Epstein Secrets

hat in the course of your Office's criminal investigation and prosecution of Epstein's sex trafficking conspiracy, as described in the indictment in United States of America v. Jeffrey Epstein, 19-cr-490-RMB (the "Indictment"), your office collected 1. Jane Doe's identity is known by the prosecutors who represented the G

th the investigation, recounting Epstein's abuse in painstaking detail over the course of many meetings. 62. In July 2019, Epstein was indicted by the Unites States Attorney's Office for the Southern District of New York, based in large part on information provided by Plaintiff. Indeed, upon information and bel

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

d on her when she was a child, which irreparably scarred her for life. PARTIES 17. Plaintiff Mary Doe is an individual who resides in the western United States. 18. Defendants Darren K. Indyke and Richard D. Kahn are the Executors of the Estate of Jeffrey E. Epstein (the "Estate"). As Executors of the Est

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

trated against her by them cause her immeasurable pain and suffering every day. Enstein's Death and Will 26. In July 2019, Epstein was indicted by the Unites States Attorney's Office for the Southern District of New York. 27. On August 10, 2019, Epstein was found dead in his jail cell at the Metropolitan Corr

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