Epstein Secrets

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

of 19 JURY DEMAND Plaintiff hereby demands a trial by jury on all causes of action asserted within this pleading. Dated: November 12, 2019. Is/ Joshua I. Schiller David Boies Bows $CHILLER FLEXNER LLP Joshua I. Schiller BNB $CHILLER FLEXNER LLP Sigrid McCawley (Pro Hac Vice Pending) BOLES $CHILLER FLEXNE

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

sserted within this pleading. 13 EFTA00099188 Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 14 of 14 Dated: November 14, 2019. /s/ Joshua I. Schiller David Boies BOLES $CHILLER FLEXNER LLP 333 Main Street Armonk, NY 10504 (914) 749-8200 Joshua I. Schiller BOLES $CHILLER FLEXNER LLP 55 Hudso

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

9 of 19 JURY DEMAND Plaintiff hereby demands a trial by jury on all causes of action asserted within this pleading. Dated: November 12, 2019. Is/Joshua I. Schiller David Boies BOIES $CHILLER FLEXNER LLP 333 Main Street Armonk, NY 10504 (914) 749-8200 Joshua I. Schiller BOIES $CHILLER FLEXNER LLP 55 Hudso

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

under New York Penal Law Article 130. Epstein and Ghislaine Maxwell sexually assaulted Plaintiff by forcible

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

pleading. 13 EFTA00023304 --- PAGE BREAK --- Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 14 of 14 Dated: November 14, 2019. /s/ Joshua I. Schiller David Boies BOIES $CHILLER FLEXNER LLP 333 Main Street Armonk, NY 10504 (914) 749-8200 Joshua I. Schiller BOIES SCHILLER FLEXNER LLP 55 Hudso

O: 19-cv-10475-LGS-DCF 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. PLAINTIFF NOTICE OF DEPOSITION OF DEFENDANT GHISLAINE MAXWELL PLEASE TAKE NOTICE that, pursuant to Federal Rule of Civil Procedure

TAKE NOTICE that, pursuant to Federal Rule of Civil Procedure 30, Plaintiff by and through her attorneys, will take the oral deposition of Defendant Ghislaine Maxwell on April 29, 2020, beginning at 10:00 a.m. Eastern Standard Time at the offices of Boies Schiller Flexner LLP unless the parties mutually a

that, pursuant to Federal Rule of Civil Procedure 30, Plaintiff by and through her attorneys, will take the oral deposition of Defendant Ghislaine Maxwell on April 29, 2020, beginning at 10:00 a.m. Eastern Standard Time at the offices of Boies Schiller Flexner LLP unless the parties mutually agree to

ted: March 24, 2020 By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Boles Schiller Flexner LLP David Boles Boles Schiller Flexner LLP a Joshua I. Schiller Andrew Villacastin Sabina Mariella Boies Schiller Flexner LLP Mnal Counsel for EFTA00030307 --- PAGE BREAK --- CERTIFICATE OF SERVICE WE HE