EPSTEIN
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Court Records Bryant v. Indyke, No. 119-
==================== DOCUMENT: Court Records__Bryant v. Indyke, No. 119-cv-10479 (S.D.N.Y. 2019)__001.txt ====================
METADATA_SOURCE: Court RecordsBryant v. Indyke, No. 119-cv-10479 (S.D.N.Y. 2019)
METADATA_FILENAME: 001.pdf
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UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
JULIETTE BRYANT,
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
Case 1:19-cv-10479-ALC-DCF Document 1 Filed 11/14/19 Page 1 of 16
Plaintiff Juliette Bryant, 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 status and upon information and belief and to all other matters as follows:
NATURE OF THE ACTION
1.
This suit arises out of Jeffrey Epstein’s sexual abuse of Plaintiff beginning when Plaintiff
was 20 years old that lasted years and included trafficking Plaintiff to each of his homes in the
United States and Paris.
2.
Plaintiff was a young girl living in South Africa with hopes of becoming a model when
she was approached by one of Epstein’s recruiters about a prospective modeling opportunity in
the United States and invited to a restaurant to meet Epstein, who was dining with a former high
U.S. Government official, a famous actor, and a well-known comedian. What appeared on the
outside as a legitimate opportunity to break into the modeling business in the United States
turned into years of horrific abuse and manipulation at the hands of Jeffrey Epstein.
3.
Epstein’s trafficking scheme involved recruiting young females by making false promises
and using his wealth, power and threats to intimidate the females into submission to his
demands. This same pattern was repeated numerous times with numerous young women.
4.
As United States District Judge Kenneth Marra found, “From between about 1999 and
2007, Jeffrey Epstein sexually abused more than 30 minor girls . . . at his mansion in Palm Beach
Florida, and elsewhere in the United States and overseas. . . . In addition to his own sexual abuse
of the victims, Epstein directed other persons to abuse the girls sexually. Epstein used paid
employees to find and bring minor girls to him. Epstein worked in concert with others to obtain
Case 1:19-cv-10479-ALC-DCF Document 1 Filed 11/14/19 Page 2 of 16
minors not only for his own sexual gratification, but also for the sexual gratification of others.”
Doe 1 v. United States, 359 F. Supp. 3d 1201, 1204 (S.D. Fla. 2019) (internal citations omitted).
5.
Epstein organized this sex trafficking network to obtain hundreds of young females for
himself for sex, and also lent these females out to other powerful and wealthy individuals to be
sexually abused.
6.
Epstein conspired with others and hired staff to maintain and keep secret this network of
sexual abuse for years, which sprawled throughout Epstein’s residences in New York, Florida,
New Mexico, the United States Virgin Islands, and Paris. Epstein’s preference was to have three
different young females a day for his sexual pleasure.
7.
Despite his significant criminal activity, in 2008 Epstein received a shockingly minimal
charge, pleading guilty to a single Florida state law charge of procuring a minor for prostitution
and a non-prosecution agreement (a “NPA”) with the U.S. Attorney for the Southern District of
Florida. Unknown to the public and the victims at the time, Epstein’s lawyers were pressuring
the Government to commit to the NPA without informing the victims. Epstein’s multiple
victims were kept in the dark and told to be “patient” while Epstein’s lawyers worked to protect
him and other potential co-conspirators from prosecution. Epstein served one year in jail, but
was afforded the privilege of being able to leave the jail to go to work for twelve hours per day,
six days per week.
8.
The NPA allowed Epstein to escape proportionate punishment for his actions and to
continue operating his sex trafficking enterprise with liberty.
9.
A few years later, Epstein flippantly referred to his sexual abuse of multiple minors, and
the slap on the wrist he had received for it, in a 2011 interview with the New York Post:
“Billionaire pervert Jeffrey Epstein is back in New York City – and making wisecracks about his
Case 1:19-cv-10479-ALC-DCF Document 1 Filed 11/14/19 Page 3 of 16
just-ended jail stint for having sex with an underage girl. ‘I am not a sexual predator, I’m an
offender,’ the financier told The Post yesterday. ‘It’s the difference between a murderer and a
person who steals a bagel,’ said Epstein.” Amber Sutherland, Billionaire Jeffrey Epstein: I’m a