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-10475-LGS-DCF Document 1 Filed 11/12/19 Page 1 of 19 UNITED STATES DISTRICT COURT FOR THE SOUTHERN 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
OF NEW YORK Plaintiff, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the
N DISTRICT OF NEW YORK Plaintiff, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities
N DISTRICT OF NEW YORK Plaintiff, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities
ead in his cell at the Metropolitan Correctional Center on August 10, 2019. 36. Epstein's last will and testament was filed on August 15, 2019, in the Probate Division of the Superior Court of the Virgin Islands. 37. Darren K. Indyke and Richard D. Kahn filed a Certificate of Trust in the Superior Court of the V
ocument 1 Filed 11/14/19 Page 1 of 14 UNITED STATES DISTRICT COURT FOR 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 C
NE DOE 1000, Plaintiff, CASE NO: v. DARREN K. INDYKE and in their capacities as the execuorl. ESTATE
W YORK JANE DOE 1000, Plaintiff, CASE NO: v. DARREN K. INDYKE and in their capacities as the execuorl.
W YORK JANE DOE 1000, Plaintiff, CASE NO: v. DARREN K. INDYKE and in their capacities as the execuorl.
ead in his cell at the Metropolitan Correctional Center on August 10, 2019. 32. Epstein's last will and testament was filed on August 15, 2019, in the Probate Division of the Superior Court of the Virgin Islands. 33. Darren K. Indyke and Richard D. Kahn filed a Certificate of Trust in the Superior Court of the V
9-cv-10475-LGS Document 1 Filed 11/12/19 Page 1 of 19 UNITED STATES DISTRICT COURT FOR THE SOUTHERN 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
OF NEW YORK Plaintiff, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the
N DISTRICT OF NEW YORK Plaintiff, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities
N DISTRICT OF NEW YORK Plaintiff, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities
ead in his cell at the Metropolitan Correctional Center on August 10, 2019. 36. Epstein's last will and testament was filed on August 15, 2019, in the Probate Division of the Superior Court of the Virgin Islands. 37. Darren K. Indyke and Richard D. Kahn filed a Certificate of Trust in the Superior Court of the V
-10475-LGS-DCF Document 1 Filed 11/12/19 Page 1 of 19 UNITED STATES DISTRICT COURT FOR THE SOUTHERN 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
T OF NEW YORK Plaintiff CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, i in their capacities as the
RN DISTRICT OF NEW YORK Plaintiff CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, i in their capacitie
RN DISTRICT OF NEW YORK Plaintiff CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, i in their capacities
ead in his cell at the Metropolitan Correctional Center on August 10, 2019. 36. Epstein's last will and testament was filed on August 15, 2019, in the Probate Division of the Superior Court of the Virgin Islands. 37. Darren K. Indykc and Richard D. Kahn filed a Certificate of Trust in the Superior Court of the V
f 55 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, PLAINTIFF, DARREN K. INDYKE, in his capacity as the EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN and ADMINISTRATOR OF THE 1953 TRUST; RICHARD D. KAHN, in his capacity as th
Page: EFTA00018779 →F THE UNITED STATES VIRGIN ISLANDS, PLAINTIFF, DARREN K. INDYKE, in his capacity as the EXECUTOR FOR THE
Page: EFTA00018779 →on by VIDOJ. 7. Epstein was found dead on August 10, 2019 while in custody in New York for sex crimes. 8. Defendant Darren K. Indyke ("Defendant Indyke") is co-executor of the Estate of Jeffrey E. Epstein and Administrator of The 1953 Trust. 9. Defendant Richard D. Kahn ("Defendant Kahn") is co-ex
Page: EFTA00018780 →in GVI's First Amended Complaint Page 3 of 55 Petition for Probate and Letters Testamentary which included Epstein's last will and testament with the Probate Division of the Superior Court of the Virgin Islands. 11. The Petition reports the value of the real and personal property in The Estate located in the Vir
Page: EFTA00018781 →ocument 1 Filed 11/14/19 Page 1 of 14 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK JANE DOE 1000, Plaintiff, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, Defendants. COMPLAINT BOIES SCHILLER FLEXNER
Page: EFTA00023292 →W YORK JANE DOE 1000, Plaintiff, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities
Page: EFTA00023292 →for her Complaint against Defendants, Darren K. Indyke and Richard D. Kahn in their capacities as the ex
Page: EFTA00023293 →ead in his cell at the Metropolitan Correctional Center on August 10, 2019. 32. Epstein's last will and testament was filed on August 15, 2019, in the Probate Division of the Superior Court of the Virgin Islands. 33. Darren K. Indyke and Richard D. Kahn filed a Certificate of Trust in the Superior Court of the V
Page: EFTA00023299 →Entities connected to both Darren Indyke and the Probate Division

Jeffrey Epstein
PERSON
Richard Kahn
PERSON
Martha Stewart
PERSON
Ghislaine Maxwell
PERSON
U.S. Virgin Islands
LOCATION
Jes Staley
PERSON
New York
LOCATION
Les Wexner
PERSONJane Doe
PERSON
Palm Beach
LOCATION
David Boies
PERSON
Kenneth Marra
PERSON
Alaska
LOCATION
Edward Jay Epstein
PERSONSuperior Court
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATIONSigrid McCawley
PERSON
United Kingdom
LOCATION
Southern District of New York
ORGANIZATION
Lauderdale
LOCATION