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nt 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 BOIES $CHILLER FLEX
f, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ES
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
14/19 Page 2 of 14 Plaintiff Jane Doe 1000, by her attorneys Boies Schiller Flexner LLP, for her Complaint against Defendants, Darren K. Indyke and Richard D. Kahn in their capacities as the executors of the Estate of Jeffrey Edward Epstein ("Epstein"), avers upon personal knowledge as to her own acts and stat
ainst Defendants, Darren K. Indyke and Richard D. Kahn in their capacities as the executors of the Esta
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
nt 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 BOIES $CHILLER FLEX
f, CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ES
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
nt 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 3514.011 Page 1 o
ff CASE NO: v. DARREN K. INDYKE and RICHARD D. KAHN, i in their capacities as the executors of the E
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
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 the EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN, and ADMINISTRATOR OF THE 1953 TRUST; ESTATE OF JEFFREY E. EPSTEIN, THE 195
Page: EFTA00018779 →efendant 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-executor of The Estate of Jeffrey E. Epstein and Administrator of The 1953 Trust. 10. Defendant, the Estate of Jeffrey E. Epstein ("Estate
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 →/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 LLP 1 EFTA00023292
Page: EFTA00023292 →ainst Defendants, Darren K. Indyke and Richard D. Kahn in their capacities as the executors of the Esta
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 Richard Kahn and the Probate Division

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Martha Stewart
PERSON
Ghislaine Maxwell
PERSON
U.S. Virgin Islands
LOCATION
Jes Staley
PERSON
New York
LOCATION
Les Wexner
PERSON
Palm Beach
LOCATION
Edward Jay Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
David Boies
PERSON
United Kingdom
LOCATIONSuperior Court
ORGANIZATION
Alaska
LOCATION
Southern District of New York
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATIONThe New York Post
ORGANIZATION
New York Post
ORGANIZATION