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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
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
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
would constitute sexual 10 EFTA00084153 Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 11 of 13 offenses as defined in Article 130 of the New York Penal Law, and such acts and/or omissions were committed against when she was less than eighteen years of age. 70. Epstein's conduct constitutes "childhood
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
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
ill indicated that it was executed by Epstein on August 8, 2019 at the Metropolitan Correctional Center. The Will was accompanied by affidavits 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 fil
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. 30. The Will's first arti
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
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
Entities connected to both Darren Indyke and the New York Penal Law

Jeffrey Epstein
PERSON
Richard Kahn
PERSON
Ghislaine Maxwell
PERSON
U.S. Virgin Islands
LOCATION
United States
LOCATION
New York
LOCATIONJane Doe
PERSONthe State of New York
LOCATION
New York State
LOCATIONU.S. Virgin
LOCATIONthe Superior Court of the Virgin Islands
ORGANIZATION
Gloria Allred
PERSONthe Superior Court
ORGANIZATIONCarolyn P. Hermon-Percell
PERSONCuti Hecker Wang LLP
ORGANIZATIONDaniel Mullkoff
PERSONMAROKO & GOLDBERG
ORGANIZATIONN.Y. P.L.
ORGANIZATIONWANG LLP
PERSONCUTI HECKER
ORGANIZATION