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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
rd D. Kahn to administer Epstein's estate. See Order for Probate, In the Matter of the Estate opeey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Sept. 6, 2019); Letters Testamentary, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Sept. 6, 2019). 39. The Will's
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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
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
Estate of Jeey E. Epstein, Probate 8 EFTA00099183 Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 9 of 14 No. ST-19-PB-80 (Super. Ct. V.I. Sept. 6, 2019); Letters Testamentary, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Sept. 6, 2019). 35. The Will's
4 mentions1 same-page
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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
rd D. Kahn to administer Epstein's estate. See Order for Probate, In the Matter of the Estate opeey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Sept. 6, 2019); Letters Testamentary, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Sept. 6, 2019). 39. The Will's
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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
9-PB-80 (Super. Ct. V.I. Sept. 6, 2019); Letters Testamentary, In the Matter of the Estate ofJeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Sept. 6, 2019). 39. The Will's first article directs Epstein's executors "to pay from my estate all expenses of my last illness, my funeral and burial expenses,
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Mutual Connections (38)
Entities connected to both Ghislaine Maxwell and V.I. Sept. 6, 2019
Jeffrey Epstein
PERSON8,987 w/ Ghislaine·4 w/ V.I.
DI
Darren Indyke
PERSON703 w/ Ghislaine·4 w/ V.I.
New York
LOCATION653 w/ Ghislaine·4 w/ V.I.
Les Wexner
PERSON578 w/ Ghislaine·3 w/ V.I.
David Boies
PERSON465 w/ Ghislaine·3 w/ V.I.
Palm Beach
LOCATION403 w/ Ghislaine·3 w/ V.I.
SM
Sigrid McCawley
PERSON399 w/ Ghislaine·3 w/ V.I.
U.S. Virgin Islands
LOCATION385 w/ Ghislaine·4 w/ V.I.
Richard Kahn
PERSON383 w/ Ghislaine·4 w/ V.I.
Kenneth Marra
PERSON381 w/ Ghislaine·4 w/ V.I.
United Kingdom
LOCATION293 w/ Ghislaine·3 w/ V.I.
Martha Stewart
PERSON255 w/ Ghislaine·4 w/ V.I.
Southern District of New York
ORGANIZATION255 w/ Ghislaine·4 w/ V.I.
Alaska
LOCATION225 w/ Ghislaine·2 w/ V.I.
Jes Staley
PERSON199 w/ Ghislaine·4 w/ V.I.
Metropolitan Correctional Center
ORGANIZATION169 w/ Ghislaine·4 w/ V.I.
New Mexico
LOCATION124 w/ Ghislaine·3 w/ V.I.
New York City Police Department
ORGANIZATION106 w/ Ghislaine·3 w/ V.I.
New York Post
ORGANIZATION89 w/ Ghislaine·3 w/ V.I.
Lauderdale
LOCATION79 w/ Ghislaine·2 w/ V.I.