys, Cuti Hecker Wang LLP and Allred, Maroko & Goldberg, for her Complaint alleges as follows: NATURE OF THE ACTION EFTA00084144 Case 1:19-cv-10788-GHW-DCF Document 1 Fil
Entities connected to both Jeffrey Epstein and Cuti Hecker Wang LLP

Richard Kahn
PERSONDarren Indyke
PERSON
New York
LOCATION
New York State
LOCATION
Gloria Allred
PERSONMAROKO & GOLDBERG
ORGANIZATIONDaniel Mullkoff
PERSONthe New York Penal Law
ORGANIZATIONMariann Meier Wang
PERSONWANG LLP
PERSONCUTI HECKER
ORGANIZATION