Epstein Secrets

UTHERN DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY E. EPSTEIN, Defendants. Case No. JURY TRIAL DEMANDED COMPLAINT EFTA00103496 Case 1:19-cv-08673 Document 1 Filed 09/18/19 Page 2 of 16 Plaintiff Jane Doe

18, 2019). Because Doe was a child at the time of her abuse, which took place more than 15 years ago, Doe is largely without documentary evidence of Epstein's crimes against her. However, we believe that in the course of your Office's criminal investigation and prosecution of Epstein's sex trafficking c

eir capacities as the executors of the ESTATE OF JEFFREY E. EPSTEIN, Defendants. Case No. JURY TRIAL DEMA

her claims in this action. FACTUAL ALLEGATIONS Defendant Epstein's Scheme of Exploitation and Abuse 15. Defendan

e in o interview her about her experiences with Mr. Epstein. We understand that, at t at time, counsel retain

eir capacities as the executors of the ESTATE OF JEFFREY E. EPSTEIN, Defendants. Case No. JURY TRIAL DEMAN

KAPLAN HECKER & FINK LLP VIA E-MAIL United States Attorney Southern District of New York Geoffrey S. Berman do Assistant United States Attorney 350 FIFTH AVENUE I SUITE

status of discovery, Plaintiff respectfully requests that she be allowed to move forward. The sixteen cases currently pending against the Estate of Jeffrey Epstein in the Southern District of New York are all in very different stages of litigation. Two cases have already been stayed by agreement of the parties.

its participants from liability and accountability." (Id., at 18.) The New York Times reports that this lawsuit "seeks to head off an effort by Mr. Epstein's executor, Mr. Indyke, to turn Mr. Epstein's vast wealth into a victim's compensatory fund."' Particularly in light of these recent developments,

District of New York are all in very different stages of litigation. Two cases have already been stayed by agreement of the parties. Doe 1 et a! v. Jeffrey Epstein et at, 19-cv-07675-GBD-DCF (S.D.N.Y.); Doe 17 v. ',dyke et at, 19-cv-09610-PAE-DCF (S.D.N.Y.). One was filed recently, on December 27, 2019. Anasta

een cases currently pending against the Estate of Jeffrey Epstein in the Southern District of New York are

hat this lawsuit "seeks to head off an effort by Mr. Epstein's executor, Mr. Indyke, to turn Mr. Epstein's va

Case 1:19-cv-08673-KPF-DCF Document 45 Filed 01/15/20 Page 1 of 3 KAPLAN HECKER & FINK LLP WWW.KAPLANHECKER.COM DIRECT DIAL 212.763.0884 DIRECT EMAIL rkaplan©kaplanhecker.com January 15, 2020 VIA ECF The Honorable Katherine Polk Fail

there is no issue in this case, as there are in many of the other cases, about whether or not our client settled any prior claims with either Mr. Epstein or the estate. And the facts are straightforward. She was, as your Honor knows, was witness No. 1, victim No. 1 in the indictment. The U.S. Attorn

, I don't -- I don't -- with respect, I don't think we have that problem here. Our client is very poor. She was a street kid when she was raped by Jeffrey Epstein, a 14-year-old street kid. She's not a wealth -- she's a very poor person today. She does not go to doctors, certainly, for everyone who knows me,

poor. She was a street kid when she was raped by Jeffrey Epstein, a 14-year-old street kid. She's not a w

our client settled any prior claims with either Mr. Epstein or the estate. And the facts are straightforward

INGS BEFORE THE HONORABLE JUDGE DEBRA C. FREEMAN, UNITED STATES DISTRICT COURT MAGISTRATE JUDGE APPEARANCES: For Plaintiff: For the Defendants: KAPLAN HECKER & FINK LLP BY: ROBERTA A. KAPLAN, ESQ. KATE L. DONIGER, ESQ. 350 Fifth Avenue, Suite 7110 New York, New York 10118 212-763-0883 TROUTMAN SANDERS LLP BY: