EPSTEIN
page 3 / 43 . OCR, unverified
knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
solicited, threatened, forced, or coerced Plaintiff to engage in commercial sex acts.
30.
Such actions were undertaken knowing that Defendant Epstein’s use of force,
threats of force, fraud, coercion, and/or combinations of such means would be used, and were in
fact used, in order to cause Plaintiff to engage in commercial sex acts. In doing so, Defendant
violated 18 U.S.C. § 1591.
31.
Furthermore, Defendant attempted to violate 18 U.S.C. § 1591. In doing so,
violated U.S.C. § 1594(a).
32.
Defendant conspired with each member of the enterprise, and with other persons
known and unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated U.S.C. §
1594(a).
33.
By virtue of Defendant’s violations of 18 U.S.C. §§ 1591, 1593A, and 1594,
Defendant Darren K. Indyke and Richard D. Khan as Joint Personal Representatives of the Estate
of Jeffrey E. Epstein is subject to civil causes of action under 18 U.S.C. § 1595 by Plaintiff, who
Case 1:20-cv-02365 Document 1 Filed 03/17/20 Page 6 of 8
is a victim of the violations.
34.
Certain property of Defendant was essential to the commission of the federal
crimes and torts described herein, including the use of multiple private aircraft including a
Boeing aircraft (of make and model B-727-31H with a tail number N908JE) and a Gulfstream
aircraft (of make and model G-1159B with a tail number N909JE). Such aircraft, along with
other of Defendants’ property, were used as means and instruments of Defendants’ tortious and
criminal offenses and, as such, are subject to forfeiture.
35.
Additionally, Defendant’s mansion, located at 9 East 71st Street, New York, New
York, in the Southern District of New York, his Palm Beach residence and his private island
located in the United States Virgin Islands, and his ranch in New Mexico were among those used
as means and instruments of Defendants’ tortious and criminal offenses, and, as such, are subject
to forfeiture.
36.
As direct and proximate result of Defendant’s commission of the aforementioned
criminal offenses enumerated in 18 U.S.C. § 1591, 1593A, and 1594, and the associated civil
remedies provide in § 1595, Plaintiff has in the past suffered and will continue to suffer injury
and pain; emotional distress; psychological and psychiatric trauma; mental anguish; humiliation;
confusion; embarrassment; loss of self-esteem; loss of dignity; loss of enjoyment of life; invasion
of privacy; and other damages associated with actions. Plaintiff will incur further legal, medical
and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to
suffer from them in the future. In addition to these losses, Plaintiff has incurred attorneys’ fees
and will be required do so in the future.
37.
WHEREFORE, Plaintiff demands judgment against Defendants for compensatory
and general damages, attorneys’ fees, punitive damages and such other and further relief as this
Case 1:20-cv-02365 Document 1 Filed 03/17/20 Page 7 of 8
Court deems just proper. Plaintiff hereby demands trial by jury on all issues triable as of right by
a jury.
WHEREFORE, Plaintiff demands judgment against defendants as follows:
(i)
Assessing compensatory damages and punitive damages in an amount to be
determined at trial;
(ii)
Attorney’s fees and interest, and disbursements; and
(iii)
For such other relief as the Court deems just and proper.
Dated: New York, New York
March 17, 2020
KAISER SAURBORN & MAIR, P.C.
By: __________________________________
Daniel J. Kaiser, Esq.
William H. Kaiser, Esq.
Attorneys for Plaintiff
Broad Street, 37th Floor
New York, New York 10004
(212) 338-9100
Case 1:20-cv-02365 Document 1 Filed 03/17/20 Page 8 of 8
==================== END OF Court Records__Doe v. Indyke, No. 120-cv-02365 (S.D.N.Y. 2020)__001.txt ====================
==================== DOCUMENT: Court Records__Doe v. Indyke, No. 120-cv-02365 (S.D.N.Y. 2020)__002.txt ====================
METADATA_SOURCE: Court RecordsDoe v. Indyke, No. 120-cv-02365 (S.D.N.Y. 2020)
METADATA_FILENAME: 002.pdf
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AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v.
Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of