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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 COMPLAINT EFTA00103496 Ca
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. 12 EFTA00103507 Case 1:19-cv-08673 D
he 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 Judge Carolyn P. Hermon-Percell of the Superior Court of the Virgin Islands ordered that Epstein's will be admitted to probate and authorized Mr. Indyke and Mr. Kahn to administer
U.S. Virgin Islands Re: Estate of Jeffrey E. Epstein Probate No. ST-19-PB-80 Dear Magistrate Percell: We write on behalf of Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate'), to follow up on our letter to Your Honor dated August 14, 2020. In that letter
rite on behalf of Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Eps
g, 9053 Estate Thomas, Suite 101, St. Thomas, V.I. 00802 Telephone I 1.888.316.9269 Fax I www.kellfer.com September 9, 2020 By E-Filing Honorable Carolyn P. Hermon-Percell Superior Court of the U.S. Virgin Islands Magistrate Division Barbell Plaza South St. Thomas, U.S. Virgin Islands Re: Estate of Jeffrey E. Epst
March 23, 2022 to a five year term as the Commissioner to Casino Control.] During the investigation into the EPSTEIN estate it was discovered that Richard Kahn (KAHN) and Darren Indyke (INDYKE) were participants in the human trafficking operation. INDYKE was in charge of coordinating female to female marri
to a five year term as the Commissioner to Casino Control.] During the investigation into the EPSTEIN estate it was discovered that Richard Kahn (KAHN) and Darren Indyke (INDYKE) were participants in the human trafficking operation. INDYKE was in charge of coordinating female to female marriages t
CICO against the EPSTEIN estate. Approximately a few days after EPSTEIN died KELLERHALS filed a probate petition in Superior Court USVI with Judge Carolyn P. Hermon-Percell (PERCELL). Agent Note: [PERCELL was appointed by BRYAN on March 23, 2022 to a five year term as the Commissioner to Casino Control.] During the in
1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SOUTHERN DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defendants. Case No. COMPLAINT FOR DAMA
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
irgin Islands, confirming that he and Defendant Richard D. Kahn arc the two Trustees of The 1953 Trust. 32. On September 6, 2019, Magistrate Judge Carolyn P. Hermon-Percell of the Superior Court of the Virgin Islands ordered that Epstein's will be admitted to probate and authorized Mr. Indyke and Mr. Kahn to administer
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 →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 →irgin Islands, confirming that he and Defendant Richard D. Kahn are the two Trustees of The 1953 Trust. 32. On September 6, 2019, Magistrate Judge Carolyn P. Hermon-Percell of the Superior Court of the Virgin Islands ordered that Epstein's will be admitted to probate and authorized Mr. Indyke and Mr. Kahn to administer
Page: EFTA00019106 →SHMENT OF A VOLUNTARY CLAIMS RESOLUTION PROGRAM COME NOW the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorable Court for an expedited order to establish an independent and voluntary claims resolution program (the "Program") for purpo
Page: EFTA00018905 →opy of this Order shall be directed to counsel of record. Dated: ATTEST: ESTRELLA H. GEORGE Clerk of the Court BY: Court Clerk Supervisor / / CAROLYN P. HERMON-PERCELL Magistrate Judge of the Superior Court of the Virgin Islands EFTA00018917
Page: EFTA00018917 →Entities connected to both Richard Kahn and Carolyn P. Hermon-Percell

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSONErika Kellerhals
PERSON
United States
LOCATION
U.S. Virgin Islands
LOCATION
New York
LOCATIONJane Doe
PERSON
Michigan
LOCATIONthe Southern District
LOCATIONU.S. Virgin
LOCATIONthe State of New York
LOCATIONRoyal Palms Professional Building
ORGANIZATIONthe Superior Court of the Virgin Islands
ORGANIZATIONthe Superior Court
ORGANIZATIONthe New York Penal Law
ORGANIZATIONDistrict Court for the Southern District of New York
ORGANIZATIONInterlochen Arts Camp
ORGANIZATIONN.Y. P.L.
ORGANIZATION