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marker2/court-redacted-v-indyke-10475/EFTA02777675/EFTA02777675.md

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+# EXHIBIT A
+
+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+X
+
+UNITED. STATES OF AMERICA
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+x
+
+SEALED
+
+INDICTMENT
+
+19 Cr.
+
+19 CRIM 490
+
+COUNT ONE (Sex Trafficking Conspiracy)
+
+The Grand Jury charges:
+
+#### OVERVIEW
+
+1. As set forth herein, over the course of many years, JEFFREY EPSTEIN, the defendant, sexually exploited and abused dozens of minor girls at his homes in Manhattan, New York, and Palm Beach, Florida, among other locations.
+
+2. In particular, from at least in or about 2002, up to and including at least in or about 2005, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and recruited, minor girls to visit his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residence") to engage in sex acts with him, after which he would give the victims hundreds of dollars in cash. Moreover, and in order to maintain and increase his supply of victims, EPSTEIN also paid certain of his victims to recruit additional girls to be similarly abused by EPSTEIN. In
+
+this way, EPSTEIN created a vast network of underage victims for him to sexually exploit in locations including New York and Palm Beach.
+
+3. The victims described herein were as young as 14 years old at the time they were abused by JEFFREY EPSTEIN, the defendant, and were, for various reasons, often particularly vulnerable to exploitation. EPSTEIN intentionally sought out minors and knew that many of his victims were in fact under the age of 18, including because, in some instances, minor victims expressly told him their age.
+
+4. In creating and maintaining this network of minor victims in multiple states to sexually abuse and exploit, JEFFREY EPSTEIN, the defendant, worked and conspired with others, including employees and associates who facilitated his conduct by, among other things, contacting victims and scheduling their sexual encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence.
+
+## FACTUAL BACKGROUND
+
+5. During all time periods charged in this Indictment, JEFFREY EPSTEIN, the defendant, was a financier with multiple residences in the continental United States, including the New York Residence and the Palm Beach Residence.
+
+6. Beginning in at least 2002, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and
+
+recruited, dozens of minor girls to engage in sex acts with him, after which EPSTEIN paid the victims hundreds of dollars in cash, at the New York Residence and the Palm Beach Residence.
+
+7. In both New York and Florida, JEFFREY EPSTEIN, the defendant, perpetuated this abuse in similar ways. Victims were initially recruited to provide "massages" to EPSTEIN, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts. EPSTEIN paid his victims hundreds of dollars in cash for each encounter. Moreover, EPSTEIN actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. EPSTEIN incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each girl that they brought to EPSTEIN. In so doing, EPSTEIN maintained a steady supply of new victims to exploit.
+
+#### The New York Residence
+
+8. At all times relevant to this Indictment, JEFFREY EPSTEIN, the defendant, possessed and controlled amulti-story private residence on the Upper East Side of Manhattan, New York, i.e., the New York Residence. Between at least in or about <sup>2002</sup> and in or about 2005, EPSTEIN abused numerous minor victims at the New York Residence by causing these victims to be recruited to engage in paid sex acts with him.
+
+9. When a victim arrived at the New York Residence, she typically would be escorted to a room with a massage table, where she would perform a massage on JEFFREY EPSTEIN, the defendant. The victims, who were as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress before beginning the "massage." During the encounter, EPSTEIN would escalate the nature and scope of physical contact with his victim to include, among other things, sex acts such as groping and direct and indirect contact with the victim's genitals. EPSTEIN typically would also masturbate during these sexualized encounters, ask victims to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys.
+
+10. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, paid the victim in cash. Victims typically were paid hundreds of dollars in cash for each encounter.
+
+11. JEFFREY EPSTEIN, the defendant, knew that many of his New York victims were underage, including because certain victims told him their age. Further, once these minor victims were recruited, many were abused by EPSTEIN on multiple subsequent occasions at the New York Residence. EPSTEIN sometimes personally contacted victims to schedule appointments at the New York Residence. In other instances, EPSTEIN directed
+
+employees and associates, including aNew York-based employee ("Employee-1"), to communicate with victims via phone to arrange for these victims to return to the New York Residence for additional sexual encounters with EPSTEIN.
+
+12. Additionally, and to further facilitate his ability to abuse minor girls in New York, JEFFREY EPSTEIN, the defendant, asked and enticed certain of his victims to recruit additional girls to perform "massages" and similarly engage in sex acts with EPSTEIN. When avictim would recruit another girl for EPSTEIN, he paid both the victim-recruiter and the new victim hundreds of dollars in cash. Through these victimrecruiters, EPSTEIN gained access to and was able to abuse dozens of additional minor girls.
+
+13. In particular, certain recruiters brought dozens of additional minor girls to the New York Residence to give massages to and engage in sex acts with JEFFREY EPSTEIN, the defendant. EPSTEIN encouraged victims to recruit additional girls by offering to pay these victim-recruiters for every additional girl they brought to EPSTEIN. When avictimrecruiter accompanied anew minor victim to the New York Residence, both the victim-recruiter and the new minor victim were paid hundreds of dollars by EPSTEIN for each encounter. In addition, certain victim-recruiters routinely scheduled these
+
+encounters through Employee-1, who sometimes asked the recruiters to bring a specific minor girl for EPSTEIN.
+
+## The Palm Beach Residence
+
+14. In addition to recruiting and abusing minor girls in New York, JEFFREY EPSTEIN, the defendant, created a similar network of minor girls to victimize in Palm Beach, Florida, where EPSTEIN owned, possessed and controlled another large residence, i.e., the Palm Beach Residence. EPSTEIN frequently traveled from New York to Palm Beach by private jet, before which an employee or associate would ensure that minor victims were available for encounters upon his arrival in Florida.
+
+15. At the Palm Beach Residence, JEFFREY EPSTEIN, the defendant, engaged in a similar course of abusive conduct. When a victim initially arrived at the Palm Beach Residence, she would be escorted to a room, sometimes by an employee of EPSTEIN's, including, at times, two assistants ("Employee-2" and' "Employee-3") who, as described herein, were also responsible for scheduling sexual encounters with minor victims. Once inside, the victim would provide a nude or semi-nude massage for EPSTEIN, who would himself typically be naked. During these encounters, EPSTEIN would escalate the nature and scope of the physical contact to include sex acts such as groping and direct and indirect contact with the victim's genitals. EPSTEIN would also typically masturbate during these encounters, ask victims
+
+to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys.
+
+16. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, paid the victim in cash. Victims typically were paid hundreds of dollars for each encounter.
+
+17. JEFFREY EPSTEIN, the defendant, knew that certain of his victims were underage, including because certain victims told him their age. In addition, as with New York-based victims, many Florida victims, once recruited, were abused by JEFFREY EPSTEIN, the defendant, on multiple additional occasions.
+
+18. JEFFREY EPSTEIN, the defendant, who during the relevant time period was frequently in New York, would arrange for Employee-2 or other employees to contact victims by phone in advance of EPSTEIN's travel to Florida to ensure appointments were scheduled for when he arrived. In particular, in certain instances, Employee-2 placed phone calls to minor victims in Florida to schedule encounters at the Palm Beach Residence. At the time of certain of those phone calls, EPSTEIN and Employee-2 were in New York, New York. Additionally, certain of the individuals victimized at the Palm Beach Residence were contacted by phone by Employee-3 to schedule these encounters.
+
+19. Moreover, as in New York, to ensure a steady stream of minor victims, JEFFREY EPSTEIN, the defendant, asked and enticed certain victims in Florida to recruit other girls to engage in sex acts. EPSTEIN paid hundreds of dollars to victimrecruiters for each additional girl they brought to the Palm Beach Residence.
+
+## STATUTORY ALLEGATIONS
+
+20. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York and elsewhere, JEFFREY EPSTEIN, the defendant, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to wit, sex trafficking of minors, in violation of Title 18, United States Code, Section. 1591(a) and (b).
+
+21. It was a part and object of the conspiracy that JEFFREY EPSTEIN, the defendant, and others known and unknown, would and did, in and affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, and obtain, by any means a person, and to benefit, financially and by receiving anything of value, from participation in a venture which has engaged in any such act, knowing that the person had not attained the age of 18 years and would be caused to engage in a
+
+commercial sex act, in violation of Title 18, United States Code, Sections 1591(a) and (b)(2).
+
+#### Overt Acts
+
+22. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere:
+
+a. In or about 2004, JEFFREY EPSTEIN, the defendant, enticed and recruited multiple minor victims, including minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3, to engage in sex acts with EPSTEIN at his residences in Manhattan, New York, and Palm Beach, Florida, after which he provided them with hundreds of dollars in cash for each encounter.
+
+b. In or about 2002, Minor Victim-1 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the New York Residence over <sup>a</sup> period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-1 to recruit other girls to engage in paid sex acts, which she did. EPSTEIN asked Minor Victim-1 how old she was, and Minor Victim-1 answered truthfully.
+
+c. In or about 2004, Employee-1, located in the Southern District of New York, and on behalf of EPSTEIN, placed
+
+<sup>a</sup>telephone call to Minor Victim-1 in order to schedule an appointment for Minor Victim-1 to engage in paid sex acts with EPSTEIN.
+
+d. In or about 2004, Minor Victim-2 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over <sup>a</sup> period of years and was paid hundreds of dollars after each encounter. EPSTEIN also encouraged and enticed Minor Victim-2 to recruit other girls to engage in paid sex acts, which she did.
+
+e. In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed <sup>a</sup>telephone call to Minor Victim-2 in order to schedule an appointment for Minor Victim-2 to engage in paid sex acts with EPSTEIN.
+
+f. In or about 2005, Minor Victim-3 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over <sup>a</sup> period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-3 to recruit other girls to engage in paid sex acts, which she did. EPSTEIN asked Minor Victim-3 how old she was, and Minor Victim-3 answered truthfully.
+
+In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to Minor Victim-3 in Florida in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN.
+
+h. In or about 2004, Employee-3 placed a telephone call to Minor Victim-3 in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN.
+
+(Title 18, United States Code, Section 371.)
+
+#### COUNT TWO (Sex Trafficking)
+
+The Grand Jury further charges:
+
+23. The allegations contained in paragraphs 1 through 19 and 22 of this Indictment are repeated and realleged as if fully set forth within.
+
+24. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York, JEFFREY EPSTEIN, the defendant, willfully and knowingly, in and affecting interstate and foreign commerce, did recruit, entice, harbor, transport, provide, and obtain by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act, and did aid and abet the same, to wit, EPSTEIN recruited, enticed, harbored, transported, provided, and obtained numerous
+
+individuals-who were less than 18 years old, including but not limited to Minor Victim-1, as described above, and who were then caused to engage in at least one commercial sex act in Manhattan, New York.
+
+> (Title 18, United States Code, Sections 1591(a), (b)(2), and 2.)
+
+#### FORFEITURE ALLEGATIONS
+
+25. As a result of committing the offense alleged in Count Two of this Indictment, JEFFREY EPSTEIN, the defendant, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 1594(c)(1), any property, real and personal, that was used or intended to be used to commit or to facilitate the commission of the offense alleged in Count Two, and any property, real or personal, constituting or derived from any proceeds obtained, directly or indirectly, as <sup>a</sup>result of the offense alleged in Count Two, or any property traceable to such property, and the following specific property:
+
+a. The lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 9 East 71st Street, New York, New York, with block number 1386 and lot number 10, owned by Maple, Inc.
+
+#### Substitute Asset Provision
+
+26. If any of the above-described forfeitable property, as a result of any act or omission of the defendant:
+
+- (a) cannot be located upon the exercise of due diligence;
+- (b) has been transferred or sold to, or deposited with, a third person;
+- (c) has been placed beyond the jurisdiction of the Court;
+- (d) has been substantially diminished in value; or
+- (e) has been commingled with other property which cannot be subdivided without difficulty;
+
+it is the intent of the United States, pursuant to 21 U.S.C. 853(p) and 28 U.S.C. § 2461(c), to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property.
+
+(Title 18, United States Code, Section 1594; Title 21, United States Code, Section 853(p); and Title 28, United States Code, Section 2461.)
+
+FOAEPERSON
+
+(t hs-GEOFFR Y BERMAN United States Attorney Form No. USA-33s-274 (Ed. 9-25-58)
+
+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+## UNITED STATES OF AMERICA
+
+v.
+
+JEFFREY EPSTEIN,
+
+Defendant.
+
+## 'INDICTMENT
+
+(18 U.S.C. §§ 371, 1591(a), (b)(2), and 2)
+
+> GEOFFREY S. BERMAN United States Attorney
+
+> > U 14/.0.I.GFCiowas

