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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
filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 34. Epstein's will was entered into probate on September 6, 2019, and
6 mentions1 same-page
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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
filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 38. Epstein's will was entered into probate on September 6, 2019, and
6 mentions1 same-page
Page ?Same page
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
filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 38. Epstein's will was entered into probate on September 6, 2019, and
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6 mentions1 same-page
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OUTHERN DISTRICT OF NEW YORK Plaintiff CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, i in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL, Defendants. COMPLAINT 3514.011 Page 1 of 19 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_000076
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
ncier 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.cont/2011/02/25/billionaire-jeffrey-cpstein-im-a-sex-offender-not-a-pr
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
filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 38. Epstein's will was entered into probate on September 6, 2019, and
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Mutual Connections (38)
Entities connected to both Jeffrey Epstein and the Matter of the Estate of
Richard Kahn
PERSON32,356 w/ Jeffrey·4 w/ the
DI
Darren Indyke
PERSON17,179 w/ Jeffrey·4 w/ the
Ghislaine Maxwell
PERSON8,987 w/ Jeffrey·4 w/ the
Jes Staley
PERSON4,304 w/ Jeffrey·4 w/ the
Martha Stewart
PERSON3,074 w/ Jeffrey·4 w/ the
Kenneth Marra
PERSON2,566 w/ Jeffrey·4 w/ the
New York
LOCATION1,992 w/ Jeffrey·4 w/ the
U.S. Virgin Islands
LOCATION1,639 w/ Jeffrey·4 w/ the
Palm Beach
LOCATION1,429 w/ Jeffrey·3 w/ the
Les Wexner
PERSON1,040 w/ Jeffrey·3 w/ the
David Boies
PERSON978 w/ Jeffrey·3 w/ the
Metropolitan Correctional Center
ORGANIZATION863 w/ Jeffrey·4 w/ the
Southern District of New York
ORGANIZATION686 w/ Jeffrey·4 w/ the
SM
Sigrid McCawley
PERSON539 w/ Jeffrey·3 w/ the
United Kingdom
LOCATION512 w/ Jeffrey·3 w/ the
Alaska
LOCATION441 w/ Jeffrey·2 w/ the
Lauderdale
LOCATION321 w/ Jeffrey·2 w/ the
Edward Jay Epstein
PERSON228 w/ Jeffrey·3 w/ the
New York Post
ORGANIZATION224 w/ Jeffrey·3 w/ the
New Mexico
LOCATION219 w/ Jeffrey·3 w/ the