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Case 1:20-cv-00484-JGK-DCF Document 9 Filed 01/22/20 Page 1 of 10 1 2 3 4 5 6 7 Case 1:20-cv-00484-JGK Document 9 Filed 01/22/20 Page 1 of 10 JANE DOE, Plaintiff, V. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Case No. l:20-cv-00484 COMPLAINT FOR DAMAGES DARREN K. INDYKE and RICHARD D. 8 KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, DEMAND FOR JURY TRIAL 9 GHISLAINE MAXWELL, an individual, 10 11 12 13 14 Defendants. Plaintiff Jane Doe ("Doe" or "Plaintiff') alleges as follows: INTRODUCTION 1. This case arises out of years of sexual abuse and exploitation of a young girl by 15 notorious pedophile and convicted sex offender Jeffrey Epstein ("Epstein"). It all started in 1994 16 when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a 17 summer camp in Michigan. Jane Doe was their first known victim and was subsequently abused 18 by Epstein and Maxwell for years as a young girl, suffering unimaginable physical and 19 psychological trauma and distress. Despite that, Jane Doe has persevered and survived to tell her 20 story, to hold her perpetrators accountable and to seek justice for the atrocities committed against 21 her. 22 2. Throughout his life, Epstein systematically perpetrated acts of molestation, 23 exploitation, assault and rape on hundreds of young girls. Epstein's system of abuse was 24 facilitated in large part by his co-conspirator and accomplice, Maxwell, who helped supply him 25 with a steady stream of young and vulnerable girls-many of whom were fatherless, like Jane 26 Doe, and came from struggling families . 27 28 1 COMPLAINT FOR DAMAGES Case 1:20-cv-00484-JGK-DCF Document 9 Filed 01/22/20 Page 2 of 10 Case 1:20-cv-00484-JGK Document 9 Filed 01/22/20 Page 2 of 10 1 3. This system, which took years to develop, all started with them exploiting and 2 abusing Jane Doe who they used as a guinea pig to refine their criminal enterprise and widen their 3 network of additional sexual abuse victims . 4 5 4. THE PARTIES Plaintiff Jane Doe is a citizen of the State of California. At all times relevant to this 6 suit, Doe was a minor child living in Florida and New York and who was sexually abused while 7 she was a minor by Defendants in New York. 8 9 5. 6. Defendant Ghislaine Maxwell is domiciled in the State of New York. Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the 10 Estate of Jeffrey E. Epstein . 11 7. Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the 12 Estate of Jeffrey E. Epstein. 13 14 15 8. 9. JURISDICTION AND VENUE Plaintiff is domiciled in California. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin 16 Islands at the time of his death. As the legal representatives of the Estate of Jeffrey E. Epstein, 17 Darren K. Indyke and Richard D. Kahn are deemed citizens of the U. S. Virgin Islands. The matter 18 in controversy exceeds the sum of$75,000, and therefore jurisdiction in this Court is proper. 28 19 U.S.C. § 1332(c)(2). 20 21 10. 11. Ghislaine Maxwell is domiciled in New York. A substantial part of the events giving rise to these causes of action occurred in the 22 Southern District of New York, thus venue in this district is proper. 28 U.S.C. § 139l(b)(2). 23 24 25 26 27 JURY DEMAND 12. Plaintiff hereby demands a trial by jury on all of her claims in this action. FACTUAL ALLEGATIONS Epstein and Maxwell 's Abuse of D oe 13. In the summer of 1994, Jane Doe met Jeffrey Epstein and Ghislaine Maxwell at 28 Interlochen Arts Camp in Michigan when she was only 13-years-old. Doe was there as a student 2 COMPLAINT FOR DAMAGES Case 1:20-cv-00484-JGK-DCF Document 9 Filed 01/22/20 Page 3 of 10 p.. H 8 ~ H " ~ ~ V, i ~ ~ §;::: 0 "!20-r-.. 0 O '<I; ~ ai 'g ~ "5 - ~ ~ ~ 0. -< 0 U Ql ~ .g ~ ~ ::r:~Q)Q. C/) 0 g>g -<r-.. ::r:ao-: U') v,_,f:::: >-< - '<I; z := 0 -< - .;; ~ Case 1:20-cv-00484-JGK Document 9 Filed 01/22/20 Page 3 of 10 1 in the voice program. Doe was sitting alone on a bench between classes when Epstein and 2 Maxwell approached her. Epstein bragged to her about being a patron of the arts and giving 3 scholarships to talented young artists like Doe. Epstein and Maxwell probed her at length about 4 her background, family situation and where she lived. As Doe got up to leave, Epstein requested 5 her mother's phone number back in Florida. She was alarmed by his request, but also feared that 6 she could not refuse the older man's request so she complied and provided him with the phone 7 number. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 14. Several weeks later, once Doe had returned from Michigan to Florida, Epstein called Doe's home. Epstein first spoke with Doe's mother about how he mentors young kids and provides scholarships for the arts. He requested to speak to Doe and invited her and her mother to his mansion in Palm Beach. He sent a driver across town to pick them up. 15 . Over the course of the next several months, Epstein and Maxwell attempted to groom and mentor 13-year-old Jan Doe. Epstein gave himself the name of Doe's "godfather" while Maxwell acted like an older sister to her. They took her to movies, went shopping with her and lounged around Epstein's estate with her. Epstein and Maxwell then started to make sexual references when they were with her. For instance, Maxwell told Doe that having sex with ex- boyfriends was easy because once you slept with them "they've been grandfathered in and you could go back and fuck them whenever you wanted." Epstein also started to slowly display his pedophilic ways when shopping with Doe and Maxwell. Instead of Doe picking out clothes she wanted to wear, Epstein insisted that she pick out and wear little children's cotton underwear. Also, after nearly every visit with Epstein and Maxwell, Epstein sent Doe home with two or three one-hundred-dollar bills to give her mother since "she 's having a hard time and struggling as a 23 widow." 24 16. While these visits made Doe extremely uncomfortable, Epstein and Maxwell made 25 her feel she could not refuse them. During this time, Epstein started to pay for voice lessons for 26 Doe and insisted that Doe could not advance her career in any way without him. When Doe 27 expressed hesitation about spending time with Epstein and Maxwell or acquiescing to their 28 desires, Epstein and Maxwell would threaten Doe, and scold her for being "ungrateful". 3 COMPLAINT FOR DAMAGES Case 1:20-cv-00484-JGK-DCF Document 9 Filed 01/22/20 Page 4 of 10 i::i.. ...:l 8 )( ...:l ..... .E ~ Cl) <>- ~ ~§ ~ 0 12<>-!;;.: 0 O , ~ ~ .E ~ "S .E cw, 0($ 0 =. a, 0 ~ oUG> 0 , C ~ ·c ~ _g ::r: 0 Qi a. ~ Cl C/)oC8 - <( ..... ::r: § ~;::: er.; V) .....J "' - - '<I; z - 0 ::: .;; ~- p.. Case 1:20-cv-00484-JGK Document 9 Filed 01/22/20 Pag