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Case 1:19-cv-10577 Document 1 Filed 11/14/19 Page 1 of 14
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
JANE DOE 1000,
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-10577 Document 1 Filed 11/14/19 Page 2 of 14
Plaintiff Jane Doe 1000, 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.
2. Jane Doe 1000 was sexually trafficked by Epstein as part of his organized ring of
procuring young and underage girls for sex. One of Epstein’s co-conspirators contacted Jane
Doe after a modeling appearance and arranged to have Jane Doe meet Epstein under the false
pretense that he was involved in the modeling industry and wanted to interview her about
opportunities. Rather than help her with her modeling career, Epstein manipulated and
intimidated Jane Doe and subjected her to years of sexual abuse in his New York mansion.
3. Epstein’s trafficking scheme involved recruiting young females by making false promises
and using his wealth, power and threats to intimidate the females into submission to his
demands. This same pattern was repeated numerous times with numerous young w
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