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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
K. Indyke and Richard D. Kahn filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 38. Epstein's will was entered into
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.
K. Indyke and Richard D. Kahn filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 34. Epstein's will was entered into
Case 1:19-cv-08673 Document 1 Filed 09/18/19 Page 1 of 16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY E. EPSTEIN, Defendants. Case No. JURY TRIAL DEMANDED COMPLAI
avits from Darren K. Indyke and Richard D. Kahn attesting to their "Oath of Willingness to Serve as Executor and Appointment of Local Counsel." Mr. Indyke and Mr. Kahn also filed a Petition for Probate and for Letters Testamentary in the Superior Court of the Virgin Islands. 12 EFTA00103507 Case 1:
DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities
DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities
e of Trust with the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn are the two Trustees of The 1953 Trust. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 68. On September 6, 2019, Magistrate
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
K. Indyke and Richard D. Kahn filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 38. Epstein's will was entered into
-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
K. Indykc and Richard D. Kahn filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 38. Epstein's will was entered into
Entities connected to both Darren Indyke and See Certificate of Trust

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
Alaska
LOCATION
Kenneth Marra
PERSON
Edward Jay Epstein
PERSONSuperior Court
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATIONSigrid McCawley
PERSON
United Kingdom
LOCATION
Southern District of New York
ORGANIZATION
New Mexico
LOCATION