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Court Records Maxwell v. Estate of Jeffr
==================== DOCUMENT: Court Records__Maxwell v. Estate of Jeffrey Epstein, No. ST-20-CV-155 (V.I. Super. Ct. 2020)__2020.03.12 Civil Complaint.txt ====================
METADATA_SOURCE: Court RecordsMaxwell v. Estate of Jeffrey Epstein, No. ST-20-CV-155 (V.I. Super. Ct. 2020)
METADATA_FILENAME: 2020.03.12 Civil Complaint.pdf
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.I
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS AND ST. JOHN
CIVIL CASE NO.: ~
... ;t)_.cv'-/56
GHISLAINE MAXWELL,
Plaintiff,
vs.
ESTATE OF JEFFREY E. EPSTEIN, DARREN
K. INDYKE, in his capacity as EXECUTOR OF
TH E ESTATE OF JEFFREY E. EPSTEIN,
RICHARD
D. KAHN,
in
his capacity as
EXECUTOR OF TH E ESTATE OF JEFFREY E.
EPSTEI , and NES, LLC, a New York Limited
Liability Company.
Defendants.
COMPLAI NT
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Plaintiff GHISLAINE MAXWELL ("Maxwell"), through her undersigned attorneys. by
\·a) of her Complaint against Delendants ESTA/ f::, OF JU FREY I~. LPSTEIN (the "Estate").
DARRFN K. INDYKE. in his capacity as Executor of the [STA.I [ 01· Jf-.l·FREY E. EPSTEIN
("lndyke"). RICHARD D. KAHN, in his capacity as Executor of the 1-.S1 ATE-: OF JEFFREY E.
EPS f'U N ("Kahn'"), and NES. LLC, a New York Lim ited Liabilit) Company ( .. NES, LLC"),
alleges as follows:
NATURE OF THIS ACTION
l.
This is an action for indemnification for and advancement of the attorneys· fees.
security costs, costs to find safe accommodation, and all other expenses Maxwell has reasonably
incurred and ,viii incur by reason of her prior employment relationship with Jeffrey E. Epstein
(''Epstein") and his affiliated businesses in connection with any threatened, pending, or completed
CIVIL CASE NO.: __
_
Page 2 of JO
suit, proceeding, or investigation relating to Epstein, his affiliated businesses, and his alleged
victims.
PARTIES AND JURISDICTION
2.
Plaintiff Ghislaine Maxwell is an adult citizen of the United States.
3.
Jeffrey E. Epstein was a resident of the Virgin Islands. The Estate of Jeffrey E.
Epstein was created following Epstein's death and is domiciled in the Virgin Islands.
4.
Defendant Darren K. lndyke is an Executor of the 'Estate.
5.
Defendant Richard D. Kahn is an Executor of the Estate.
6.
Defendant NES, LLC. is a limited liability company organized under the laws of the
State of New York on or about August 13. 1998.
7.
This Court has jurisdiction over thi'i matter pursuant to 4 V.I.C. * 76.
8.
Pursuant to 4 V.1.C. § 78, v1:nue properl) lie:. in the United States Virgin Islands. and
in the Division of St. Thomas and St. John.
FACTUAL ALLF.GATJO~S
9.
From approximately l 999 through at least 2006. ilaxwcl was employed by Ep:.tcin
indi'iclually. and by several of his affiliated busines~e.,. including. but not limited to. the C.O.U.Q.
F0t111dation. NES LLC. New York Strategy Group. JEGE LLC. JEGE Inc .. and LSJ. LLC.
10.
While under Epstein's employ. tlaxwell \as responsible for managing Epstein·s
properties. including properties located in New York. Paris, Florida. New Mexico. and the U.S.
Virgin Islands.
11.
During the course of their relationship, including while Maxwell was in Epstein's
employ, Epstein promised Maxwell that he would support her financially.
CIVIL CASE NO.: -----
Page 3 of IO
12.
Epstein made these promises to Maxwell repeatedly, both in writing and in
conversation.
13.
Epstein restated these promises when Maxwell was in the process of leaving
Epstein's employ to start a new business of her own.
14.
Epstein assured Maxwell that even if her business ventures failed he would support
her financially.
15.
In approximately 200 I. Maxwell began transitioning to a more limited employment
role for Epstein and his affiliated businesses.
In approximately 2004, Maxwell received a
typewritten letter from Epstein with a handwritten note asking Maxwell to remain in Epstein's
employ and pro111ising that no matter what Maxwell chose to do, Epstein would always support
Maxwell financially.
16.
Sometime thereaf'ter. Epstein pleaded guilty in a I· lorida stme proceeding to ,1 d ony
charge of ~olicit,Hi,ln ofpro~titution invoh·ing a rni1Hir.
17.
Since the lime of Cpstein'~ FloriJa ,tale proceeJing to the present. l'vlaxwcll ha~
incurred legal fees and expenses in 1.:on11ection with various suits, proceedings. and invcstigatiom
relating to Epstein, hi~ affiliated busincs::.<:s. and his alleged victims.
18.
Consistent with his repeated promises, Epstein indemnified !'vlaxwell and advanced
lt:gal fees and settlement costs when they \ ere incurred in connection with a lawsuit ti led by Sarah
Ransome against Epstein in 201 7 (Jone Doe .:/3 v. E'pstein. et al .. 17-cv-00616-JGK).
19.
Consistent with his repeated promises, Epstein also paid Maxwell's legal bills
incurred in connection with a civil suit tiled by Virginia Roberts against Epstein in 2009.