Court Records
Case 1:19-cv-10479-ALC-DCF Document 1 Filed 11/14/19 Page 1 of 16
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
Plaintiff, CASE NO:
v.
DARREN K. INDYKE and RICHARD D. KAHN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,
Defendants.
COMPLAINT
Bows SCHILLER FLEXNER LLP
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Plaintiff by her attorneys Boies Schiller Flexner LLP, for her Complaint
against Defendants, Darren K. Indyke and Richard D. Kahn in their capacities as the executors of
the Estate of Jeffrey Edward Epstein ("Epstein"), avers upon personal knowledge as to her own
acts and status and upon information and belief and to all other matters as follows:
NATURE OF THE ACTION
I. This suit arises out of Jeffrey Epstein's sexual abuse of Plaintiff beginning when Plaintiff
was 20 years old that lasted years and included trafficking Plaintiff to each of his homes in the
United States and Paris.
2. Plaintiff was a young girl living in with hopes of becoming a model when
she was approached by one of Epstein's recruiters about a prospective modeling opportunity in
the United States and invited to a restaurant to meet Epstein, who was dining with a former high
U.S. Government official, a famous actor, and a well-known comedian. What appeared on the
outside as a legitimate opportunity to break into the modeling business in the United States
turned into years of horrific abuse and manipulation at the hands of Jeffrey Epstein.
3. Epstein's trafficking scheme involved recruiting young females by making false promises
and using his wealth, power and threats to intimidate the females into submission to his
demands. This same pattern was repeated numerous times with numerous young women.
4. As United States District Judge Kenneth Marra found, "From between about 1999 and
2007, Jeffrey Epstein sexually abused more than 30 minor girls . . . at his mansion in Palm Beach
Florida, and elsewhere in the United States and overseas. . . . In addition to his own sexual abuse
of the victims, Epstein directed other persons to abuse the girls sexually. Epstein used paid
employees to find and bring minor girls to him. Epstein worked in concert with others to obtain
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minors not only for his own sexual gratification, but also for the sexual gratification of others."
Doe 1 v. United States, 359 F. Supp. 3d 1201, 1204 (S.D. Fla. 2019) (internal citations omitted).
5. Epstein organized this sex trafficking network to obtain hundreds of young females for
himself for sex, and also lent these females out to other powerful and wealthy individuals to be
sexually abused.
6. Epstein conspired with others and hired staff to maintain and keep secret this network of
sexual abuse for years, which sprawled throughout Epstein's residences in New York, Florida,
New Mexico, the United States Virgin Islands, and Paris. Epstein's preference was to have three
different young females a day for his sexual pleasure.
7. Despite his significant criminal activity, in 2008 Epstein received a shockingly minimal
charge, pleading guilty to a single Florida state law charge of procuring a minor for prostitution
and a non-prosecution agreement (a "NPA") with the U.S. Attorney for the Southern District of
Florida. Unknown to the public and the victims at the time, Epstein's lawyers were pressuring
the Government to commit to the NPA without informing the victims. Epstein's multiple
victims were kept in the dark and told to be "patient" while Epstein's lawyers worked to protect
him and other potential co-conspirators from prosecution. Epstein served one year in jail, but
was afforded the privilege of being able to leave the jail to go to work for twelve hours per day,
six days per week.
8. The NPA allowed Epstein to escape proportionate punishment for his actions and to
continue operating his sex trafficking enterprise with liberty.
9. A few years later, Epstein flippantly referred to his sexual abuse of multiple minors, and
the slap on the wrist he had received for it, in a 2011 interview with the New York Post:
"Billionaire pervert Jeffrey Epstein is back in New York City — and making wisecracks about his
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just-ended jail stint for having sex with an underage girl. 'I am not a sexual predator, I'm an
offender,' the financier told The Post yesterday. 'It's the difference between a murderer and a
person who steals a bagel,' said Epstein." Amber Sutherland, Billionaire Jefrey Epstein: I'm a
Sex Offender Not a Predator, N.Y. Post (Feb. 25, 2011),
https://nypost.com/20I I/02/25/billionaire-jeffrey-epstein-im-a-sex-offender-not-a-predator/.