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marker2/court-redacted-v-indyke-10475/EFTA02777690/EFTA02777690.md

@@ -0,0 +1,242 @@
+### 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, and GHISLAINE MAXWELL,
+
+Defendants.
+
+I
+
+## COMPLAINT
+
+BOIES SCHILLER FLEXNER LLP
+
+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") and Ghislaine Maxwell ("Maxwell") (collectively, "Defendants"), 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 Defendants' sexual abuse of Plaintiff beginning when Plaintiff was 16 years old.
+- 2. When Plaintiff was 16, she was sexually trafficked by Defendants as part of Epstein and Maxwell's organized ring of procuring young women and girls for sex.
+- 3. Epstein's trafficking scheme involved recruiting young women and girls 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 and girls.
+- 4. As United States District Judge Kenneth Man 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 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 girls for himself for sex, and also lent these girls out to other powerful and wealthy individuals to be sexually abused.
+
+6. 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.
+
+7. The NPA allowed Epstein to escape proportionate punishment for his actions and to continue operating his sex trafficking enterprise with liberty.
+
+8. A few years later, Epstein flippantly referred to his sexual abuse of multiple young women and girls, 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 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 Jeffrey Epstein: I'm a Sex Offender Not a Predator, N.Y. Post (Feb. 25, 2011), https://nypost.com/2011/02/25/billionaire-jeffrey-epstein-im-a-sex-offender-not-a-predator/.
+
+9. 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.
+
+10. Maxwell spent years overseeing and managing Epstein's sex trafficking network, and actively recruited underage girls to provide to Epstein and others for sex.
+
+II. Epstein and Maxwell conspired with friends 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 girls a day for his sexual pleasure and Maxwell was in charge of recruiting the girls.
+
+12. Maxwell facilitated Epstein's sexual trafficking ring by activities including, but not limited to: (1) identifying and recruiting girls, including several minors, for Epstein's sexual pleasure and that of his co-conspirators, including herself; (2) identifying and hiring individuals to recruit underage girls; (3) scheduling appointments between the trafficked girls, many of whom were minors, and Epstein; (4) administering Epstein's sex trafficking organization and hiding it from criminal repercussions; and (5) intimidating girls, many of whom were minors, who attempted to escape or report Epstein's sex trafficking operation.
+
+13. Epstein and Maxwell committed sexual assault and battery upon Plaintiff when she was 16 years old. As such, the Defendants are responsible for battery, unlawful imprisonment, and intentional infliction of emotional distress pursuant to New York common law. The damage to Plaintiff has been severe and lasting.
+
+14. This action has been timely filed pursuant to the Child Victims Act, N.Y. C.P.L.R. § 214-g. The actions described herein constitute sexual offenses by Defendants under New York Penal Law Article 130, and were committed against Plaintiff when she was a child less than eighteen years of age, for which she suffered physical, psychological, and other injuries as a result.
+
+15. 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.
+
+16. 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 Defendants used to silence their many victims, including Plaintiff. Defendants' actions deprived Plaintiff of the opportunity to commence this lawsuit before Epstein's death. Until his death, Plaintiff feared that Epstein and his co-conspirators, including Maxwell, would harm her or her family, or ruin her life, if she came forward.
+
+17. Defendants are equitably estopped from asserting a statute of limitations defense. Allowing Defendants to do so would be unjust. Defendants intimidated each of their victims into silence by threatening their lives and their livelihoods. They therefore prevented Plaintiff from commencing this lawsuit before Epstein's 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
+
+- 18. Plaintiff is a citizen and resident of Texas.
+- 19. Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the Estate of Jeffrey E. Epstein.
+- 20. Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the Estate of Jeffrey E. Epstein.
+- 21. Defendant Ghislaine Maxwell is a New York citizen and is domiciled in the Southern District of New York.
+
+### JURISDICTION AND VENUE
+
+- 22. 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 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.
+- 23. Defendant Maxwell is a citizen of both the United States and the United Kingdom and is domiciled in the Southern District of New York.
+- 24. 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.
+- 25. Venue is proper in this Court as the sexual abuse of Plaintiff by Defendants Epstein and Maxwell began and occurred in New York, New York, where they recruited her at the age of 16, physically molested her, and began grooming her for sex in their organized sex trafficking ring.
+
+26. 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(bX2).
+
+## FACTUAL ALLEGATIONS
+
+### A. Epstein's Sex Traffickine Enterprise
+
+27. 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 coconspirators, and some of the most powerful people in the world.
+
+28. Epstein owned multiple residences and frequently travelled between them, including at 9 East 71' Street, New York, New York 10021, and at 49 Zorro 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, France, and even on his own island, Great St. James Island, where his transcontinental sex trafficking of hundreds of young girls servicing him, his co-conspirators, and wealthy and powerful individuals around the world occurred.
+
+29. The allegations herein concern Epstein's and Maxwell's tortious acts against Plaintiff while in New York, where Epstein was staying at his 71' Street mansion, and at his ranch in New Mexico.
+
+30. 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. 31. Epstein and Maxwell had perfected a scheme for manipulation and abuse of young females. As part of the scheme, Maxwell or another female 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. Maxwell 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 Maxwell'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, Maxwell 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 Maxwell continued to manipulate the victims, using their 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
+
+32. 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.
+
+33. 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.
+
+34. Epstein's last will and testament (the "Will") was executed on August 8, 2019, at the Metropolitan Correctional Center. The witnesses were Martel Colon Mire and Gulnora 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."
+
+35. Epstein was found dead in his cell at the Metropolitan Correctional Center on August 10, 2019.
+
+36. Epstein's last will and testament was filed on August 15, 2019, in the Probate Division of the Superior Court of the Virgin Islands.
+
+37. 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 ofJeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019).
+
+38. 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-I 9-PB-80 (Super. Ct. V.I. Sept. 6, 2019).
+
+39. 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."
+
+40. 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.
+
+C.
+
+• was born on July 2, 1979. parents divorced when she was young, and her mother struggled financially to support Annie and her siblings.
+
+42. In 1995 and 1996, Annie was a high school student at Xavier College Preparatory in Phoenix, Arizona. She was a top performing student with the goal of going to college.
+
+43. In approximately 1995, Annie's sister, . was an artist and a graduate student in New York. She met Epstein and Maxwell at an art show. Epstein noticed her artwork. Epstein offered to help her in her art career if she sold Epstein some of her artwork.
+
+44. Epstein asked Maria if she had a father. He also asked her personal questions about her family situation, including about her younger sister, Annie. Maria explained that her parents were divorced, and that she and her family were financially struggling.
+
+45. Maria accepted a job offer from Epstein to purchase art for him.
+
+46. Her role later included keeping records of people who entered Epstein's New York mansion. Maria observed that Defendant Maxwell was regularly bringing over school-aged girls to the New York mansion. Maxwell told Maria that these girls were interviewing for Victoria's Secret modeling positions.
+
+47. Maxwell described her role to Maria as recruiting Victoria's Secret models for Epstein. Maria witnessed Maxwell spotting girls and talking to them outside of the mansion, which Maxwell claimed was for recruiting purposes. Maxwell would leave the mansion claiming she had "to go get girls for Jeffrey."
+
+48. At the time, Maria was unaware of the sex trafficking conspiracy and believed the girls were being recruited for modeling positions.
+
+49. Annie understood her older sister, Maria, to be working for a billionaire in New York.
+
+50. Epstein began taking an interest in Annie. He asked Maria questions about her younger sister in Arizona. He presented this interest to Maria in a friendly and fatherly manner. Maria was very proud of Annie's strong academic record, and supported Annie's goal of going to a good college after high school.
+
+51. Epstein offered Maria ideas on how he could help Annie get into college. He used this as a ruse to get Annie to come to New York so that he could abuse her. Epstein purchased Annie's plane tickets, and she flew to New York.
+
+52. Epstein gave Maria money to buy Annie a dress. He paid for a limousine to pick up the sisters and take them to Epstein's townhome. He talked to Annie about going to college and potential schools before sending them to see a Broadway show.
+
+53. During Annie's stay in New York, Epstein asked Annie and Maria to go to the movie theater with him. This is where he began initiating non-consensual physical contact with Annie in an attempt to groom Annie for sexual activity and normalize sexual behavior with him.
+
+54. At the movie, Epstein intentionally positioned himself between the sisters to ensure they were separated, and to prevent Maria from seeing that he was touching Annie. Epstein began caressing and petting Annie on various parts of her body against her will. He would repeatedly touch Annie only when Maria was unaware and looking away. Annie was distressed, frightened, and confused.
+
+55. Annie then left to go back home to Arizona.
+
+56. Epstein began calling Annie and her mother from New York under the false pretense of discussing Annie's education and plans for college. He offered to send Annie on an international trip to help with her college applications.
+
