EFTA00019101.pdf

I UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF NEW YORK 3 4 5 6 7 8 9 10 a. 11 6 DJ 0 ai 0. 12 ~ E 4p 13 3t 14 P z (6:I 2 a IS § 16 a 2 `') 17 18 19 20 21 22 23 24 25 26 27 28 JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defendants. Case No. COMPLAINT FOR DAMAGES DEMAND FOR JURY TRIAL PlaintiffJane 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 notorious pedophile and convicted sex offender Jeffrey Epstein ("Epstein"). It all started in 1994 when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a summer camp in Michigan. Jane Doe was their first known victim and was subsequently abused by Epstein and Maxwell for years as a young girl, suffering unimaginable physical and psychological trauma and distress. Despite that, Jane Doe has persevered and survived to tell her story, to hold her perpetrators accountable and to seek justice for the atrocities committed against her. 2. Throughout his life, Epstein systematically perpetrated acts of molestation. exploitation, assault and rape on hundreds of young girls. Epstein's system of abuse was facilitated in large part by his co-conspirator and accomplice, Maxwell, who helped supply him with a steady stream of young and vulnerable girls—many of whom were fatherless, like Jane Doe, and came from struggling families. 1 COMPLAINT FOR DAMAGES EFTA00019101 1 2 3 4 5 6 7 8 9 10 18 19 20 21 22 23 24 25 26 27 28 3. This system, which took years to develop, all started with them exploiting and abusing Jane Doe who they used as a guinea pig to refine their criminal enterprise and widen their network of additional sexual abuse victims. THE PARTIES 4. Plaintiff Jane Doe is a citizen of the State of California. At all times relevant to this suit, Doe was a minor child living in Florida and New York and who was sexually abused while she was a minor by Defendants in New York. 5. Defendant Ghislaine Maxwell is domiciled in the State of New York. 6. Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the Estate of Jeffrey E. Epstein. 7. Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the Estate of Jeffrey E. Epstein. JURISDICTION AND VENUE 8. Plaintiff is domiciled in California. 9. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at the time of his death. As the legal representatives of the Estate of Jeffrey E. Epstein, Darren K. Indyke and Richard D. Kahn are deemed citizens of the U.S. Virgin Islands. The matter in controversy exceeds the sum of $75,000, and therefore jurisdiction in this Court is proper. 28 U.S.C. § 1332(c)(2). 10. Ghislaine Maxwell is domiciled in New York. I I. A substantial part of the events giving rise to these causes of action occurred in the Southern District of New York, thus venue in this district is proper. 28 U.S.C. § 1391(b)(2). 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 Doe 13. In the summer of 1994, Jane Doe met Jeffrey Epstein and Ghislaine Maxwell at Interlochen Arts Camp in Michigan when she was only 13-years-old. Doe was there as a student 2 COMPLAINT FOR DAMAGES EFTA00019102 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 in the voice program. Doe was sitting alone on a bench between classes when Epstein and Maxwell approached her. Epstein bragged to her about being a patron of the arts and giving scholarships to talented young artists like Doe. Epstein and Maxwell probed her at length about her background, family situation and where she lived. As Doe got up to leave, Epstein requested her mother's phone number back in Florida. She was alarmed by his request, but also feared that she could not refuse the older man's request so she complied and provided him with the phone number. 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 widow." 16. While these visits made Doe extremely uncomfortable, Epstein and Maxwell made her feel she could not refuse them. During this time, Epstein started to pay for voice lessons for Doe and insisted that Doe could not advance her career in any way without him. When Doe expressed hesitation about spending time with Epstein and Maxwell or acquiescing to their desires, Epstein and Maxwell would threaten Doe, and scold her for being "ungrateful". 3 COMPLAINT FOR DAMAGES EFTA00019103 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 17. During one of Doe's encounters with Epstein, he took her to Mar-a-Lago where he introduced her to its owner, Donald J. Trump. Introducing 14-year-old Doe to Donald J. Trump, Epstein elbowed Trump playfully asking him, referring to Doe, "This is a good one, right?" Trump smiled and nodded in agreement. They both chuckled and Doe felt uncomfortable, but, at the time, was too young to understand why. 18. Towards the end of 1994, Epstein invited Doe into his pool house, where he grabbed her, put her on his lap and started masturbating. Epstein told her that was what to expect from photographers who were soon going to be take modeling pictures of her. However, when Doe was ultimately photographed by these professional photographers, they did no such thing. 19. Over the next few years, the sexual abuse escalated. On a regular basis, Epstein would digitally penetrate Doe, force Doe to perform sexual acts on him and apply vibrators on different parts of Doe's body. The abuse occurred at Epstein's home in Palm Beach, Florida, Epstein's townhouse on 9 East 71st Street in New York City, and Epstein's ranch in New Mexico. When travelling to these places, Doe often flew with Epstein and Maxwell in Epstein's private jet. 20. In 1996, when Doe was 16-years-old, Epstein moved Doe to New York City. At first, Epstein put Doe up in his apartment on 65th Street and 2nd Avenue. After a few months. Epstein co-signed the lease for Doe and Doe's mother for an apartment. Additionally, Epstein paid her tuition at a private high school in Manhattan as well. 21. Once Epstein had secured Doe in New York and made her and her family completely dependent on him financially (including, for the roof over their heads), Epstein's abuse of Doe cont