10. In August 2018, just one year before his death, Epstein told a New York Times reporter
"that criminalizing sex with teenage girls was a cultural aberration and that at times in history it
was perfectly acceptable." James B. Stewart, The Day Jeffrey Epstein Told Me He Had Dirt on
Powerful People, N.Y. Times (Aug. 12, 2019),
https://www.nytimes.com/2019/08/12/business/jeffrey-epstein-interview.html.
II. When Plaintiff was 20 years old, Epstein added her to his long list of victims by
committing sexual assault and battery against her. As such, Epstein is responsible for battery
and intentional infliction of emotional distress pursuant to New York common law. The damage
to Plaintiff has been severe and lasting.
12. This action has been timely filed pursuant to N.Y. C.P.L.R. § 215(8)(a), which provides
that a plaintiff shall have at least one year from the termination of a criminal action against the
same defendant to commence an action with respect to the event or occurrence from which the
criminal action arose. A criminal action against Epstein with respect to the same sex trafficking
enterprise from which Plaintiff's claims arise was terminated on August 29, 2019.
13. This action has also been timely filed pursuant to N.Y. C.P.L.R. § 213-C, which provides
that a plaintiff shall have 20 years to file civil claims "for physical, psychological or other injury
or condition suffered by such person as a result of conduct which would constitute rape in the
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first degree as defined in section 130.35 of the penal law." Epstein raped Plaintiff within 20
years of filing this Complaint.
14. Any statute of limitations applicable to Plaintiff's claims, if any, is tolled due to the
continuous and active deception, duress, threats of retaliation, and other forms of misconduct that
Epstein and his co-conspirators used to silence his many victims, including Plaintiff. Epstein's
actions deprived Plaintiff of the opportunity to commence this lawsuit before his death. Until his
death, Plaintiff feared that Epstein and his co-conspirators would harm her or her family, or ruin
her life, if she came forward.
15. Defendants are equitably estopped from asserting a statute of limitations defense.
Allowing Defendants to do so would be unjust. Epstein and his co-conspirators intimidated each
of his victims into silence by threatening their lives and their livelihoods. They therefore
prevented Plaintiff from commencing this lawsuit before his death. By using threats, along with
his wealth and power, Epstein was able to escape punishment for his intolerable and brutal
crimes against countless young women and underage girls for the duration of his life.
PARTIES
16. Plaintiff is a citizen and resident of
17. Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the Estate
of Jeffrey E. Epstein.
18. Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the Estate
of Jeffrey E. Epstein.
JURISDICTION AND VENUE
19. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at
the time of his death. Jeffrey Epstein maintained a residence in the Southern District of New
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York. 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.
20. The amount in controversy in this action exceeds the sum or value of $75,000.00
excluding interests and costs and is between citizens of different states. Accordingly,
jurisdiction is proper under 28 U.S.C. § 1332.
21. Venue is proper in this Court as Epstein's sexual abuse of Plaintiff began in New York,
New York, where he recruited her at the age of 20 and began grooming her for sex in his
organized sex trafficking ring.
22. Many of the events giving rise to these causes of action occurred in the Southern District
of New York, where a substantial amount of Epstein's property is located. Thus, venue in this
district is proper. 28 U.S.C. § 1391(b)(2).
FACTUAL ALLEGATIONS
A. Epstein's Sex Trafficking Enterprise
23. Jeffrey Epstein was widely renowned as a billionaire who used his vast connections to
powerful individuals, and seemingly unlimited wealth and resources, to create a web of
transcontinental sex trafficking that served himself, his co-conspirators, and some of the most
powerful people in the world.
24. Epstein owned multiple residences and frequently travelled between them, including at 9
East 71' Street, New York, New York 10021, and at 49 Z,orro Ranch Road, Stanley, New
Mexico 87056, where the illegal sexual crimes against Plaintiff occurred. Epstein conservatively
valued his New York townhome at $55,931,000.00. Epstein conservatively valued his New
Mexico ranch at $17,246,208.00. In addition, Epstein owned residences in the Virgin Islands,
Florida, and France, and even on his own island, Great St. James Island, where his
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transcontinental sex trafficking of hundreds of young females servicing him, his co-conspirators,
and wealthy and powerful individuals around the world occurred.
