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ondition suffered by such person as a result of conduct which would constitute" certain sex crimes under New York Penal Law Article 130. Epstein and Ghislaine Maxwell sexually assaulted Plaintiff by forcible compulsion within 20 years of filing this Complaint, and that sexual assault constitutes one or more sex c
Page: EFTA00023295 →under New York Penal Law Article 130. Epstein and Ghislaine Maxwell sexually assaulted Plaintiff by forcible
Page: EFTA00023295 →York Times reporter "that criminalizing sex with teenage girls was a cultural aberration and that at times in history it was perfectly acceptable." James B. Stewart, The Day Jeffrey Epstein Told Me He Had Dirt on Powerful People, N.Y. Times (Aug. 12, 2019), https://www.nytimes.com/2019/08/12/business/jeffrey-ep
Page: EFTA00023295 →ise for years, up until the last time Jane Doe saw Epstein. 46. One day, Epstein had someone call Jane Doe to his mansion. When Jane Doe arrived, Maxwell was waiting for her and led her upstairs to Epstein's master bedroom. When they got to the bedroom, sex toys were laid out on the bed. Epstein and M
Page: EFTA00023302 →rported connections to Donald Trump, Bill Clinton and Prince Andrew, and moved in elite circles, including for several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. Epstein and the Miami US attorney's office, headed at the time by Alexander Acosta, broke
r several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoon Robert
cluding for several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoo
nterest Rates for First Time Since 2008 Crisis Public Corruption Epstein Jeffrey Epstein Hoped to Seed Human Race With His DNA New York Times By James B. Stewart, Matthew Goldstein and Jessica Silver-Greenberg 7/31/19 Jeffrey E. Epstein, the wealthy financier who is accused of sex trafficking, had an unusual
rported connections to Donald Trump, Bill Clinton and Prince Andrew, and moved in elite circles, including for several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. Epstein and the Miami US attorney's office, headed at the time by Alexander Acosta, broke
r several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoon Robert
cluding for several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoo
26 SDNY News Clips, Wednesday, July 31, 2019 Public Corruption Epstein Jeffrey Epstein Hoped to Seed Human Race With His DNA New York Times By James B. Stewart, Matthew Goldstein and Jessica Silver-Greenberg 7/31/19 Jeffrey E. Epstein, the wealthy financier who is accused of sex trafficking, had an unusual
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 Page 2 of 19 Pl
gainst 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 and belief and to all ot
arren 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 and belief and to all other matter
York Times reporter "that criminalizing sex with teenage girls was a cultural aberration and that at times in history it was perfectly acceptable." James B. Stewart, The Day Jeffrey Epstein Told Me He Had Dirt on Powerful People, N.Y. Times (Aug. 12, 2019), https://www.nytimes.com/2019/08/12/business/jeffity-ep
r several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoon Robert
cluding for several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoo
rported connections to Donald Trump, Bill Clinton and Prince Andrew, and moved in elite circles, including for several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. Epstein and the Miami US attorney's office, headed at the time by Alexander Acosta, broke
est Rates for First Time Since 2008 Crisis. 35 Public Corruption Epstein Jeffrey Epstein Hoped to Seed Human Race With His DNA New York Times By James B. Stewart, Matthew Goldstein and Jessica Silver-Greenberg 7/31/19 Jeffrey E. Epstein, the wealthy financier who is accused of sex trafficking, had an unusual
ondition suffered by such person as a result of conduct which would constitute" certain sex crimes under New York Penal Law Article 130. Epstein and Ghislaine Maxwell sexually assaulted Plaintiff by forcible compulsion within 20 years of filing this Complaint, and that sexual assault constitutes one or more sex c
ise for years, up until the last time Jane Doe saw Epstein. 46. One day, Epstein had someone call Jane Doe to his mansion. When Jane Doe arrived, Maxwell was waiting for her and led her upstairs to Epstein's master bedroom. When they got to the bedroom, sex toys were laid out on the bed. Epstein and M
under New York Penal Law Article 130. Epstein and Ghislaine Maxwell sexually assaulted Plaintiff by forcible
York Times reporter "that 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-epst
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 2 of 19 Plaint
gainst 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 and belief and to all ot
arren 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 and belief and to all other matter
York Times reporter "that criminalizing sex with teenage girls was a cultural aberration and that at times in history it was perfectly acceptable." James B. Stewart, The Day Jeffrey Epstein Told Me He Had Dirt on Powerful People, N.Y. Times (Aug. 12, 2019), https://www.nytimes.com/2019/08/12/business/jeffity-ep
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_00007677 EFTA00158752
gainst 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 and belief and to all ot
arren 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 and belief and to all other matter
York Times reporter "that criminalizing sex with teenage girls was a cultural aberration and that at times in history it was perfectly acceptable." James B. Stewart, The Day Jefrey Epstein Told Me He Had Dirt on Powerful People, N.Y. Times (Aug. 12, 2019), https://www.nytimes.com/2019/08/ 2/businessijeffrey-cps
Crisis. 35 Public Corruption Epstein EFTA00018441 --- PAGE BREAK --- Jeffrey Epstein Hoped to Seed Human Race With His DNA New York Times By James B. Stewart, Matthew Goldstein and Jessica Silver-Greenberg 7/31/19 Jeffrey E. Epstein, the wealthy financier who is accused of sex trafficking, had an unusual
Page: EFTA00018442 →rported connections to Donald Trump, Bill Clinton and Prince Andrew, and moved in elite circles, including for several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. Epstein and the Miami US attorney's office, headed at the time by Alexander Acosta, broke
Page: EFTA00018448 →r several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoon Robert
Page: EFTA00018448 →cluding for several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoo
Page: EFTA00018448 →--- SDNY News Clips, Wednesday, July 31, 2019 Public Corruption Epstein Jeffrey Epstein Hoped to Seed Human Race With His DNA New York Times By James B. Stewart, Matthew Goldstein and Jessica Silver-Greenberg 7/31/19 Jeffrey E. Epstein, the wealthy financier who is accused of sex trafficking, had an unusual
Page: EFTA00018467 →rported connections to Donald Trump, Bill Clinton and Prince Andrew, and moved in elite circles, including for several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. Epstein and the Miami US attorney's office, headed at the time by Alexander Acosta, broke
Page: EFTA00018474 →r several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoon Robert
Page: EFTA00018474 →cluding for several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoo
Page: EFTA00018474 →Entities connected to both Ghislaine Maxwell and James B. Stewart

Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
United States
LOCATION
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Eric Trump
PERSON
Julie K. Brown
PERSONDarren Indyke
PERSON
Virginia Giuffre
PERSON
New York
LOCATION
Les Wexner
PERSONJane Doe
PERSONEmmy Taylor
PERSON
David Boies
PERSON