+57. As part of his plan to recruit Annie for sexual purposes, Epstein explained to Annie's mother that he sponsored educational trips for high school students, and was sponsoring an event in New Mexico at his ranch called Zorro Ranch. He invited Annie. He explained that Maxwell would be a host or chaperone for Annie at the event. Under these false pretenses, Annie's mother agreed to send Annie to Epstein's program for high school students.
+
+58. Epstein and Maxwell, who were in New York at the time, arranged and paid for Annie to fly to New Mexico in the spring of 1996. Epstein mailed her airline tickets from New York to her mother in Arizona. When Annie arrived in New Mexico, Epstein had a driver take her to his ranch. Epstein's Zorro Ranch sits on over 10,000 acres and is very remote. Upon arriving at the ranch, Annie learned that Epstein had not invited any other students. She was the only person at the massive ranch in a different state, away from her family in Arizona, her sister in New York, and anyone she knew. She was alone with Maxwell and Epstein.
+
+59. Maxwell appeared charming and friendly to Annie. Upon arriving, Maxwell and Epstein took Annie shopping and lavished her with gifts, including beauty products and a pair of brand new cowboy boots. After returning to the ranch, Maxwell began pressuring Annie to touch Epstein and give him a foot massage. Annie was very scared and did not want to touch Epstein, but Maxwell was relentless and demanded that Annie massage Epstein. Both adults explained to Annie that it was just a massage, and attempted to normalize this sexual behavior with an adult to her.
+
+60. Epstein and Maxwell took Annie to a movie theater. While in line for the movie, Maxwell pulled down Epstein's sweatpants, exposing part of his buttocks. Both Epstein and Maxwell repeatedly fondled each other in front of Annie, trying to normalize sexual behavior to Annie, a child.
+
+61. In the movie theater in New Mexico, Epstein caressed and petted various parts of Annie's body against her will. Annie was incredibly scared, and did not know how to escape because she was a child alone with Epstein and Maxwell. Annie did not have a phone or any other means of communication without Epstein or Maxwell knowing.
+
+62. Epstein, Maxwell, and Annie returned to Epstein's ranch. Upon returning from the movie, Maxwell repeatedly told Annie that she wanted to give her a massage. Annie was very uncomfortable with the idea of Maxwell touching her, but realized that she was completely alone with Epstein and Maxwell. Annie feared what would happen if she did not comply with their demands. Annie said that she had never had a massage and tried to avoid having Maxwell touch her body, but Maxwell continued to pressure her. Maxwell directed Annie to take off all of her clothes and lay on the massage table. Annie was extremely scared to be naked in front of Epstein and Maxwell.
+
+63. Maxwell left the door open so that Epstein could view Annie's naked body during the massage.
+
+64. Maxwell touched intimate parts of Annie's body against her will for the sexual benefit of Maxwell and Epstein.
+
+65. Maxwell exposed Annie's breasts and groped her.
+
+66. Annie was extremely distressed and afraid. She was a child in a massive ranch in New Mexico, away from her family in Arizona, and isolated from any source of help. She was alone with Epstein and Maxwell. She had no way to access a phone or other method of communication without Epstein or Maxwell knowing. She had no way of leaving.
+
+67. Annie woke up the next morning to find Epstein entering her room. He climbed into the bed with her and announced, "I want to cuddle." Without her consent, Epstein got into the bed with Annie, physically restrained her with his arms and proceeded to press his body (including his genitals) against Annie. Annie was frozen in fear. She was sixteen years old.
+
+68. Annie knew she had no way of escaping Epstein's massive estate, and attempted to escape by saying she needed to use the restroom. She was in shock, and frightened by what she was experiencing. She feared for her safety, knowing she was alone in Epstein's ranch in another state and that Maxwell and Epstein were closely monitoring her activity.
+
+69. Annie escaped to Epstein's bathroom. She was in extreme fear and emotional distress, not knowing how to escape Epstein's ranch in New Mexico, where these two adults were groping her, a child, against her will.
+
+70. Epstein and Maxwell eventually allowed Annie to fly back home to Arizona and they returned to New York. Out of fear of what could happen to her and her family because of Epstein and Maxwell's great power, wealth, and connections that they had displayed to her, Annie did not tell anyone about Epstein and Maxwell touching her against her will.
+
+71. Devastatingly, Annie was not the only family member that Epstein and Maxwell sexually abused. During that summer, Maria was lured into an "artist in residence" position by Epstein at billionaire Les Wexner's Ohio estate on which Epstein owned a guest house. There, Epstein and Maxwell both sexually assaulted Maria. Wexner's security personnel did not allow Maria to exit his estate, even after she pleaded with them and told them about her assault. There was only one entrance with a guard house to Wexner's estate.
+
+72. After Maria's sexual assault in Ohio, Maxwell called on behalf of Epstein and threatened Maria in order to keep her quiet: "We're going to burn all your art. And I just want you to know that anything you ever make will be burned. Your career is burned."
+
+73. Instead of letting Maxwell's words silence her, Maria reported her assault to the Sixth Precinct of the New York City Police Department ("NYPD"). The NYPD referred Maria to the Federal Bureau of Investigation ("FBI"). Maria followed the instruction and called the FBI to make a report of the abuse. To the extreme detriment of Maria and Annie—and also countless other victims who came after them—authorities ignored Maria's reporting efforts and took no action.
+
+74. Maria also called Annie, who was overseas studying at an educational seminar for high performing high school students. During the call, Annie shared with Maria her own assaults in New York and New Mexico, as well as her false imprisonment at Epstein's New Mexico ranch.
+
+75. Frustrated that authorities did not appear to be taking any action and in the hopes of exposing the crimes that Maxwell and Epstein were committing, Annie and Maria decided to share their stories with Vanity Fair magazine. Tragically for Annie and Maria, Epstein threatened and intimidated the magazine and Vanity Fair bent to those threats and ultimately published a profile of Epstein without mentioning the sisters or their allegations.
+
+76. Once Maxwell and Epstein learned that Maria had revealed the abuse to Vanity Fair, they embarked on a campaign to destroy Maria's reputation and art career. Afraid for her safety, having informed the NYPD, FBI, and media to no avail, Maria left New York and Annie moved
+
+to Alaska. Annie and Maria's fear of Epstein's power was exacerbated by the fact that state and federal authorities, as well as the media, were not taking action against Epstein.
+
+77. Annie was deeply affected by her harrowing experiences at the hands of Epstein and Maxwell as a child. She suffers severe emotional distress from an experience that has affected her for her entire life.
+
+78. The Defendants' sexual assault, battery, and false imprisonment of Annie continue to cause her significant distress and harm.
+
+## FIRST CAUSE OF ACTION
+
+# (Battery)
+
+79. Plaintiff repeats and re-alleges the allegations stated above in paragraphs 1-78 as if fully set forth herein.
+
+80. Epstein and Maxwell intentionally committed battery by sexually assaulting Plaintiff when she was a young girl. As described above, on multiple occasions Epstein and Maxwell intentionally touched Plaintiff in an offensive and sexual manner without her consent.
+
+81. Epstein and Maxwell's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to forcible touching as defined in Article 130.52, inasmuch as Epstein and Maxwell intentionally and forcibly touched sexual and intimate parts of Plaintiff's body for their own sexual gratification on multiple occasions. See N.Y. C.P.L.R. § 214g.
+
+82. A criminal action against Epstein with respect to the same sex trafficking enterprise from which Plaintiff's 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).
+
+83. As a direct and proximate result of Epstein's and Maxwell's criminal acts, Plaintiff has in the past and will in the future continue to suffer extreme emotional distress, humiliation, fear, psychological trauma, loss of dignity and self-esteem, and invasion of her privacy.
+
+## SECOND CAUSE OF ACTION
+
+### (False Imprisonment)
+
+84. Plaintiff repeats and re-alleges the allegations stated above in paragraphs 1-78 as if fully set forth herein.
+
+85. As a direct result of these allegations as stated, Defendants falsely imprisoned Plaintiff at Epstein's New Mexico residence while Plaintiff was a young girl for the purpose of degrading her, abusing her, or gratifying their sexual desires.
+
+86. Epstein and Maxwell brought Plaintiff to Epstein's New Mexico Ranch with the intent to confine her in that location so that they could sexually abuse her. Plaintiff was conscious of her confinement and did not consent that confinement. Epstein and Maxwell prevented Plaintiff, a child with no way to communicate with anyone other than Epstein and Maxwell and with no access to a car or other means of transportation, from leaving the premises, Epstein's remote 10,000 acre Zorro Ranch in New Mexico.
+
+87. 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).
+
+88. As a direct and proximate result of Epstein and Maxwell's criminal acts, Plaintiff has in the past and will in the future continue to suffer extreme emotional distress, humiliation, fear, psychological trauma, loss of dignity and self-esteem, and invasion of her privacy.
+
+### THIRD CAUSE OF ACTION
+
+### (Intentional Infliction of Emotional Distress)
+
+89. Plaintiff repeats and re-alleges the allegations stated above in paragraphs 1-78 as if fully set forth herein.
+
+90. As a direct result of these allegations as stated, Defendants committed intentional infliction of emotional distress against Plaintiff.
+
+91. Defendants' actions, described above, constitute extreme and outrageous conduct that shocks the conscience. Epstein and Maxwell's plan to recruit, entice, and assault Plaintiff, a sixteen-year-old child, on multiple occasions, goes beyond all possible bounds of decency and is intolerable in a civilized community.
+
+92. Defendants knew or disregarded the substantial likelihood that these actions would cause Plaintiff severe emotional distress.
+
+93. A criminal action against Epstein with respect to the same sex trafficking enterprise from which Plaintiff's third 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).
+
+94. As a direct and proximate result of Epstein and Maxwell's criminal acts, Plaintiff has in the past and will in the future continue to suffer extreme emotional distress, humiliation, fear, 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 12, 2019.
+
+Is/ Joshua I. Schiller
+
+David Boies BOIES SCHILLER FLEXNER LLP 333 Main Street Armonk, NY 10504 (914) 749-8200
+
+Joshua I. Schiller BOWS SCHILLER FLEXNER LLP 55 Hudson Yards New York, NY 10001 (212) 446-2300
+
+Sigrid McCawley (Pro Hac Vice Pending) BOWS SCHILLER FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011

