EPSTEIN
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Court Records Doe v. Indyke, No. 120-cv-
==================== DOCUMENT: Court Records__Doe v. Indyke, No. 120-cv-02365 (S.D.N.Y. 2020)__001.txt ====================
METADATA_SOURCE: Court RecordsDoe v. Indyke, No. 120-cv-02365 (S.D.N.Y. 2020)
METADATA_FILENAME: 001.pdf
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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JANE DOE,
Plaintiff,
-against-
COMPLAINT
DARREN K. INDYKE and RICHARD D. KAHN, in their
capacities as executors of the ESTATE OF JEFFREY E.
EPSTEIN;
Defendants.
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Plaintiff, Jane Doe, by her attorneys, Kaiser Saurborn & Mair, P.C., as and for her
complaint against the defendants, alleges as follows:
I.
BACKGROUND
1.
Jane Doe seeks justice for the sexual crimes perpetrated against her by Jeffrey
Epstein over the course of many years and for the abuse, manipulation and exploitation she
suffered at his hands. Epstein identified Jane Doe as an extremely emotionally vulnerable young
woman who, at the time she met him, had been entirely abandoned by her community, friends,
and family which enabled him to seduce her into his world of horrific abuse. Every aspect of her
life was controlled by Epstein. He dominated her psychologically. Jane Doe was constantly
emotionally bullied and coerced by Epstein, including being required to submit to his constant
sexual abuse. This lawsuit is about Jane Doe claiming her power, becoming a survivor, not a
victim, and getting restitution for the sexual crimes perpetuated against her. She has real
damages that are lasting: 1) She has permanent emotional injuries; 2) Her capacity to pursue a
professional career has been severely compromised; 3) Her name and reputation has been ruined;
Case 1:20-cv-02365 Document 1 Filed 03/17/20 Page 1 of 8
and 4) she is virtually bankrupt, having been forced to spend most of her resources defending
herself against false accusations, all of which stem from Epstein’s crimes.
2.
The Estate of Jeffrey E. Epstein, who perpetrated crimes of sexual abuse, sexual
assault and rape against Jane Doe, must be held responsible for ruining her life. It has been
nearly 19 years since Jane Doe was recruited by Jeffrey Epstein and Ghislaine Maxwell and
plunged into a world in which she was psychologically, physically and sexually exploited and
controlled for years.
3.
Jane Doe was a naïve and uniquely vulnerable 22-year old when Epstein and
Maxwell first preyed upon her.
II.
JURISDICTION
4.
This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1331 because
the claims asserted herein arise under 18 U.S.C. § 1591-1595.
5.
Venue is properly laid in this District pursuant to 28 U.S.C. § 1391 because it is a
District in which much of the alleged wrongdoing occurred.
III.
THE PARTIES
6.
Plaintiff is a sex trafficking victim of Epstein.
7.
At all times relevant herein, Jeffrey Edward Epstein (“Jeffrey Epstein” or
“Epstein”) maintained a residence and businesses at 9 East 71st Street, New York, NY 10021
(“Epstein’s NY Residence”) which was the location where Epstein committed repeated sexual
assaults of young women, like Plaintiff, and engaged in sex trafficking.
8.
At all times relevant herein, Epstein was an adult male over the age of 48, born on
Case 1:20-cv-02365 Document 1 Filed 03/17/20 Page 2 of 8
January 20, 1953, and who died on August 10, 2019. He continued to maintain a residence and
businesses at 9 East 71st Street, New York, NY 10021, and occupy it until his death.
9.
At all times relevant herein, Defendant, Darren K. Indyke, is named in his
personal capacity as an appointed executor of the Estate of Jeffrey E. Epstein (the “Estate of
Jeffrey E. Epstein”), which was opened and domiciled in the United States Virgin Islands, St.
Thomas Division, and is the legal entity responsible for intentional, criminal, and tortious
conduct committed by Jeffrey Epstein as described in this Complaint. The Estate of Jeffrey E.
Epstein includes Epstein’s NY Residence, which was occupied by Jeffrey Epstein and his
businesses until his death and was one of the locations where repeated acts of sexual abuse and
sex trafficking against various women, including plaintiff, occurred.
10.
At all times relevant herein, Defendant, Richard D. Kahn, is named in his
personal capacity as an appointed executor of the Estate of Jeffrey E. Epstein (the “Estate of
Jeffrey E. Epstein”).
11.
At all times relevant herein, Defendant, Darren K. Indyke, is named in his
personal capacity as an appointed executor of the Estate of Jeffrey E. Epstein (the “Estate of
Jeffrey E. Epstein”).
12.
At all times relevant herein, Jeffrey Epstein (legally represented now through
Darren K. Indyke and Richard D. Kahn as Executors of the Estate of Jeffrey E. Epstein (and