EPSTEIN
page 4 / 67 . OCR, unverified
24.
From at least in or about 2002, up to and
including in or about 2005, in the Southern District of New
York, JEFFREY EPSTEIN, the defendant, willfully and knowingly,
in and affecting interstate and foreign commerce, did recruit,
entice, harbor, transport, provide, and obtain by any means a
person, knowing that the person had not attained the age of 18
years and would be caused to engage in a commercial sex act, and
did aid and abet the same, to wit, EPSTEIN recruited, enticed,
harbored, transported, provided, and obtained numerous
Case 1:19-cv-11869-MKV-DCF Document 1-1 Filed 12/27/19 Page 13 of 15
individuals•who were less than 18 years old, including but not
limited to Minor Victim-1, as described above, and who were then
caused to engage in at least one commercial sex act in
Manhattan, New York.
(Title 18, United States Code, Sections 159l(a),
( b) ( 2 ) , and 2 . )
FORFEITURE ALLEGATIONS
25.
As a result of committing the offense alleged in
Count Two of this Indictment, JEFFREY EPSTEIN, the defendant,
shall forfeit to the United States, pursuant to Title 18, United
States Code, Section 1594(c) (1), any property, real and
personal, that was used or intended to be used to commit or to
facilitate the commission of the offense alleged in Count Two,
and any property, real or personal, constituting or derived from
any proceeds obtained, directly or indirectly, as a result of
the offense alleged in Count Two, or any property traceable to
such property, and the following specific property:
a.
The lot or parcel of land, together with its
buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 9 East 71st Street, New York, New
York, with block number 1386 and lot number 10, owned by
Maple, Inc.
Case 1:19-cv-11869-MKV-DCF Document 1-1 Filed 12/27/19 Page 14 of 15
Substitute Asset Provision
26.
If any of the above-described forfeitable
property, as a result of any act or omission of the defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a
third person;
(c) has been placed beyond the jurisdiction of the Court;
(d), has been substantially diminished in value; or
(e) has been commingled with other property which cannot
be subdivided without difficulty;
it is the intent of the United States, pursuant to 21 U.S.C.
§ 853(p) and 28 U.S.C. § 246l(c), to seek forfeiture of any
other property of the defendant up to the value of the above
forfeitable property.
(Title 18, United States Code, Section 1594; Title 21,
United States Code, Section 853(p); and
Title 28, United States Code, Section 2461.)
~d.~
GEOFFRY~ BERMAN
United States Attorney
Case 1:19-cv-11869-MKV-DCF Document 1-1 Filed 12/27/19 Page 15 of 15
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
v.
JEFFREY EPSTEIN,
Defendant.
'INDICTMENT
(18 U.S.C. §§ 371, 1591(a), (b) (2),
and 2)
GEOFFREY S. BERMAN
United States Attorney
I
1.:V.L C .t-1C.LUV.l.L
==================== END OF Court Records__Doe v. Indyke, No. 119-cv-11869 (S.D.N.Y. 2019)__001-01.txt ====================
==================== DOCUMENT: Court Records__Doe v. Indyke, No. 119-cv-11869 (S.D.N.Y. 2019)__001.txt ====================
METADATA_SOURCE: Court RecordsDoe v. Indyke, No. 119-cv-11869 (S.D.N.Y. 2019)
METADATA_FILENAME: 001.pdf
----------------------------------------
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ANASTASIA DOE,
Plaintiff,
CASE NO.:
vs.
DARREN K. INDYKE AND RICHARD D.
KAHN AS CO-EXECUTORS OF THE
ESTATE OF JEFFREY E. EPSTEIN
Defendant.
___________________________________/
COMPLAINT
Plaintiff, ANASTASIA DOE, by and through her undersigned counsel, for her claims
against Defendant, Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of
Jeffrey E. Epstein, states and alleges as follows:
1.
The controversy in this cause of action exceeds the sum or value of $75,000,
exclusive of interest and costs, and is between citizens of different States. Therefore, jurisdiction
is proper under 28 U.S.C. section 1332.
2.
Plaintiff who was born in 1989 and files this Complaint under a pseudonym in order
to protect her identity because this 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 of and domiciled in the state of New York.
4.
At all times material to this cause of action, Jeffrey Epstein travelled between and
stayed regularly in multiple residences, including in New York, New York and the United States
Virgin Islands. He was a citizen of the United States and a resident of the U.S. Virgin Islands.
Case 1:19-cv-11869-MKV-DCF Document 1 Filed 12/27/19 Page 1 of 14
5.
At all times material to this cause of action Jeffrey Epstein was an adult male born