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te of New York. 6. Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the Estate of Jeffrey E. Epstein. 7. Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the Estate of Jeffrey E. Epstein. JURISDICTION AND VENUE 8. Plaintiff is domiciled in Califor
Page: EFTA00019102 →y E. Epstein. JURISDICTION AND VENUE 8. Plaintiff is domiciled in California. 9. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at the time of his death. As the legal representatives of the Estate of Jeffrey E. Epstein, Darren K. Indyke and Richard D. Kahn are deemed
Page: EFTA00019102 →en 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 article directs E
Page: EFTA00019105 →ROBATE NO. ST-19-PB- ACTION FOR TESTATE ADMINISTRATION PETITION FOR PROBATE AND FOR LETTERS TESTAMENTARY COME NOW Petitioners DARREN IC INDYKE and RICHARD D. KAHN, Executors of the Estate of Jeffrey E. Epstein, by and through KELLERHALS FERGUSON KROBLIN PLLC, and petition this Honorable Court to grant the ins
Page: EFTA00027979 →That Petitioners Darren K. Indyke and Richard D. Kahn ("Petitioners') are citizens of the United State
Page: EFTA00027979 →e of Death attached hereto.' 4) Decedent left certain assets in trust. 5) The Decedent died possessed of certain property within the Territory of the U.S. Virgin Islands and within the jurisdiction of the Court as herein described: The original death certificate, or a certified copy thereof, will be filed with
Page: EFTA00027979 →TES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x Plaintiff, Case No. 19 Civ. 10788 COMPLAINT -against- AND JURY DEMAND 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, Maro
Page: EFTA00025109 →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 VENUE 14. T
Page: EFTA00025111 →Epstein viciously exploited this power dynamic. In the summer and fall of 2002, he flew seventeen-year-old to his homes in New York, Florida, and the U.S. Virgin Islands, sexually assaulting her in each of those locations. 48. In or around December 2002, Epstein flew to stay at his townhouse 7 EFTA000251
Page: EFTA00025115 →Entities connected to both Richard Kahn and the U.S. Virgin

Jeffrey Epstein
PERSON
Marc Rich
PERSONDarren Indyke
PERSON
Lesley Groff
PERSON
Alfredo Rodriguez
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
George Mitchell
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
United States
LOCATION
U.S. Virgin Islands
LOCATION
Julie K. Brown
PERSON
Harry Reid
PERSON
New York City
LOCATION
Financial Trust Company
ORGANIZATION
Stephen Hawking
PERSONMartin Weinberg
PERSON
New York
LOCATION