Court records
- Format
- Set
- Court Records
- Text
- Searchable
Text as released
Machine-read from the scan. Names, dates and numbers can be misread — check anything you rely on against the original page.
Case 1:19-cv-07625-AJN-DCF Document 3 Filed 08/20/19 Page 1 of 30
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
CASE NO.: 1:19-cv-07625-AJN
VE
Plaintiff,
vs.
DARREN K. INDYKE AND
RICHARD D. KAHN AS JOINT
PERSONAL REPRESENTATIVES OF
THE ESTATE OF JEFFREY E. EPSTEIN,
NINE EAST 71ST STREET, CORPORATION,
FINANCIAL TRUST COMPANY, INC.,
NES, LLC,
Defendant.
___________________________________/
FIRST AMENDED COMPLAINT
Plaintiff, VE, by and through her undersigned counsel, for her claims against
Defendants, 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.
1
Case 1:19-cv-07625-AJN-DCF Document 3 Filed 08/20/19 Page 2 of 30
2. Plaintiff 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 Florida.
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 (within the Southern District of 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.
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. Kahn as Joint Personal
Representatives of the Es
[…]