EPSTEIN
page 1 / 67 . OCR, unverified
Court Records Doe 17 v. Indyke, No. 119-
==================== DOCUMENT: Court Records__Doe 17 v. Indyke, No. 119-cv-09610 (S.D.N.Y. 2019)__001-01.txt ====================
METADATA_SOURCE: Court RecordsDoe 17 v. Indyke, No. 119-cv-09610 (S.D.N.Y. 2019)
METADATA_FILENAME: 001-01.pdf
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Case 1:19-cv-09610-PAE-DCF Document 1-1 Filed 10/17/19 Page 1 of 2
Exhibit A
Case 1:19-cv-09610-PAE-DCF Document 1-1 Filed 10/17/19 Page 2 of 2
T!it!lftt:JED DUCONilli411
US. v. Jeffrey Epstein, l 9-cr-490 (RMB)
-
ASSET SUMMARY - JUNE 30, 2019
6/30/19
Asset
Value
Cash
$
56,547.773
*
Fixed Income
$
14,304,679
*
Eauities
$
112,679,138
*
Hedae Funds & Private Equitv
$
194,986 301
**
Properties
***
East 71 st Street, New York, NY 10021
$
55,931,000
Zorro Ranch Road, Stanley New Mexico 87056
$
17,246,208
358 El Brillo Wav, Palm Beach, FL 33480
$
12,380,209
Avenue Foch, Paris France 75116
$
8,672,823
Great St James Island No. 6A USVI 00802 (oarcels A,B,C)
$
22,498,600
****
Little St James Island No. 68 USVI 00802 fnarcels A.B.Cl
$
63.874223
Total Assets
$
559,120,954
*
Values reflect i:iross numbers that are not net of tax
** All orooerties are valued at assessed values as per the most recent
propertv tax bills
*** Note the United States Attomev's office for the Southern District of New York
has stated that the value of this home is $77,000,000 as compared to the
market value shown above per the June 1. 2019 property tax bill
**** Note this property is valued at cost basis, however the assessment on
the most recent tax bill is $4,857,500
==================== END OF Court Records__Doe 17 v. Indyke, No. 119-cv-09610 (S.D.N.Y. 2019)__001-01.txt ====================
==================== DOCUMENT: Court Records__Doe 17 v. Indyke, No. 119-cv-09610 (S.D.N.Y. 2019)__001.txt ====================
METADATA_SOURCE: Court RecordsDoe 17 v. Indyke, No. 119-cv-09610 (S.D.N.Y. 2019)
METADATA_FILENAME: 001.pdf
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Page 1 of 34
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
CASE NO. __________________
JANE DOE 17,
Plaintiff,
v.
DARREN K. INDYKE AND
RICHARD D. KAHN, AS JOINT
PERSONAL REPRESENTATIVES OF
THE ESTATE OF JEFFREY E. EPSTEIN,
NINE EAST 71st STREET CORPORATION,
LAUREL, INC., FINANCIAL TRUST COMPANY,
INC., NES, LLC, MAPLE, INC., LSJE, LLC,
HBRK ASSOCIATES, INC., NAUTILUS, INC.,
CYPRESS, INC. and JEGE, INC.
Defendants.
______________________________________/
COMPLAINT
Plaintiff, JANE DOE 17, by and through the undersigned counsel, in support of her
claims against Defendants, alleges and states as follows:
1.
This action is brought, inter alia, pursuant to common law, statutory law and 18
U.S.C. §1591- §1595. Therefore, jurisdiction is proper under 28 U.S.C. §1331 and the damages
sought exceed the jurisdictional requirements of this Court.
2.
Plaintiff files this complaint under a pseudonym in order to protect her identity
because the Complaint makes allegations of a sensitive sexual nature the disclosure of which, in
association with her name, would cause further harm to her.
3.
Plaintiff is currently a resident and domiciled in the State of Florida and over the
age of 18.
Case 1:19-cv-09610-PAE-DCF Document 1 Filed 10/17/19 Page 1 of 34
Page 2 of 34
4.
At all times material, Jeffrey Epstein (“Epstein”) was a citizen of the United
States and resident of the U.S. Virgin Islands. Epstein was a man of extreme wealth who
frequently travelled between and regularly stayed in his numerous residences, including in New
York (within the Southern District of New York) at 9 East 71st Street, New York, NY 10021; in
Palm Beach, Florida at 358 El Brillo Way, Palm Beach, Florida 33480; in New Mexico at 49
Zorro Ranch Road, Stanley, New Mexico 87056, in Paris, France at 22 Avenue Foch, Paris,
France 75116, and in the United States Virgin Islands at Little St. James Island No. 6B USVI
00802.
5.
At all times material to this cause of action Epstein was an adult male born on
January 20, 1953, who died on August 10, 2019.
6.
Defendant, Darren K. Indyke and Richard D. Kahn as Joint Personal
Representatives of the Estate of Jeffrey E. Epstein (“Estate of Jeffrey E. Epstein”) was opened
and domiciled in the United States Virgin Islands, St. Thomas Division, and is the legal entity
responsible for intentional, criminal, or tortious conduct committed by Epstein as described in
this Complaint.
7.
At all times material hereto, Defendant Nine East 71st Street, Corporation (“Nine
East”), was a domestic business corporation conducting business in New York with its principal
place of business located at 575 Lexington Avenue, Fourth Floor, New York 10022.
8.
At all times material hereto, Defendant Laurel, Inc. (“Laurel”) was and is a U.S.
Virgin Islands corporation conducting business in multiple locations including New York and
Florida.
Case 1:19-cv-09610-PAE-DCF Document 1 Filed 10/17/19 Page 2 of 34