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marker2/court-redacted-v-indyke-10475/EFTA02777709/EFTA02777709.md

@@ -0,0 +1,118 @@
+JS 44C/SDNY REV. 08/01/17
+
+PI AINTIFFS
+
+The JS-44 OW cover sheet and the information contained herein nether replace nor supplement the Sling and smite of pleadings or other papers as required by law, except as provided by love rules of coon This lemi, approved by the Judicial Conference of Me United States in September 1974.1 required for use of IN Clerk of Court for the purpose of inibabrig the chi docket sheet
+
+ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER Joshua I. SchiNer Boles Schiller Flexner LLP 55 Hudson Yards. New York, NY 10001 (212) 446-2300
+
+CIFFFNDANTS DARREN K. INDYKE and RICHARD D. KAHN. in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN and GHISLAINE MAXWELL ATTORNEYS (IF KNOWN) Bennet J. Moskowitz (attorney for Darren K. Indyke and Richard D. Kahn) 875 Third Avenue New York, NY 10022
+
+CAUSE OF ACTION (CITE THE U.S. CML STATUTE UNDER WHICH YOU ARE FILING AND KR ITE A BRIEF STATEMENT OF CAM) (DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)
+
+28 U.S.C. § 1332: New York causes of action
+
+Has this action. case. Of proceeding, or one essentially the same been previously filed in SONY at any time? No6:Nes O Judge Previously Assigned
+
+If yes, was this case Vol O Incl. O Dismissed. NO ❑ Yes O If yes. give dale 8. Case No.
+
+Is MS AN iNTIMATIONAL ARBITRATION CAW No El Yes D
+
+(PLACE AN(xf IN ONE BOX ONLY)
+
+TORTS
+
+| CONTRACT | PERSONAL INJURY                                     | PERSONAL INJURY<br>[ ] 367 HEALTH CARE/<br>PHARMACEUTICAL PERSONAL<br>INJURY/PRODUCT LIABILITY<br>[ ] 365 PERSONAL INJURY<br>PRODUCT LIABILITY<br>[ ] 368 ASBESTOS PERSONAL<br>INJURY PRODUCT<br>LIABILITY | FORFEITURE/PENALTY                              | BANKRUPTCY                                  | OTHER STATUTES                                                           |
+|----------|-----------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------|---------------------------------------------|--------------------------------------------------------------------------|
+| [ ] 110  | INSURANCE                                           | [ ] 310 AIRPLANE                                                                                                                                                                                           | [ ] 625 DRUG RELATED                            | [ ] 422 APPEAL                              | [ ] 375 FALSE CLAIMS                                                     |
+| [ ] 120  | MARINE                                              | [ ] 315 AIRPLANE PRODUCT                                                                                                                                                                                   | SEIZURE OF PROPERTY                             | 28 USC 158                                  | [ ] 378 QUI TAM                                                          |
+| [ ] 130  | [ ] ACT                                             | LIABILITY                                                                                                                                                                                                  | 21 USC 881                                      | [ ] 423 WITHDRAWAL                          | [ ] 400 STATE                                                            |
+| [ ] 140  | NEGOTIABLE INSTRUMENT                               | [ ] 320 ASSAULT, LIBEL & SLANDER                                                                                                                                                                           | [ ] 690 OTHER                                   | 28 USC 157                                  | REAPPORTIONMENT                                                          |
+| [ ] 150  | RECOVERY OF OVERPAYMENT & ENFORCEMENT OF JUDGMENT   | [ ] 330 FEDERAL EMPLOYERS' LIABILITY                                                                                                                                                                       | PROPERTY RIGHTS                                 | [ ] 410 ANTITRUST                           | [ ] 410 ANTITRUST                                                        |
+| [ ] 150  | MEDICARE ACT                                        | [ ] 340 MARINE                                                                                                                                                                                             | [ ] 620 COPYRIGHTS                              | [ ] 430 BANKS & BANKING                     | [ ] 430 BANKS & BANKING                                                  |
+| [ ] 151  | RECOVERY OF DEFAULTED STUDENT LOANS (EXCL VETERANS) | [ ] 345 MARINE PRODUCT LIABILITY                                                                                                                                                                           | [ ] 830 PATENT                                  | [ ] 450 COMMERCE                            | [ ] 450 COMMERCE                                                         |
+| [ ] 152  | RECOVERY OF DEFAULTED STUDENT LOANS (EXCL VETERANS) | [ ] 350 MOTOR VEHICLE PRODUCT LIABILITY                                                                                                                                                                    | [ ] 835 PATENT-ABBREVIATED NEW DRUG APPLICATION | [ ] 460 DEPORTATION                         | [ ] 470 RACKETEER INFLU-ENCED & CORRUPT ORGANIZATION ACT (RICO)          |
+| [ ] 153  | RECOVERY OF OVERPAYMENT OF VETERANS BENEFITS        | [ ] 365 MOTOR VEHICLE PRODUCT LIABILITY [ ] 360 OTHER PERSONAL INJURY                                                                                                                                      | [ ] 840 TRADEMARK                               | [ ] 480 CONSUMER CREDIT                     | [ ] 490 CABLE/SATELLITE TV                                               |
+| [ ] 160  | STOCKHOLDERS SUITS                                  | [ ] 362 PERSONAL INJURY - MED MALPRACTICE                                                                                                                                                                  | [ ] 830 PATENT                                  | [ ] 851 HIA (1396ff)                        | [ ] 850 SECURITIES/ COMMODITIES/ EXCHANGE                                |
+| [ ] 160  | STOCKHOLDERS SUITS                                  | [ ] 365 PROPERTY DAMAGE PRODUCT LIABILITY                                                                                                                                                                  | [ ] 710 FAIR LABOR STANDARDS ACT                | [ ] 863 DIV/CDIWW (405(g))                  | [ ] 890 OTHER STATUTORY ACTIONS                                          |
+| [ ] 190  | OTHER CONTRACT CONTRACT PRODUCT LIABILITY           | [ ] 520 HABEAS CORPUS CORPUS                                                                                                                                                                               | [ ] 720 LABOR/MGMT RELATIONS                    | [ ] 865 RSI (405(g))                        | [ ] 890 OTHER STATUTORY ACTIONS                                          |
+| [ ] 195  | CONTRACT CONTRACT PRODUCT LIABILITY                 | [ ] 463 ALIEN DETAINEE                                                                                                                                                                                     | [ ] 740 RAILWAY LABOR ACT                       | [ ] 871 IRS-THIRD PARTY                     | [ ] 891 AGRICULTURAL ACTS                                                |
+| [ ] 195  | CONTRACT CONTRACT PRODUCT LIABILITY                 | [ ] 510 MOTIONS TO VACATE SENTENCE 28 USC 2255                                                                                                                                                             | [ ] 751 FAMILY MEDICAL LEAVE ACT (FMLA)         | [ ] 870 TAKES (U.S. Plaintiff or Defendant) | [ ] 893 ENVIRONMENTAL MATTERS                                            |
