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Case 1:19-cv-07625-AJN-DCF Document 337-1
Case 1:19-cv-07625-AJN Document FiledFiled 11/29/19
08/20/19 Page 1Page
of 301 of 48
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 337-1
Case 1:19-cv-07625-AJN Document FiledFiled 11/29/19
08/20/19 Page 2Page
of 302 of 48
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
I
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