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Case 1:19-cv-10474 Document 1 Filed 11/12/19 Page 1 of 15
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
MARIA FARMER,
Plaintiff, CASE NO:
v.
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-10474 Document 1 Filed 11/12/19 Page 2 of 15
Plaintiff Maria Farmer, 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 Jeffery Epstein’s sexual assault of Plaintiff.
2. Maria Farmer was sexually trafficked by Epstein and a co-conspirator as part of his
organized ring of procuring young females for sex. As an aspiring artist, Maria believed that
Epstein’s connections to the art world would help further her career when he offered her a
position to procure art for him. Maria began working for Epstein in his Manhattan mansion,
performing a variety of tasks including procuring art and manning the guest check in at the front
door of the home. During the course of her employment for Epstein, Epstein and Ghislaine
Maxwell violently sexually assaulted Maria while she was working on an art project at Epstein’s
guest house on Les Wexner’s Ohio estate, and threatened to ruin her career and her life if she
told anyone about the assault.
3. Epstein’s tra
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