EFTA00023140.pdf

Case 1:20-cv-02365-LJL Document 1 Filed 03/17/20 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X JANE DOE, Plaintiff, -against- COMPLAINT DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN; Defendants. X Plaintiff, Jane Doe, by her attorneys, Kaiser Saurbom & Mair, P.C., as and for her complaint against the defendants, alleges as follows: I. BACKGROUND I. Jane Doe seeks justice for the sexual crimes perpetrated against her by Jeffrey Epstein over the course of many years and for the abuse, manipulation and exploitation she suffered at his hands. Epstein identified Jane Doe as an extremely emotionally vulnerable young woman who, at the time she met him, had been entirely abandoned by her community, friends, and family which enabled him to seduce her into his world of horrific abuse. Every aspect of her life was controlled by Epstein. He dominated her psychologically. Jane Doe was constantly emotionally bullied and coerced by Epstein, including being required to submit to his constant sexual abuse. This lawsuit is about Jane Doe claiming her power, becoming a survivor, not a victim, and getting restitution for the sexual crimes perpetuated against her. She has real damages that are lasting: 1) She has permanent emotional injuries; 2) Her capacity to pursue a professional career has been severely compromised; 3) Her name and reputation has been ruined; EFTA00023140 Case 1:20-cv-02365-LJL Document 1 Filed 03/17/20 Page 2 of 8 and 4) she is virtually bankrupt, having been forced to spend most of her resources defending herself against false accusations, all of which stem from Epstein's crimes. 2. The Estate of Jeffrey E. Epstein, who perpetrated crimes of sexual abuse, sexual assault and rape against Jane Doe, must be held responsible for ruining her life. It has been nearly 19 years since Jane Doe was recruited by Jeffrey Epstein and Ghislaine Maxwell and plunged into a world in which she was psychologically, physically and sexually exploited and controlled for years. 3. Jane Doe was a naïve and uniquely vulnerable 22-year old when Epstein and Maxwell first preyed upon her. II. JURISDICTION 4. This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1331 because the claims asserted herein arise under 18 U.S.C. § 1591-1595. 5. Venue is properly laid in this District pursuant to 28 U.S.C. § 1391 because it is a District in which much of the alleged wrongdoing occurred. III. THE PARTIES 6. Plaintiff is a sex trafficking victim of Epstein. 7. At all times relevant herein, Jeffrey Edward Epstein ("Jeffrey Epstein" or "Epstein") maintained a residence and businesses at 9 East 71st Street, New York, NY 10021 ("Epstein's NY Residence") which was the location where Epstein committed repeated sexual assaults of young women, like Plaintiff, and engaged in sex trafficking. 8. At all times relevant herein, Epstein was an adult male over the age of 48, born on 2 EFTA00023141 Case 1:20-cv-02365-LJL Document 1 Filed 03/17/20 Page 3 of 8 January 20, 1953, and who died on August 10, 2019. He continued to maintain a residence and businesses at 9 East 71st Street, New York, NY 10021, and occupy it until his death. 9. At all times relevant herein, Defendant, Darren K. Indyke, is named in his personal capacity as an appointed executor of the Estate of Jeffrey E. Epstein (the "Estate of Jeffrey E. Epstein"), which was opened and domiciled in the United States Virgin Islands, St. Thomas Division, and is the legal entity responsible for intentional, criminal, and tortious conduct committed by Jeffrey Epstein as described in this Complaint. The Estate of Jeffrey E. Epstein includes Epstein's NY Residence, which was occupied by Jeffrey Epstein and his businesses until his death and was one of the locations where repeated acts of sexual abuse and sex trafficking against various women, including plaintiff, occurred. 10. At all times relevant herein, Defendant, Richard D. Kahn, is named in his personal capacity as an appointed executor of the Estate of Jeffrey E. Epstein (the "Estate of Jeffrey E. Epstein"). II. At all times relevant herein, Defendant, Darren K. Indyke, is named in his personal capacity as an appointed executor of the Estate of Jeffrey E. Epstein (the "Estate of Jeffrey E. Epstein"). 12. At all times relevant herein, Jeffrey Epstein (legally represented now through Darren K. Indyke and Richard D. Kahn as Executors of the Estate of Jeffrey E. Epstein (and referred to herein as the "Estate of Jeffrey E. Epstein"), owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit, or conspire to commit, or cause to be committed, intentional, criminal, fraudulent, or tortious acts against Plaintiff, including any acts that would cause Plaintiff to be harmed through conduct committed against her in violation of the TVPRA. 3 EFTA00023142 Case 1:20-cv-02365-LJL Document 1 Filed 03/17/20 Page 4 of 8 IV. EPSTEIN'S SEX TRAFFICKING CRIMINAL ENTERPRISE 13. At all times relevant herein, Jeffrey Epstein ["Epstein"] was an extremely wealthy financier, who used his wealth, power, resources, and connections to commit illegal sexual crimes in violation of the TVPRA, and to employ and conspire with other corporate entities, private foundations and trusts, to assist him in committing those sexual crimes or torts or to facilitate or enable those acts to occur. 14. Epstein displayed his enormous wealth, power, and influence to his employees; to the employees of the corporate entities, private foundations, and trusts, who worked at his direction; to the victims procured for sexual purposes; and to the public, in order to advance and carry out and conceal his crimes and torts. 15. At all times relevant herein, Epstein had access to numerous mansions, a fleet of airplanes, motor vehicles, boats and several helicopters. 16. At all times relevant herein, Jeffrey Epstein travelled between and frequently inhabited and travelled between numerous properties and homes, including a Manhattan townhome located at 9 East 71st Street, New York, NY 10021 valued conservatively by Jeffrey Epstein's own admission at $55,931,000.00; a ranch located at 49 Zorro Ranch Road, Stanley, New Mexico 87056 valued conservatively by Jeffrey Epstein's own admission at $17,246,208.00; a home located at 358 El Brillo Way, Palm Beach, Florida 33480 valued conservatively by Jeffrey Epstein's own admission at $12,380,209.00; an apartment located at 22 Avenue Foch, Paris, France 75116 valued conservatively by Jeffrey Epstein's own admission at $8,672,820.00; and an Island Little St. James Island No. 6B USVI 00802 (A, B, C). 17. As has been publicly reported, Epstein had a compulsive sexual preference for 4 EFTA00023143 Case 1:20-cv-02365-LJL Document 1 Filed 03/17/20 Page 5 of 8 young females and took pleasure in corrupting vulnerable young females into engaging in sexual acts with him. The allegations herein primarily concern Jeffrey Epstein's conduct while at his NY, Virgin Islands, Florida, New Mexico, and Paris residences and other locations. 18. Epstein fulfilled his compulsive need for sexual contact with and control over young females by preying on their personal, psychological, financial, and related vulnerabilities. Epstein's tactics included promising the victims shelter, transportation, gifts, money and employment, admission into educational institutions, educational tuition, protection, illusion of family and other things of value in exchange for sex. 19. Jeffrey Epstein specifically targeted underprivileged, emotionally vulnerable and/or economically disadvantaged young females exactly like Plaintiff to sexually molest and abuse. 20. Epstein's continuous psychological and physical control over Jane Doe facilitated his sexual abuse of her on a relatively consistent basis for many