25. The allegations herein concern Epstein's tortious acts against Plaintiff while at Epstein's
mansion in New York, his home in Florida, his home in the Virgin Islands, his apartment in
Paris, and his New Mexico ranch.
26. At all times material to this cause of action, Jeffrey Epstein utilized his seemingly
unlimited power, wealth, and resources, as well as his deep connections to powerful and
politically connected individuals to intimidate and manipulate his victims of sexual abuse.
27. Epstein and his co-conspirators had perfected a scheme for manipulation and abuse of
young females. As part of the scheme, a female "recruiter" would approach a young female and
strike up a conversation in an effort to quickly learn about the young female's background and
any vulnerabilities they could expose. The recruiter would then manipulate the young female
into coming back to one of Epstein's residences by offering the young female something she
needed. At times the recruiter's lure would be a modeling opportunity, money for education,
help for the young female's family, and a whole host of other related offers depending on their
target's situation. Once in the residence, the recruiter and Epstein would work in concert to
impress and intimidate the young female with displays of vast wealth, including having
employees that were butlers and maids formally dressed around the house. They would also
strategically place photographs of very powerful political and social figures amongst
photographs and art displaying nude females in an effort to normalize the sexual abuse. They
would also normalize the sexual abuse by placing a massage table and spa related products
around the massage area in an effort to legitimize the area where the abuse was set to occur.
Once abused, Epstein and his co-conspirators continued to manipulate the victims, using their
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financial power, promises, and threats to ensure that the victim returned as directed and remained
compliant with their demands.
B. The Arrest, Prosecution, and Death of Epstein
28. The sexual trafficking ring described herein started at least as early as 1995 and
continued up until at least July 2, 2019, when the U.S. Attorney's Office for the Southern District
of New York ("SDNY") charged Epstein with sex trafficking conspiracy and sex trafficking in
violation of 18 U.S.C. § 1591. He was arrested on July 8, 2019, pursuant to the SDNY's Sealed
Two Count Indictment, which is attached as Exhibit A.
29. The Indictment described Epstein's conduct and his abuse and trafficking of females in
the same trafficking operation he used to abuse and traffic Plaintiff.
30. Epstein's last will and testament (the "Will") was executed on August 8, 2019, at the
Metropolitan Correctional Center. The witnesses were Mariel Colon Mire and Gulnom Tali. The
Will included affidavits from Darren K. Indyke and Richard D. Kahn, in which they swear an
"Oath of Willingness to Serve as Executor and Appointment of Local Counsel."
31. Epstein was found dead in his cell at the Metropolitan Correctional Center on August 10,
2019.
32. Epstein's last will and testament was filed on August 15, 2019, in the Probate Division of
the Superior Court of the Virgin Islands.
33. Darren K. Indyke and Richard D. Kahn filed a Certificate of Trust in the Superior Court
of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In
the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26,
2019).
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34. Epstein's will was entered into probate on September 6, 2019, and the Superior Court of
the Virgin Islands accordingly authorized Darren K. Indyke and Richard D. Kahn to administer
Epstein's estate. See Order for Probate, In the Matter of the Estate ofJeffrey E. Epstein, Probate
No. ST-19-PB-80 (Super. Ct. V.I. Sept. 6, 2019); Letters Testamentary, In the Matter of the
Estate of Jeffrey E. Epstein, Probate No. ST-I9-PB-80 (Super. Ct. V.I. Sept. 6, 2019).
35. The Will's first article directs Epstein's executors "to pay from my estate all expenses of
my last illness, my funeral and burial expenses, the administration expenses of my estate and all
of my debts duly proven and allowed against my estate." The Will further directs that "after the
payments and distributions provided in Article FIRST," Epstein "give[s] all of my property, real
and personal, wherever situated ... to the then acting Trustees of The 1953 Trust."
36. Following Epstein's death, SDNY submitted a proposed nolle prosequi order in the
criminal matter against him because it was required by law to do so after Epstein was deceased.
On August 29, 2019, U.S. District Judge Richard Berman formally dismissed SDNY's
indictment against Epstein, terminating the criminal action against him. Plaintiff's claims are
therefore timely under N.Y. C.P.L.R. § 215(8Xa).
C.