+| [ ] 196  | FRANCHISE                                           | [ ] 535 DEATH PENALTY                                                                                                                                                                                      | [ ] 791 EMPL RET INC (FMLA)                     | [ ] 871 IRS-THIRD PARTY 28 USC 7609         | [ ] 895 FREEDOM OF INFORMATION ACT                                       |
+|          |                                                     | [ ] 540 MANDAMUS & OTHER (Non-Prisoner)                                                                                                                                                                    | [ ] 750 OTHER LABOR LITIGATION                  | [ ] 875 TAKES (U.S. Plaintiff or Defendant) | [ ] 899 ADMINISTRATIVE PROCEDURE ACT/REVIEW OR APPEAL OF AGENCY DECISION |
+|          |                                                     | [ ] 440 OTHER CIVIL RIGHTS (Non-Prisoner)                                                                                                                                                                  | [ ] 791 EMPL RET INC (FMLA)                     | [ ] 875 TAKES (U.S. Plaintiff or Defendant) | [ ] 950 CONSTITUTIONALITY OF STATE STATUTES                              |
+|          |                                                     | [ ] 440 OTHER CIVIL RIGHTS (Non-Prisoner)                                                                                                                                                                  | [ ] 750 OTHER LABOR LITIGATION                  | [ ] 870 TAKES (U.S. Plaintiff or Defendant) | [ ] 895 FREEDOM OF INFORMATION ACT                                       |
+|          |                                                     | [ ] 440 OTHER CIVIL RIGHTS (Non-Prisoner)                                                                                                                                                                  | [ ] 751 FAMILY MEDICAL LEAVE ACT (FMLA)         | [ ] 870 TAKES (U.S. Plaintiff or Defendant) | [ ] 890 OTHER STATUTORY ACTIONS                                          |
+|          |                                                     | [ ] 540 MANDAMUS & OTHER (Non-Prisoner)                                                                                                                                                                    | [ ] 791 EMPL RET INC (FMLA)                     | [ ] 871 IRS-THIRD PARTY 28 USC 7609         | [ ] 895 FREEDOM OF INFORMATION ACT                                       |
+|          |                                                     | [ ] 440 OTHER CIVIL RIGHTS (Non-Prisoner)                                                                                                                                                                  | [ ] 750 OTHER LABOR LITIGATION                  | [ ] 870 TAKES (U.S. Plaintiff or Defendant) | [ ] 899 ADMINISTRATIVE PROCEDURE ACT/REVIEW OR APPEAL OF AGENCY DECISION |
+|          |                                                     | [ ] 440 OTHER CIVIL RIGHTS (Non-Prisoner)                                                                                                                                                                  | [ ] 750 OTHER LABOR LITIGATION                  | [ ] 871 IRS-THIRD PARTY 28 USC 7609         | [ ] 950 CONSTITUTIONALITY OF STATE STATUTES                              |
+|          |                                                     | [ ] 440 OTHER CIVIL RIGHTS (Non-Prisoner)                                                                                                                                                                  | [ ] 790 OTHER LABOR LITIGATION                  | [ ] 875 TAKES (U.S. Plaintiff or Defendant) | [ ] 895 FREEDOM OF INFORMATION ACT                                       |
+|          |                                                     | [ ] 440 OTHER CIVIL RIGHTS (Non-Prisoner)                                                                                                                                                                  | [ ] 790 OTHER LABOR LITIGATION                  | [ ] 875 TAKES (U.S. Plaintiff or Defendant) | [ ] 950 CONSTITUTIONALITY OF STATE STATUTES                              |
+|          |                                                     | [ ] 440 OTHER CIVIL RIGHTS (Non-Prisoner)                                                                                                                                                                  | [ ] 700 FEDERAL TAX SUITS                       | [ ] 895 ENVIRONMENTAL MATTERS               | [ ] 895 FREEDOM OF INFORMATION ACT                                       |
+|          |                                                     | [ ] 440 OTHER CIVIL RIGHTS (Non-Prisoner)                                                                                                                                                                  | [                                               |                                             |                                                                          |
+
+NATURE OF SUIT
+
+O
+
+a
+
+ACTIONS UNDER STATUTES
+
+Check if demanded in complaint.
+
+n CHECK IF THIS IS A CLASS ACTION UNDER F.R.C.P. 23
+
+DEMAND \$ OTHER JUDGE DOCKET NUMBER
+
+Check YES only if demanded in complaint
+
+JURY DEMAND: a YES 510
+
+DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.O.N.Y. AS DEFINED BY LOCAL RULE FOR DIVISION OF BUSINESS 13? IF SO, STATE:
+
+NOTE. You must also submit at the lime of filing the Statement of Relatedness form (Form IH-32).
+
+0 1 Ongind 02 Removed from 03 Remanded 0 4 Reinstated c O 5 Trend wed from O 6 M"Illtna 7 Ants to District Proceeding Slate Court from Reopened (SPecity District) litigation 1,--, Judge from Appetite (Transferred) Magistrate Judge 0 a. ad dirges 'preowned Court O8 Muttelistna Lagabm (Direct File) O b. At least one petty Is pron.
+
+## (PLACE AN x IN ONE BOX ONLY) BASIS OF JURISDICTION IF DIVERSITY, INDICATE
+
+01 U.S. PLAINTIFF O 2 U.S. DEFENDANT 0 3 FEDERAL QUESTION 04 DIVERSITY CITIZENSHIP BELOW. (U.S. NOT A PARTY)
+
+## CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)
+
+(Place an (X) in one box for Plaintiff and one box for Defendant)
+
+PTF DEF PTF DEF PTF DEF CITIZEN OF THIS STATE I II ( 11 CITIZEN OR SUBJECT OF A [13[ 13 INCORPORATED and PRINCIPAL PLACE [ I 5 f I 5 FOREIGN COUNTRY OF BUSINESS IN ANOTHER STATE CITIZEN OF ANOTHER STATE [td 2 latj 2 INCORPORATED or PRINCIPAL PLACE [ I 4 [ I4 FOREIGN NATION [ IS I )6 OF BUSINESS IN THIS STATE
+
+PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)
+
+1907 North Lamar Boulevard Suite 240 Austin, TX 78705
+
+DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)
+
+Darren K. Indyke, Richard D. Kahn: U.S. Virgin Islands Ghislaine Maxwell: 116 East 65th Street, New York, NY 10065
+
+DEFENDANT(S) ADDRESS UNKNOWN
+
+REPRESENTATION IS HEREBY MADE THAT. AT THIS TIME. I HAVE BEEN UNABLE. WITH REASONABLE DILIGENCE. TO ASCERTAIN THE RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:
+
+Darren K. lndyke and Richard D. Kahn are sued as executors of the Estate of Jeffrey Epstein. Per 28 U. S.C. § 1332, Defendants are deemed citizens of the U.S. Virgin Islands (USVI), decedent Epstein's domicile. Defendants' residential addresses are unknown to Plaintiff. Their counsel is listed above.
+
+O
+
+### COURTHOUSE ASSIGNMENT
+
+I hereby certify that this case should be assigned to the courthouse indicated below pursuant to Local Rule for Division of Business 18, 20 or 21.
+
+Check one: THIS ACT(jON HOULD 3B S ED O: D PLAINS QMANHATTAN
+
+DATE 11/12/2019 SI qTT Y OF RE ORD ADMITTED TO PRACTICE IN THIS DISTRICT
+
+NO pd YES (DATE ADMITTED Mo.08 Yr. 2009 ) RECEIPT # Attorney Bar Code a JS3315
+
+Magistrate Judge is to be designated by the Clerk of the Court.
+
+Magistrate Judge is so Designated.
+
+Ruby J. Krajick, Clerk of Court by Deputy Clerk, DATED

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marker2/court-redacted-v-indyke-10475/EFTA02777711/EFTA02777711.md

