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Case 1:19-cv-10479-ALC-DCF Document 1 Filed 11/14/19 Page 1 of 16

UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK

JULIETTE BRYANT,

Plaintiff, CASE NO:

DARREN K. INDYKE and RICHARD D. KAHN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,

Defendants.

_____________________________________

COMPLAINT

BOIES SCHILLER FLEXNER LLP

1
Case 1:19-cv-10479-ALC-DCF Document 1 Filed 11/14/19 Page 2 of 16

Plaintiff Juliette Bryant, by her attorneys Boies Schiller Flexner LLP, for her Complaint

against Defendants, Darren K. Indyke and Richard D. Kahn in their capacities as the executors of

the Estate of Jeffrey Edward Epstein (“Epstein”), avers upon personal knowledge as to her own

acts and status and upon information and belief and to all other matters as follows:

NATURE OF THE ACTION

1. This suit arises out of Jeffrey Epstein’s sexual abuse of Plaintiff beginning when Plaintiff

was 20 years old that lasted years and included trafficking Plaintiff to each of his homes in the

United States and Paris.

2. Plaintiff was a young girl living in South Africa with hopes of becoming a model when

she was approached by one of Epstein’s recruiters about a prospective modeling opportunity in

the United States and invited to a restaurant to meet Epstein, who was dining with a former high

U.S. Government official, a famous actor, and a well-known comedian. What appeared on the

outside as a legitimate opportunity to break into the modeling business in the United States

turned into years of horrific abuse and manipulation at the hands of Jeffrey Epstein.

3. Epstein’s trafficking scheme involved recruiting

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