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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
rder in the criminal matter against him because it was required by law to do so after Epstein was deceased. On August 29, 2019, U.S. District Judge Richard Berman formally dismissed SDNY's indictment against Epstein, terminating the criminal action against him. C. 41. was born on parents divorced when she
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
rder in the criminal matter against him because it was required by law to do so after Epstein was deceased. On August 29, 2019, U.S. District Judge Richard Berman formally dismissed SDNY's indictment against Epstein, terminating the criminal action against him. Plaintiff's claims are therefore timely under N.
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
rder in the criminal matter against him because it was required by law to do so after Epstein was deceased. On August 29, 2019, U.S. District Judge Richard Berman formally dismissed SDNY's indictment against Epstein, terminating the criminal action against him. C. 41. was born on Ms parents divorced when
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
rder in the criminal matter against him because it was required by law to do so after Epstein was deceased. On August 29, 2019, U.S. District Judge Richard Berman formally dismissed SDNY's indictment against Epstein, terminating the criminal action against him. to the New York mansion. Maxwell told that thes
year, particularly since FCPA unit chief Daniel Kahn and two of his three assistant chiefs are slated
rs, is whether the investigations referenced in your letter will include the incident at MCC involving Mr. Epstein on or about July 23, 2019," Judge Richard Berman wrote in his response dated Aug. 12. "To my knowledge, it has never been definitively explained what the BOP concluded about that incident." The w
year, particularly since FCPA unit chief Daniel Kahn and two of his three assistant chiefs are slated
rs, is whether the investigations referenced in your letter will include the incident at MCC involving Mr. Epstein on or about July 23, 2019," Judge Richard Berman wrote in his response dated Aug. 12. "To my knowledge, it has never been definitively explained what the BOP concluded about that incident." The w
prince-and-the-epstein-scandal. 14 Ex. E, Mattie Kahn, 'This Is Not Our Shame': Five Survivors of Jeffr
lude photographs of Epstein and Maxwell l° Additionally, shortly after Jeffrey Epstein died in prison, stood up in open court before the Honorable Richard Berman to tell her story and to discuss Epstein's escape from punishment. told the court: For a very long time Jeffrey Epstein gamed the system at every
/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 →rder in the criminal matter against him because it was required by law to do so after Epstein was deceased. On August 29, 2019, U.S. District Judge Richard Berman formally dismissed SDNY's indictment against Epstein, terminating the criminal action against him. Plaintiff's claims are therefore timely under N.
Page: EFTA00023300 →Entities connected to both Richard Kahn and Richard Berman

Jeffrey Epstein
PERSON
Marc Rich
PERSONDarren Indyke
PERSON
Martha Stewart
PERSON
Alfredo Rodriguez
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
George Mitchell
PERSON
George W. Bush
PERSON
Teterboro
LOCATION
John F. Kennedy
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
Wilbur Ross
PERSON
Ehud Barak
PERSON
United States
LOCATION
Joe Biden
PERSON
U.S. Virgin Islands
LOCATION
Julie K. Brown
PERSON