• was born on in
38. In 2002, was 20 years old and an aspiring model. In Cape Town, ME, an
American model, approached in an attempt to befriend her. asked if she
would like to meet Epstein, who she called the "King of America." described Epstein as a
well-connected billionaire who could help her with her modeling career and explained that he
was visiting Africa with a former high U.S. Government official, a famous actor, and a
well- known comedian.
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39. considered meeting Epstein an amazing opportunity because modeling in New
York City had always been one of her biggest dreams. • brought to a restaurant to
meet Epstein, who at the time was dining with the former high U.S. Government official, the
famous actor, and the well-known comedian. had never met a celebrity before. She was
invited to attend a speech the former high U.S. Government official was giving in Cape Town
the next day, and was escorted to the speech by police cars with individuals associated with the
former official.
40. Later, Epstein asked to bring her modeling portfolio to his hotel for "casting."
Epstein told that he owned a modeling agency and would get her an agent in New York.
He also mentioned that his good friend, Les Wexner, owned Victoria's Secret, a lingerie
conglomerate.
41. Within a few days, Leslie Groff began calling . Groff told that Epstein
wanted to bring her to New York City to model. Groff, who was in New York at the time,
helped get a visa, passport, and airline tickets. It was first time traveling
overseas, so she was nervous. Epstein called mother from New York to assure her that
would be safe with him in New York.
42. Within two weeks, arrived in New York. A car picked her up from the airport
and brought her to an apartment building on 66th Street, where Epstein housed some of the other
models who he was abusing. But was not there for long. Shortly after arriving at the
apartment, ==, another one of Epstein's co-conspirators, called and told that
was going to the Caribbean. did not understand why she was traveling to the
Caribbean so soon after arriving in New York City, but hoped it was for a modeling job.
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43. was taken on Epstein's private plane. During the flight, Epstein began sexually
touching leg. She felt trapped and terrified, and feared that she would be killed.
44. They arrived at Epstein's home in the Virgin Islands. Epstein's abuse of there
began when sent to Epstein's room to massage him. For the rest of the trip,
Epstein repeatedly raped by forcible compulsion. repeatedly sent to
Epstein's room, where he would touch her, use massage devices on her, force her to perform oral
sex on him, and sexually force himself on her. also witnessed another young girl
performing oral sex on Epstein in front of while they were watching a movie.
was terrified of Epstein and his power. No one knew where she was and she believed that if
anything happened to her, no one would ever know.
45. Instead of fulfilling her dreams of becoming a model in New York City, was
subject to extreme and repeated sexual abuse. Epstein's sexual abuse of was humiliating
and degrading, and caused to cry herself to sleep each night. She felt trapped and alone
on Epstein's private island. learned very quickly that Epstein was incredibly powerful
and that she should not disobey his demands.
46. Epstein's abuse of lasted for years. Epstein forced her to travel to the United
States many times to see Epstein and be subjected to repeated sexual abuse for one to two weeks
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at a time, sometimes staying in his New York apartment. Epstein never introduced to a
modeling agent, and she was never hired for a modeling job.
47. For those years, felt like a prisoner and was afraid of betraying Epstein because of
his money and power. She was afraid he would hurt her or her family. In fact, the very first time
Epstein brought to the United States, in order to scare her, he told her that when another
woman had accused him of rape, he planted drugs in the woman's apartment and had her sent to
prison.
48. Epstein made very clear to that he was incredibly wealthy, powerful, and
regularly in contact with world leaders. In fact, in his New York mansion he had photographs
displayed of significant political figures to ensure that any young female entering the home
would know that he had extensive government connections. Epstein was not to be disobeyed and
he made clear by his words and actions that there would be consequences if did not
comply with his demands.
49. was also forced to travel to Epstein's home in Paris where she had to stay with
Ghislaine Maxwell, one of Epstein's main recruiters of young females, and where
forced her to be photographed nude for Epstein. During that trip, witnessed that young
females were on call to sexually pleasure Epstein.
