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

onduct perpetrated against Plaintiff when she was under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55. COUNT TWO Sexual Battery 74. Plaintiff incorporates by reference all preceding parag

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

F Document 1 Filed 11/20/19 Page 17 of 19 injury suffered as a result of conduct that would constitute sexual offenses as defined in Article 130 of the New York Penal Law, and such acts and/or omissions were committed against Mary when she was less than eighteen years of age. FIRST CAUSE OF ACTION (Battery) 108. P

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

would constitute sexual 10 EFTA00084153 Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 11 of 13 offenses as defined in Article 130 of the New York Penal Law, and such acts and/or omissions were committed against when she was less than eighteen years of age. 70. Epstein's conduct constitutes "childhood

SOUTHERN DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defendants. Case No. COMPLAINT FOR DAMAGES DEMAND FOR JURY TRIAL Plaintiff Jane Doe ("Doe" or "Plaintiff") a

N I. This case arises out of years of sexual abuse and exploitation of a girl by notorious pedophile and convicted sex offender Jeffrey Epstein ("Epstein"). It all started in when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a summer camp in Michigan. Jane Doe was t

n their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Def

n their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defe

onduct perpetrated against Plaintiff when she was under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55. SECOND CAUSE OF ACTION (Sexual Battery) 38. Plaintiff incorporates by reference all