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Case 1:19-cv-09610-PAE-DCF Document 1 Filed 10/17/19 Page 1 of 34
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
CASE NO. __________________
JANE DOE 17,
Plaintiff,
v.
DARREN K. INDYKE AND
RICHARD D. KAHN, AS JOINT
PERSONAL REPRESENTATIVES OF
THE ESTATE OF JEFFREY E. EPSTEIN,
NINE EAST 71st STREET CORPORATION,
LAUREL, INC., FINANCIAL TRUST COMPANY,
INC., NES, LLC, MAPLE, INC., LSJE, LLC,
HBRK ASSOCIATES, INC., NAUTILUS, INC.,
CYPRESS, INC. and JEGE, INC.
Defendants.
______________________________________/
COMPLAINT
Plaintiff, JANE DOE 17, by and through the undersigned counsel, in support of her
claims against Defendants, alleges and states as follows:
1. This action is brought, inter alia, pursuant to common law, statutory law and 18
U.S.C. §1591- §1595. Therefore, jurisdiction is proper under 28 U.S.C. §1331 and the damages
sought exceed the jurisdictional requirements of this Court.
2. Plaintiff files this complaint under a pseudonym in order to protect her identity
because the 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 and domiciled in the State of Florida and over the
age of 18.
Page 1 of 34
Case 1:19-cv-09610-PAE-DCF Document 1 Filed 10/17/19 Page 2 of 34
4. At all times material, Jeffrey Epstein (“Epstein”) was a citizen of the United
States and resident of the U.S. Virgin Islands. Epstein was a man of extreme wealth who
frequently travelled between and regularly stayed in his numerous residences, including in New
York (within the Southern District of New Yo
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