@@ -0,0 +1,63 @@
+## UNITED STATES DISTRICT COURT
+
+for the
+
+Southern District of New York
+
+Plaintiff(s)
+
+v.
+
+DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREYEDWARD EPSTEIN, and GHISLAINE MAXWELL
+
+Defendant(s)
+
+Civil Action No.
+
+## SUMMONS IN A CIVIL ACTION
+
+To: (Defendant's name and address) Darren K. Indyke and Richard D. Kahn do Bennet J. Moskowitz, attorney 875 Third Avenue New York, NY 10022
+
+A lawsuit has been filed against you.
+
+Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (aX2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: Joshua Schiller
+
+Boies Schiller Flexner LLP 55 Hudson Yards New York, NY 10001 (212)446-2300 jischilleriabalp.com
+
+If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
+
+Date:
+
+CLERK OF COURT
+
+Signature of Clerk or Deputy Clerk
+
+Civil Action No.
+
+## PROOF OF SERVICE
+
+(This section should not be filed with the court unless required by Pet R. Civ. P. 4 (1))
+
+This summons for (name of individual and title. ij any) was received by me on (dare)
+
+O I personally served the summons on the individual at (mace) on (date) ; or
+
+O I left the summons at the individual's residence or usual place of abode with (name) , a person of suitable age and discretion who resides there, on (date) , and mailed a copy to the individual's last known address; or
+
+O I served the summons on (name of individual) designated by law to accept service of process on behalf of (name of organization) on (date) ; or , who is
+
+O I returned the summons unexecuted because ; or
+
+O Other (specify):
+
+My fees are \$ for travel and for services, for a total of \$ 0.00
+
+I declare under penalty of perjury that this information is true.
+
+Date: Server's signature
+
+Printed name and title
+
+Server's address
+
+Additional information regarding attempted service, etc:

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marker2/court-redacted-v-indyke-10475/EFTA02777713/EFTA02777713.md

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+## UNITED STATES DISTRICT COURT
+
+for the
+
+Southern District of New York
+
+Plaintiffis)
+
+v.
+
+DARREN K. INDYKE, RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL
+
+Defendant(s)
+
+Civil Action No.
+
+## SUMMONS IN A CIVIL ACTION
+
+To: (Defendant's name and address) Ghislaine Maxwell 116 East 65th Street New York, NY 10065
+
+A lawsuit has been filed against you.
+
+Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (aX2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: Joshua Schiller
+
+Boies Schiller Flexner LLP 55 Hudson Yards New York, NY 10001 (212) 446-2300 jischiller@bsfllp.com
+
+If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
+
+Date:
+
+CLERK OF COURT
+
+Signature of Clerk or Deputy Clerk
+
+Civil Action No.
+
+## PROOF OF SERVICE
+
+(This section should not be filed with the court unless required by Fed R. Civ. P. 4 (1))
+
+This summons for (name of individual and title. ij any) was received by me on (date)
+
+O I personally served the summons on the individual at (place) on (date) ; or
+
+O I left the summons at the individual's residence or usual place of abode with (name) , a person of suitable age and discretion who resides there, on (date) , and mailed a copy to the individual's last known address; or
+
+O I served the summons on (name of individual) designated by law to accept service of process on behalf of (name of organization) on (date) ; or , who is
+
+O I returned the summons unexecuted because ; or
+
+O Other (speciM:
+
+My fees are \$ for travel and \$ for services, for a total of \$ 0.00
+
+I declare under penalty of perjury that this information is true.
+
+Date: Server's .signature
+
+Printed name and title
+
+Server's address
+
+Additional information regarding attempted service, etc:

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marker2/court-redacted-v-indyke-10475/EFTA02777715/EFTA02777715.md

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+# UNITED STATES DISTRICT COURT
+
+for the
+
+Southern District of New York
+
+![](_page_0_Picture_138.jpeg)
+
+*Plaintiff(s)*
+
+v.
+
+DARREN K. INDYKE and RICHARD D. KAHN,  
+in their capacities as the executors of the  
+ESTATE OF JEFFREYEDWARD EPSTEIN,  
+and GHISLAINE MAXWELL
+
+*Defendant(s)*
+
+)  
+)  
+)  
+)  
+)  
+)  
+)  
+)  
+)  
+)  
+)  
+)  
+)  
+)  
+)
+
+Civil Action No.
+
+## SUMMONS IN A CIVIL ACTION
+
+To: *(Defendant's name and address)* Darren K. Indyke and Richard D. Kahn  
+c/o Bennet J. Moskowitz, attorney  
+875 Third Avenue  
+New York, NY 10022
+
+A lawsuit has been filed against you.
+
+Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are:
+
+Joshua Schiller  
+Boies Schiller Flexner LLP  
+55 Hudson Yards  
+New York, NY 10001  
+(212) 446-2300  
+jischiller@bsfllp.com
+
+If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
+
+CLERK OF COURT
+
+Date: 11/13/2019
+
+/s/ P. Canales
+
+*Signature of Clerk or Deputy Clerk*
+
+![]()Civil Action No.
+
+## PROOF OF SERVICE
+
+(This section should not be filed with the court unless required by Fet R. Civ. P. 4 (1))
+
+This summons for (name of-individual and title. ijany) was received by me on (date)
+
+O I personally served the summons on the individual at (mace/ on (date) ; or
+
+O I left the summons at the individual's residence or usual place of abode with (name) , a person of suitable age and discretion who resides there, on (date) , and mailed a copy to the individual's last known address; or
+
+O I served the summons on (name of individual) designated by law to accept service of process on behalf of (name of organization) on (date) ; or , who is
+
+O I returned the summons unexecuted because ; or
+
+O Other (speciM:
+
+My fees are \$ for travel and \$ for services, for a total of \$ 0.00
+
+I declare under penalty of perjury that this information is true.
+
+Date: Server's signature
+
+Printed name and title
+
+Server's address
+
+Additional information regarding attempted service, etc:

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marker2/court-redacted-v-indyke-10475/EFTA02777717/EFTA02777717.md

@@ -0,0 +1,92 @@
+# UNITED STATES DISTRICT COURT
+
+for the
+
+Southern District of New York
+
+![](_page_0_Picture_134.jpeg)
+
+*Plaintiff(s)*
+
+v.
+
+DARREN K. INDYKE, RICHARD D. KAHN,  
+in their capacities as the executors of the  
+ESTATE OF JEFFREY EDWARD EPSTEIN,  
+and GHISLAINE MAXWELL
+
+*Defendant(s)*
+
+)  
+)  
+)  
+)  
+)  
+)  
+)  
+)  
+)  
+)  
+)  
+)  
+)  
+)
+
+Civil Action No.
+
+## SUMMONS IN A CIVIL ACTION
+
+To: *(Defendant's name and address)* Ghislaine Maxwell  
+116 East 65th Street  
+New York, NY 10065
+
+A lawsuit has been filed against you.
+
+Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are:
+
+Joshua Schiller  
+Boies Schiller Flexner LLP  
+55 Hudson Yards  
+New York, NY 10001  
+(212) 446-2300  
+jischiller@bsfllp.com
+
+If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
+
+CLERK OF COURT
+
+Date: 11/13/2019
+
+/s/ P. Canales
+
+*Signature of Clerk or Deputy Clerk*
+
+![]()Civil Action No,
+
+## PROOF OF SERVICE
+
+(This section should not be filed with the court unless required by Pet R. Civ. P. 4 (1))
+
+This summons for (name of-individual and title. if any) was received by me on (date)
+
+O I personally served the summons on the individual at (place) on (date) ; or
+
+O I left the summons at the individual's residence or usual place of abode with (name) , a person of suitable age and discretion who resides there, on (date) , and mailed a copy to the individual's last known address; or
+
+O I served the summons on (name of individual) designated by law to accept service of process on behalf of (name of organization) on (date) ; or , who is
+
+O I returned the summons unexecuted because ; or
+
+O Other (specify):
+
+My fees are \$ for travel and \$ for services, for a total of S 0.00
+
+I declare under penalty of perjury that this information is true.
+
+Date: Server's signature
+
+Printed name and title
+
+Server's address
+
+Additional information regarding attempted service, etc:

