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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x MARY DOE, Case No. 19 Civ. 10758 Plaintiff, COMPLAINT -against- AND JURY DEMAND DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, and Defendants. x Plaintiff Mary Doe', by and through her attorneys, Cuti
COMPLAINT -against- AND JURY DEMAND DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE ESTATE
laintiff, COMPLAINT -against- AND JURY DEMAND DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE
laintiff, COMPLAINT -against- AND JURY DEMAND DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE
DYKE and RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, and Defendants. x Plaintiff Mary Doe', by and through her attorneys, Cuti Hecker Wang LLP and Allred, Maroko & Goldberg, for her Complaint alleges as follows: NATURE OF THE ACTION 1. Beginning when Plaintiff Mary Doe was sixteen years
Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, -against- DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, Defendants. Case No. 19 Civ. 10788 COMPLAINT AND JURY DEMAND Plaintiff
RICT OF NEW YORK Plaintiff, -against- DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE ESTATE
THERN DISTRICT OF NEW YORK Plaintiff, -against- DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE
THERN DISTRICT OF NEW YORK Plaintiff, -against- DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE
TORS OF THE ESTATE OF JEFFREY E. EPSTEIN, Defendants. Case No. 19 Civ. 10788 COMPLAINT AND JURY DEMAND Plaintiff by and through her attorneys, Cuti Hecker Wang LLP and Allred, Maroko & Goldberg, for her Complaint alleges as follows: NATURE OF THE ACTION EFTA00084144 Case 1:19-cv-10788-GHW-DCF Document 1 Fil
iv. 10788 COMPLAINT -against- AND JURY DEMAND DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE
Page: EFTA00025109 →DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, Defendants. x Plaintiff by and through her attorneys, Cuti Hecker Wang LLP and Allred, Maroko & Goldberg, for her Complaint alleges as follows: NATURE OF THE ACTION 1. When Plaintiff was just seventeen years old, living
Page: EFTA00025109 →the egregious abuse that Epstein inflicted when she was a child. PARTIES 12. Plaintiff is an individual who resides in Arizona. 13. Defendants Darren K. Indyke and Richard D. Kahn are the Executors of the Estate of Jeffrey E. Epstein (the "Estate"). As Executors of the Estate, Defendants are liable for the
Page: EFTA00025111 →s Executors of the Estate, Defendants are liable for the acts and omissions of Epstein and his agents. For purposes of 28 U.S.C. § 1332, Defendants Indyke and Kahn are deemed to be citizens of the United States Virgin Islands, where Epstein was domiciled at the time of his death. JURISDICTION AND VENU
Page: EFTA00025111 →Entities connected to both Darren Indyke and Cuti Hecker Wang LLP

Jeffrey Epstein
PERSON
Richard Kahn
PERSON
New York
LOCATION
New York State
LOCATION
Gloria Allred
PERSONDaniel Mullkoff
PERSONthe New York Penal Law
ORGANIZATIONMAROKO & GOLDBERG
ORGANIZATIONCUTI HECKER
ORGANIZATIONWANG LLP
PERSONMariann Meier Wang
PERSON