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Case 1:19-cv-09610-PAE-DCF   Document 36-1   Filed 12/23/19   Page 1 of 37




               EXHIBIT A
  Case 1:19-cv-09610-PAE-DCF
     Case 1:19-cv-09610-PAE-DCFDocument
                                Document36-1   Filed
                                          1 Filed    12/23/19Page
                                                   10/17/19     Page
                                                                  1 of234
                                                                        of 37




                            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.



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