Epstein Secrets

T 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 Hecker Wang LLP and

Indyke and Richard D. Kahn are the Executors of the Estate of Jeffrey E. Epstein (the "Estate"). As Executors of the Estate, Defendants Indyke and Kahn 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 citiz

Court may deem just and proper. Dated: New York, New York November 20, 2019 CUTI HECKER WANG LLP By: /s/ Mariann Meier Wang Mariann Meier Wang Daniel Mullkoff 305 Broadway, Suite 607 York 10007 ALLRED, MAROKO & GOLDBERG Gloria Allred 305 Broadway, Suite 607 York 10007 Attorneys for Plaintiff 19 E

W-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 by and through her

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

t 1 Filed 11/21/19 Page 13 of 13 Dated: New York, New York November 21, 2019 CUTI HECKER WANG LLP By: Is/ Mariann Meier Wang Mariann Meier Wang Daniel Mullkoff ALLRED, MAROKO & GOLDBERG Gloria Allred Attorneys for Plaintiff 13 EFTA00084156

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

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

t 1 Filed 11/21/19 Page 13 of 13 Dated: New York, New York November 21, 2019 CUTI HECKER WANG LLP By: Is/ Mariann Meier Wang Mariann Meier Wang Daniel Mullkoff 305 Broadway, Suite 607 New York, New York 10007 (212) 620-2603 [email protected] ALLRED, MAROKO & GOLDBERG Gloria Allred 305 Broadway, Suite 6