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Case 1:19-cv-11869-MKV-DCF Document 1 Filed 12/27/19 Page 1 of 14

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

ANASTASIA DOE,

Plaintiff, CASE NO.:

vs.

DARREN K. INDYKE AND RICHARD D.
KAHN AS CO-EXECUTORS OF THE
ESTATE OF JEFFREY E. EPSTEIN

Defendant.
___________________________________/

COMPLAINT

Plaintiff, ANASTASIA DOE, by and through her undersigned counsel, for her claims

against Defendant, Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of

Jeffrey E. Epstein, states and alleges as follows:

1. The controversy in this cause of action exceeds the sum or value of $75,000,

exclusive of interest and costs, and is between citizens of different States. Therefore, jurisdiction

is proper under 28 U.S.C. section 1332.

2. Plaintiff who was born in 1989 and files this Complaint under a pseudonym in order

to protect her identity because this Complaint makes allegations of a sensitive sexual nature the

disclosure of which, in association with her name, would cause further harm to her.

3. Plaintiff is currently a resident of and domiciled in the state of New York.

4. At all times material to this cause of action, Jeffrey Epstein travelled between and

stayed regularly in multiple residences, including in New York, New York and the United States

Virgin Islands. He was a citizen of the United States and a resident of the U.S. Virgin Islands.

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Case 1:19-cv-11869-MKV-DCF Document 1 Filed 12/27/19 Page 2 of 14

5. At all times material to this cause of action Jeffrey Epstein was an adult male born

in 1953, who died on August 10, 2019.

6. Defendant, Darren K. Indyke and Richard D.

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