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marker2/court-redacted-v-indyke-10475/EFTA02777719/EFTA02777719.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_\_\_\_\_\_\_\_\_ x
+
+Plaintiff(s), :
+
+USDC SONY DOCUMENT ELECTRONICALLY PILED DOC I+: DATE FILED: November 1\$, 2019
+
+19 Civ. 10475(LGS)
+
+-against- ORDER
+
+Darren K. Indyke, et al.,
+
+Defendant(s), : \_\_\_\_\_\_\_\_\_\_\_\_\_\_ ------------- -------- X
+
+LORNA G. SCHOFIELD, District Judge:
+
+This case has been assigned to me for all purposes. It is hereby ORDERED that counsel for all parties appear for an initial pretrial conference with the Court at the time and place listed below. All pretrial conferences must be attended by the attorney who will serve as principal trial counsel. Parties who are not local (within the Metropolitan tri-state area) may request to attend by phone by filing a letter motion via ECF. Any open legal issues can be addressed at the conference.
+
+All parties are required to register promptly as filing users on ECF. Counsel are further required to review and comply with the Court's Individual Rules and Procedures ("Individual Rules") (available at the Court's website, hup://nysd.uscourts.gov/judge/Schofield).
+
+Counsel are directed to confer with each other prior to the conference regarding settlement and each of the other subjects to be considered at a Fed. R. Civ. P. 16 conference. Additionally, in accordance with the Court's Individual Rules, the parties are hereby ORDERED to prepare a joint Proposed Civil Case Management Plan and Scheduling Order in the form available at the Court's website (http://nysd.uscourts.gov/judge/Schofield) and append it to their joint letter described below. The parties must propose dates for the various deadlines even if they intend to request a stay of discovery.
+
+IT IS FURTHER ORDERED that the parties shall file a joint letter on ECF at least seven calendar days prior to the initial pre-trial conference, not to exceed 5 pages, providing the following information in separate paragraphs:
+
+- (1) A brief statement of the nature of the case, the principal claims and defenses, and the major legal and factual issues that are most important to resolving the case, whether by trial, settlement or dispositive motion;
+- (2) A brief statement by plaintiff as to the basis of subject matter jurisdiction and venue, and a brief statement by each other party as to the presence or absence of subject matter jurisdiction and venue. Statements shall include citations to relevant statutes.
+
+In addition, in cases for which subject matter jurisdiction is founded on diversity of citizenship, the parties shall explain the factual basis for such jurisdiction, including (i) in the case of a corporation, the principal place of business and place of incorporation, (ii) in the case of a partnership, limited liability company or trust, the citizenship of each of the entity's members, shareholders, partners and/or trustees. If this information is lengthy, it may be included in an Appendix to the letter, not to be included in the page limit.
+
+- (3) A brief description of any (i) motions that any party seeks or intends to file, including the principal legal and other grounds in support of and opposition to the motion, (ii) pending motions and (iii) other applications that are expected to be made at the status conference;
+- (4) A brief description of any discovery that has already taken place, and any discovery that is likely to be admissible under the Federal Rules of Evidence and material to proof of claims and defenses raised in the pleadings. (This is narrower than the general scope of discovery stated in Rule 26(bX1));
+- (5) A computation of each category of damages claimed, see Fed. R. Civ. P. 26(a)(1)(A)(iii);
+- (6) A statement describing the status of any settlement discussions and whether the parties would like a settlement conference; and
+- (7) Any other information that the parties believe may assist this Court in resolving the action.
+
+If this case has been settled or otherwise terminated, counsel are not required to appear, provided that a stipulation of discontinuance, voluntary dismissal, or other proof of termination is sent prior to the date of the conference via email to the Orders and Judgment Clerk at the following email address: orders\_andjudgments@nysd.uscourts.gov.
+
+Any request for an extension or adjournment shall be made only by letter as provided in Individual Rule I.B.2 and must be received at least 48 hours before the deadline or conference. Unless counsel are notified that the conference has been adjourned, it will be held as scheduled.
+
+Counsel who have noticed an appearance as of the issuance of this order are directed (i) to notify all other parties' attorneys in this action by serving upon each of them a copy of this order and the Court's Individual Rules forthwith, and (ii) to file proof of such notice with the Court. If unaware of the identity of counsel for any of the parties, counsel receiving this order must send a copy of this order and Individual Rules to that party personally.
+
+**DATE AND PLACE OF CONFERENCE:** January 9, 2020 at **10:40 a.m**, in **Courtroom 1106** of the United States District Court for the Southern District of New York, Thurgood Marshall U.S. Courthouse at **40 Foley Square**, New York, New York. Please monitor the docket the day before the conference, as the time may change slightly.
+
+Dated: November 18, 2019  
+New York, New York
+
+![]()

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marker2/court-redacted-v-indyke-10475/EFTA02777722/EFTA02777722.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+Plaintiff,
+
+vs.
+
+DARREN I. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL,
+
+Defendants.
+
+Case No. 1:19-cv- 10475 (LGS)
+
+## NOTICE OF APPEARANCE
+
+PLEASE TAKE NOTICE that the undersigned attorney, David Boies, who is a member in good standing of the bar of this Court, hereby appears as counsel for Plaintiff in the above-captioned proceeding.
+
+Dated: New York, New York November 20, 2019
+
+BOLES SCHILLER FLEXNER LLP
+
+By: /s/ David Boies David Boies 333 Main Street Armonk, NY 10504 Telephone: (914) 749-8200 Fax: (914) 749-8300 dboies@bsflIp.com
+
+Attorney for Plainta

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marker2/court-redacted-v-indyke-10475/EFTA02777723/EFTA02777723.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+Plaintiff,
+
+VS.
+
+DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL,
+
+Defendants.
+
+Case No. 1:19-cv-10475 (LGS)
+
+DECLARATION OF SIGRID S. MCCAWLEY IN SUPPORT OF APPLICATION FOR ADMISSION PRO HAC VICE
+
+I, Sigrid S. McCawley, hereby declare as follows:
+
+- I. I have never been convicted of a felony.
+- 2. I have never been censured, suspended, disbarred or denied admission or readmission by any court.
+- 3. There are no pending disciplinary proceedings against me in any state or federal court.
+- 4. I am a member in good standing of the bar of the State of Florida.
+
+I hereby declare under penalty of perjury that the foregoing statements are true and correct.
+
+Dated: November 21, 2019 Respectfully Submitted,
+
+/s/ SiRrid S. McCawlev
+
+Sigrid S. McCawley
+
+Boles Schiller Flexner LLP
+
+401 E. Las Olas Boulevard, Suite 1200
+
+Fort Lauderdale, FL 33301
+
+Tel: (954) 356-0011
+
+Fax: (954) 356 0022
+
+Email: smccawley@bsfllp.com
+
+Counsel for Plaintiff

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marker2/court-redacted-v-indyke-10475/EFTA02777724/EFTA02777724.md

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+# Supreme Court of Florida Certificate of Good Standing
+
+*I JOHN A. TOMASINO, Clerk of the Supreme Court of the State of Florida, do hereby certify that*
+
+**SIGRID [REDACTED] MCCAWLEY**
+
+*was admitted as an attorney and counselor entitled to practice law in all the Courts of the State of Florida on November 6, 1997, is presently in good standing, and that the private and professional character of the attorney appear to be good.*
+
+*WITNESS my hand and the Seal of the Supreme Court of Florida at Tallahassee, the Capital, this November 20, 2019.*
+
+![](_page_0_Picture_62.jpeg)
+
+![]()*Clerk of the Supreme Court of Florida.*

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marker2/court-redacted-v-indyke-10475/EFTA02777725/EFTA02777725.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+Plaintiff, VS. DARREN K. INDYICE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL, Defendants.
+
+Case No. 1:19-cv-10475 (LGS)
+
+## ORDER FOR ADMISSION PRO HAC VICE
+
+The motion of Sigrid S. McCawley, for admission to practice Pro Hac Vice in the above captioned action is granted.
+
+Applicant has declared that she is a member in good standing of the bar of the State of Florida; and that her contact information is as follows:
+
+Sigrid S. McCawley Boies Schiller Flexner LLP 401 E. Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 33301 Telephone: (954) 356-0011 Fax: (954) 356-0022 smccawley@bsfilp.com
+
+Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Plaintiff in the above entitled action;
+
+IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York.
+
+All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys.
+
+Dated:
+
+United States District Judge

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marker2/court-redacted-v-indyke-10475/EFTA02777727/EFTA02777727.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+Plaintiff,
+
+VS.
+
+DARREN INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL,
+
+Defendants.
+
+Case No. l :19-cv- 10475 (LGS)
+
+## MOTION FOR ADMISSION PRO HAC VICE
+
+Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern Districts of New York, I, Sigrid S. McCawley, hereby move this Court for an Order for Admission to practice Pro Hac Vice to appear as counsel for Plaintiff, in the above-captioned action.
+
+I am in good standing in the bar of the State of Florida and there are no pending disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3.
+
+Dated: November 21, 2019 Respectfully Submitted,
+
+/s/ Sigrid S. McCawlev
+
+Sigrid S. McCawley Boies Schiller Flexner LLP 401 E. Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 33301 Tel: (954) 356-0011 Fax: (954) 356 0022 Email: smccawlev@bsfilp.com

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marker2/court-redacted-v-indyke-10475/EFTA02777728/EFTA02777728.md

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+AO 399 i0 l: (NI %Val tr of the SET% Ice of Summons
+
+## UNITED STATES DISTRICT COURT
+
+for the
+
+Southern District of New York
+
+Plaintiff
+
+v.
+
+Darren I Indyke et al
+
+E14/ fiqUialll
+
+To: David Boles
+
+Civil Action No. 1:19-cv-10475-LGS
+
+## WAIVER OF THE SERVICE OF SUMMONS
+
+(Name of the plaintiff's attorney or unrepresented plaintiff)
+
+1 have received your request to waive service of a summons in this action along with a copy of the complaint, two copies of this waiver form, and a prepaid means of returning one signed copy of the form to you.
+
+I. or the entity I represent. agree to save the expense of serving a summons and complaint in this case.
+
+I understand that I, or the entity I represent. will keep all defenses or objections to the lawsuit, the court's jurisdiction, and the venue of the action, but that I waive any objections to the absence of a summons or of service.
+
+I also understand that I. / the entity I represent, must file and serve an answer or a motion under Rule 12 within 60 days from it/ 7214 , the date when this request was sent (or 90 days if it was sent outside the United States). If I fail to do so, a default judgment will be entered against me or the entity I represent.
+
+Date: /1 /2 5/1 9
+
+Darren Indyke and Richard D. Kahn
+
+Printed name ofparty waiving service of summons
+
+Signature of the attorney or unrepresented party
+
+Bennet Moskowitz
+
+Printed name
+
+Troutman Sanders LLP 875 Third Avenue. New York. NY 10022
+
+Address
+
+Bennet.Moskowitz@troutman.com
+
+(212) 704-6087
+
+E-mail address
+
+Telephone number
+
+## Duty to Avoid Unnecessary Expenses of Serving a Summons
+
+Rule 4 of the Federal Rules of Civil Procedure requires certain defendants to cooperate in saving unnecessary expenses of serving a summons and complaint. A defendant who is located in the United States and who fails to return a signed waiver of service requested by a plaintiff located in the United States will be required to pay the expenses of service, unless the defendant shows good cause for the failure.
+
+"Good cause" does nor include a belief that the lawsuit is groundless, or that it has been brought in an improper venue, or that the court has no jurisdiction over this matter or over the defendant or the defendant's property.
+
+If the waiver is signed and returned, you can still make these and all other defenses and objections. but you cannot object to the absence of a summons or of service.
+
+If you waive service. then you must, within the time specified on the waiver form, serve an answer or a motion under Rule 12 on the plaintiff and Ale a copy with the court. By signing and returning the waiver form. you arc allowed more time to respond than if a summons had been served.

