EPSTEIN
page 5 / 67 . OCR, unverified
in 1953, who died on August 10, 2019.
6.
Defendant, Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate
of Jeffrey E. Epstein (“Estate of Jeffrey E. Epstein”) the 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 Jeffrey Epstein as described
in this Complaint.
7.
A substantial part of the acts, events, and omissions giving rise to this cause of
action occurred in the Southern District of New York; venue is proper in this District. 28 U.S.C.
section 1391(b)(2).
8.
At all times material to this cause of action, Jeffrey Epstein (legally represented
now through Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate of Jeffrey E.
Epstein (and referred to herein as “Estate of Jeffrey E. Epstein”) owed a duty to Plaintiff to treat
her in a non-negligent manner and not to commit, or conspire to commit, or cause to be committed
intentional, criminal, fraudulent, or tortious acts against Plaintiff, including any acts that would
cause Plaintiff to be harmed through conduct committed against her in violation of New York
Penal Law section 214-G, New York Penal Law section 130.20; or New York Penal Law 130.25;
or New York Penal Law 130.35; or New York Penal Law 130.40; or New York Penal Law 130.52;
or New York Penal Law 130.66.
FACTUAL ALLEGATIONS
9.
At all times material to this cause of action, Jeffrey Epstein was an adult male over
years old. Epstein was tremendously wealthy, widely recognized as a billionaire, who used his
wealth, power, resources, and connections to commit illegal sexual crimes in violation of federal
Case 1:19-cv-11869-MKV-DCF Document 1 Filed 12/27/19 Page 2 of 14
and state statutes and to employ and conspire with other individuals and corporate entities to assist
him in committing those crimes or torts or to facilitate or enable those acts to occur.
10.
Epstein displayed his enormous wealth, power, and influence to his employees; to
the employees of the corporate or company entities who worked at his direction; to the victims
procured for sexual purposes; and to the public, in order to advance and carry out and conceal his
crimes and torts.
11.
The allegations herein primarily concern Jeffrey Epstein’s conduct while at his
townhouse in New York.
12.
Epstein had a compulsive sexual preference for young females as young as 14 years
old.
13.
Epstein enjoyed sexual contact with young females, including minor children, and
took pleasure corrupting vulnerable young females, including minor children, into engaging in
sexual acts with him.
14.
Epstein directed a complex system of individuals, including employees and
associates of entities, to work in concert and at his direction, for the purpose of harming teenage
girls through sexual exploitation.
15.
On July 2, 2019, the United States Attorney’s Office for the Southern District of
New York filed a Sealed Two Count Indictment inclusive of One Count of Sex Trafficking
Conspiracy and One Count of Sex Trafficking, in part due to Epstein’s criminal activities against
children in the New York Mansion located at 9 East 71st Street.
16.
On July 8, 2019, Jeffrey Epstein was arrested pursuant to the aforementioned
Indictment, which is attached hereto as Exhibit A.
Case 1:19-cv-11869-MKV-DCF Document 1 Filed 12/27/19 Page 3 of 14
17.
The Indictment stated in part, and Plaintiff herein adopts as true, that “from at least
in or about 2002, up to and including at least in or about 2005, Jeffrey Epstein, the defendant,
enticed and recruited, and caused to be enticed and recruited, minor girls to visit his mansion in
Manhattan, New York (the “New York Residence”) and his estate in Palm Beach, Florida (the
“Palm Beach Residence”) to engage in sex acts with him, after which the victims were given
hundreds of dollars in cash.” Criminal Indictment at 1.
18.
“Moreover, and in order to maintain and increase his supply of victims, Epstein
also paid certain of his victims to recruit additional girls to be similarly abused by EPSTEIN. In
this way, EPSTEIN created a vast network of underage victims for him to sexually exploit in
locations including New York and Palm Beach.” Criminal Indictment at 1-2.
19.
“The victims described herein were as young as 14 years old at the time they were
abused by Jeffrey Epstein, and were, for various reasons, often particularly vulnerable to
exploitation. Epstein intentionally sought out minors and knew that many of his victims were in
fact under the age of 18, including because, in some instances, minor victims expressly told him
their age.” Criminal Indictment at 2.
20.
“In creating and maintaining this network of minor victims in multiple states to
sexually abuse and exploit, JEFFREY EPSTEIN, … worked and conspired with others, including