EPSTEIN
page 2 / 155 . OCR, unverified
10.
In August 2018, just one year before his death, Epstein told a New York Times reporter
“that criminalizing sex with teenage girls was a cultural aberration and that at times in history it
was perfectly acceptable.” James B. Stewart, The Day Jeffrey Epstein Told Me He Had Dirt on
Powerful People, N.Y. Times (Aug. 12, 2019),
https://www.nytimes.com/2019/08/12/business/jeffrey-epstein-interview.html.
11.
When Plaintiff was a young woman, Epstein added her to his long list of victims by
committing sexual assault and battery against her. As such, Epstein is responsible for battery
and intentional infliction of emotional distress pursuant to New York common law. The damage
to Plaintiff has been severe and lasting.
12.
This action has been timely filed pursuant to N.Y. C.P.L.R. § 215(8)(a), which provides
that a plaintiff shall have at least one year from the termination of a criminal action against the
same defendant to commence an action with respect to the event or occurrence from which the
criminal action arose. A criminal action against Epstein with respect to the same sex trafficking
enterprise from which Plaintiff’s claims arise was terminated on August 29, 2019.
13.
This action has also been timely filed pursuant to N.Y. C.P.L.R. § 213-C, which provides
that a plaintiff shall have 20 years to file civil claims “for physical, psychological or other injury
or condition suffered by such person as a result of conduct which would constitute” certain sex
crimes under New York Penal Law Article 130. Epstein and Ghislaine Maxwell sexually
assaulted Plaintiff by forcible compulsion within 20 years of filing this Complaint, and that
sexual assault constitutes one or more sex crimes described in N.Y. C.P.L.R. § 213-C.
Case 1:19-cv-10577 Document 1 Filed 11/14/19 Page 4 of 14
14.
Any statute of limitations applicable to Plaintiff’s claims, if any, is tolled due to the
continuous and active deception, duress, threats of retaliation, and other forms of misconduct that
Epstein and his co-conspirators used to silence his many victims, including Plaintiff. Epstein’s
actions deprived Plaintiff of the opportunity to commence this lawsuit before his death. Until his
death, Plaintiff feared that Epstein and his co-conspirators would harm her or her family, or ruin
her life, if she came forward.
15.
Defendants are equitably estopped from asserting a statute of limitations defense.
Allowing Defendants to do so would be unjust. Epstein and his co-conspirators intimidated each
of his victims into silence by threatening their lives and their livelihoods. They therefore
prevented Plaintiff from commencing this lawsuit before his death. By using threats, along with
his wealth and power, Epstein was able to escape punishment for his intolerable and brutal
crimes against countless young women and underage girls for the duration of his life.
PARTIES
16.
Plaintiff Jane Doe 1000 is a citizen and resident of New Jersey.
17.
Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the Estate
of Jeffrey E. Epstein.
18.
Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the Estate
of Jeffrey E. Epstein.
JURISDICTION AND VENUE
19.
Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at
the time of his death. Jeffrey Epstein maintained a residence in the Southern District of New
York. As the legal representatives of the Estate of Jeffrey E. Epstein, Darren K. Indyke and
Richard D. Kahn are deemed citizens of the U.S. Virgin Islands.
Case 1:19-cv-10577 Document 1 Filed 11/14/19 Page 5 of 14
20.
The amount in controversy in this action exceeds the sum or value of $75,000.00
excluding interests and costs and is between citizens of different states. Accordingly, jurisdiction
is proper under 28 U.S.C. § 1332.
21.
Venue is proper in this Court as Epstein’s sexual abuse of Plaintiff began and occurred in
New York, New York, where he recruited her, physically molested her, and began grooming her
for sex in his organized sex trafficking ring.
22.
Many of the events giving rise to these causes of action occurred in the Southern District
of New York, where a substantial amount of Epstein’s property is located. Thus, venue in this
district is proper. 28 U.S.C. § 1391(b)(2).
FACTUAL ALLEGATIONS
A.
Epstein’s Sex Trafficking Enterprise
23.
Jeffrey Epstein was widely renowned as a billionaire who used his vast connections to
powerful individuals, and seemingly unlimited wealth and resources, to create a web of
transcontinental sex trafficking that served himself, his coconspirators, and some of the most
powerful people in the world.
24.
Epstein owned multiple residences and frequently travelled between them, including at 9
East 71st Street, New York, New York 10021, where the illegal sexual crimes against Plaintiff
occurred. Epstein conservatively valued his New York townhome at $55,931,000.00. Epstein