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Case 1:20-cv-02365 Document 1 Filed 03/17/20 Page 1 of 8

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:

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;

1
Case 1:20-cv-02365 Document 1 Filed 03/17/20

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