50. final trip to the United States was in 2004. She flew to see Epstein at his New
Mexico ranch, called "Zorro Ranch." Epstein abused at Zorro Ranch. During that trip,
Epstein took with him to meet another important government official. complied
and went with Epstein. At the meeting, believed that Epstein had brought her there so
that the official could look her over. felt very uncomfortable and she and Epstein began
to fight because he claimed she was not being obedient. Epstein then informed that he
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wanted her to travel with him on his plane to California and serve drinks to some of his scientist
friends who were going to be flying with him to California. But before the flight, after an
argument with Epstein, flew home to This was the last time visited
Epstein.
51. Epstein attempted to keep in contact with through e-mail over the years. For
example, in 2016, Epstein e-mailed to ask if she knew another woman
who was a victim of Epstein's sex trafficking scheme. In June 2019, only two months before his
death, Epstein sent an e-mail asking her to send him nude photographs.
52. was deeply affected by her harrowing experiences at the hands of Epstein. She
developed eating disorders that affected her for years afterwards. She also suffered from
substance abuse, debilitating panic attacks, and severe anxiety.
53. Epstein's sexual assault and battery of continues to cause her significant distress
and harm.
FIRST CAUSE OF ACTION
(Battery)
54. Plaintiff repeats and re-alleges the allegations stated above in paragraphs 1-53 as if fully
set forth herein.
55. Epstein intentionally committed battery by sexually assaulting Plaintiff on numerous
occasions at his homes in New York, New Mexico, Florida, France, and the U.S. Virgin Islands.
As described above, on multiple occasions over a years-long period, Epstein raped Plaintiff and
intentionally touched intimate parts of her body in an offensive and sexual manner without her
consent.
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56. Epstein's actions constitute sexual offenses as defined in New York Penal Law Article
130, including but not limited to rape in the first degree as defined in Article 130.35, inasmuch as
Epstein engaged in sexual intercourse with Plaintiff by forcible compulsion. See N.Y. C.P.L.R.
§ 213-C.
57. A criminal action against Epstein with respect to the same sex trafficking enterprise from
which Plaintiffs first cause of action arises was terminated on August 29, 2019, less than one
year prior to the filing of this Complaint. See N.Y. C.P.L.R. § 215(8Xa).
58. As a direct and proximate result of Epstein's conduct, Plaintiff has in the past and will in
the future continue to suffer extreme emotional distress, humiliation, fear, anxiety, panic attacks,
psychological trauma, loss of dignity and self-esteem, and invasion of her privacy.
SECOND CAUSE OF ACTION
(Intentional Infliction of Emotional Distress)
59. Plaintiff repeats and re-alleges the allegations stated above in paragraphs I 53 as if fully
set forth herein.
60. As a direct result of these allegations as stated, Epstein committed intentional infliction of
emotional distress against Plaintiff.
61. Epstein's actions, described above, constitute extreme and outrageous conduct that
shocks the conscience. Epstein's plan to recruit, entice, rape, and assault Plaintiff on multiple
occasions goes beyond all possible bounds of decency and is intolerable in a civilized
community.
62. Epstein knew or disregarded the substantial likelihood that these actions would cause
Plaintiff severe emotional distress.
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63. A criminal action against Epstein with respect to the same sex trafficking enterprise from
which Plaintiff's second cause of action arises was terminated on August 29, 2019, less than one
year prior to the filing of this Complaint. See N.Y. C.P.L.R. § 215(8Xa).
64. As a direct and proximate result of Epstein's conduct, Plaintiff has in the past and will in
the future continue to suffer extreme emotional distress, humiliation, fear, anxiety, panic attacks,
psychological trauma, loss of dignity and self-esteem, and invasion of her privacy.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests judgment against Defendants, awarding
compensatory, consequential, exemplary, and punitive damages in an amount to be determined at
trial; costs of suit; attorneys' fees; and such other and further relief as the Court may deem just
and proper.
JURY DEMAND
Plaintiff hereby demands a trial by jury on all causes of action asserted within this
pleading.
Dated: November 14, 2019.
/s/ Joshua I. Schiller
David Boies
Bows SCHILLER FLEXNER LLP
333 Main Street
Armonk, NY 10504
Joshua I. Schiller
Bows SCHILLER FLEXNER LLP
55 Hudson Yards
New York, NY 10001
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Sigrid McCawley
(Pro Hac Vice Pending)
Bows SCIIILLER FL EXNER LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
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