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marker2/court-redacted-v-indyke-10475/EFTA02777729/EFTA02777729.md

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+Bennet J. Moskowitz bennetmoskowitz@troutman.com
+
+January 2, 2020
+
+ECF
+
+Hon. Lorna G. Schofield Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007
+
+Re: v. Darren K. lndyke and Richard D. Kahn, in their capacities as the executors of the Estate of Jeffrey Edward Epstein, and Ghislaine Maxwell, Case No. 19-cv-10475-LGS
+
+Dear Judge Schofield:
+
+We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, "Defendants") in the referenced action. Defendants respectfully request that the Court refer this action to Magistrate Judge Debra C. Freeman for General Pretrial (including scheduling, discovery, non-dispositive pretrial motions, and settlement). Plaintiff consents to this request.
+
+As a matter of context, several other Judges in this District have collectively referred to Magistrate Freeman for General Pretrial numerous actions against Defendants in their capacities as Co-Executors of the Estate of Jeffrey E. Epstein, including two actions in which the parties are represented by the respective counsel of record in this action.' Magistrate Freeman held a status conference on November 21, 2019, which counsel of record for the parties to this action attended. Magistrate Freeman requested the parties in the matters referred to Her Honor to submit status reports on January 10, 2020.
+
+<sup>&#</sup>x27;See v. Darren K. Indyke and Richard D. Kahn, in their capacities as the executors of the Estate of Jeffrey Edward E tin No. 19-cv-10476-PGG-DCF, Order of Reference (ECF Doc. 6) (S.D.N.Y. Nov. 21, 2019); v. Darren K. Indyke and Richard D. Kahn, in their capacities as the executors of the Estate of Jeffrey Edward Epstein, Case No. 19-cv-10479-ALC-DCF, Order of Reference (ECF Doc. 8) (S.D.N.Y. Dec. 26, 2019).
+
+The parties are aware that this Court had planned for the parties to submit Joint Letters and Civil Case Management Plans and Scheduling Orders today. However, in light of this request for referral to Magistrate Judge Freeman, the parties request the Court's guidance on whether these documents should be submitted.
+
+Respectfully submitted,
+
+s/Bennet J. Moskowitz Bennet J. Moskowitz

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marker2/court-redacted-v-indyke-10475/EFTA02777731/EFTA02777731.md

@@ -0,0 +1,49 @@
+Troutman Sanders LLP  
+875 Third Avenue  
+New York, New York 10022
+
+troutman.com
+
+| USDC SDNY                     |
+|-------------------------------|
+| DOCUMENT                      |
+| ELECTRONICALLY FILED          |
+| DOC #: _____                  |
+| DATE FILED: <u>01/02/2020</u> |
+
+**Bennet J. Moskowitz**  
+bennet.moskowitz@troutman.com
+
+Application GRANTED. A referral order will issue separately. The initial pretrial conference, scheduled for January 9, 2020, is canceled.
+
+January 2, 2020
+
+Dated: January 2, 2020  
+New York, New York
+
+**ECF**
+
+Hon. Lorna G. Schofield  
+Thurgood Marshall  
+United States Courthouse  
+40 Foley Square  
+New York, NY 10007
+
+![]()**LORNA G. SCHOFIELD**  
+**UNITED STATES DISTRICT JUDGE**
+
+**Re:** [REDACTED] v. *Darren K. Indyke and Richard D. Kahn, in their capacities as the executors of the Estate of Jeffrey Edward Epstein, and Ghislaine Maxwell, Case No. 19-cv-10475-LGS*
+
+Dear Judge Schofield:
+
+We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, "Defendants") in the referenced action. Defendants respectfully request that the Court refer this action to Magistrate Judge Debra C. Freeman for General Pretrial (including scheduling, discovery, non-dispositive pretrial motions, and settlement). Plaintiff consents to this request.
+
+As a matter of context, several other Judges in this District have collectively referred to Magistrate Freeman for General Pretrial numerous actions against Defendants in their capacities as Co-Executors of the Estate of Jeffrey E. Epstein, including two actions in which the parties are represented by the respective counsel of record in this action.<sup>1</sup> Magistrate Freeman held a status conference on November 21, 2019, which counsel of record for the parties to this action attended. Magistrate Freeman requested the parties in the matters referred to Her Honor to submit status reports on January 10, 2020.
+
+<sup>1</sup>See [REDACTED] v. *Darren K. Indyke and Richard D. Kahn, in their capacities as the executors of the Estate of Jeffrey Edward Epstein, Case No. 19-cv-10476-PGG-DCF*, Order of Reference (ECF Doc. 6) (S.D.N.Y. Nov. 21, 2019); [REDACTED] v. *Darren K. Indyke and Richard D. Kahn, in their capacities as the executors of the Estate of Jeffrey Edward Epstein, Case No. 19-cv-10479-ALC-DCF*, Order of Reference (ECF Doc. 8) (S.D.N.Y. Dec. 26, 2019).
+
+The parties are aware that this Court had planned for the parties to submit Joint Letters and Civil Case Management Plans and Scheduling Orders today. However, in light of this request for referral to Magistrate Judge Freeman, the parties request the Court's guidance on whether these documents should be submitted.
+
+Respectfully submitted,
+
+s/Bennet J. Moskowitz Bennet J. Moskowitz

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marker2/court-redacted-v-indyke-10475/EFTA02777733/EFTA02777733.md

@@ -0,0 +1,43 @@
+Case 1:19-cv-10475-LGS-DCF Document 14 Filed 0 ltYgbt ' 1 DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED:January 2, 2020
+
+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+-against-
+
+DAREN K. INDYKE, et al.
+
+Plaintiff(s), : 19 Civ. 10475 (LGS)
+
+Defendant(s). : --------- X
+
+LORNA G. SCHOFIELD, District Judge:
+
+## ORDER OF REFERENCE TO A MAGISTRATE JUDGE
+
+The above entitled action is referred to the Hon. Debra Freeman United States Magistrate Judge, for the following purpose(s):
+
+✓ GENERAL PRE-TRIAL (includes scheduling, discovery, non-dispositive pre-trial motions and settlement)
+
+GENERAL PRE-TRIAL & DISPOSITIVE MOTION (all purposes except trial)
+
+DISPOSITIVE MOTION (i.e., a motion requiring a Report & Recommendation)
+
+SPECIFIC NON-DISPOSITIVE MOTION / DISPUTE (including discovery dispute) •
+
+JURY SELECTION
+
+SO ORDERED.
+
+Dated: January 2, 2020 New York, New York
+
+\* Do not check if already referred for General Pre-Trial.
+
+HABEAS CORPUS INQUEST AFTER DEFAULT / DAMAGES HEARING
+
+SOCIAL SECURITY SETTLEMENT
+
+CONSENT UNDER 28 U.S.C. 636(c) FOR ALL PURPOSES (including trial)
+
+CONSENT UNDER 28 U.S.C. 636(c) FOR LIMITED PURPOSE OF
+
+> LO A G. SCHOFIEL UNITED STATES DISTRICT JUDGE

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marker2/court-redacted-v-indyke-10475/EFTA02777734/EFTA02777734.md

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+January 10, 2020
+
+## VIA ECF
+
+The Honorable Debra Freeman Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312
+
+> Re: v. Darren K. Indyke and Richard D. Kahn, in their capacities as executors of the Estate ofJeffrey Edward Epstein, 19-10479 Jane Doe 1000 v. Darren K. Indyke and Richard D. Kahn, in their capacities as executors o the Estate ofJetey Edward Epstein, 19-10577 v. Darren K. Indyke and Richard D. Kahn, in their capacities as executors of the Estate of Jeji•ey Edward Epstein, and Ghislaine Maxwell, 19- 10475 v. Darren K Indyke and Richard D. Kahn, in their capacities as executors of the Estate of Jeji•ey Edward Epstein, 19-10476
+
+Dear Judge Freeman:
+
+Pursuant to the Court's request at the November 21, 2019, Case Management Conference, Plaintiffs and Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, jointly submit this letter to provide the Court with an update as to the progress of discussions regarding both discovery and settlement.
+
+The parties have thus far engaged in two productive conferences pursuant to Rule 26(f) of the Federal Rules of Civil Procedure. During those conferences, the parties agreed to exchange initial disclosures by January 23, 2020, and to exchange discovery plans one week thereafter, on January 30, 2020.
+
+As the Court is aware, Defendants have arranged for a Victims' Compensation Program that will be available to Plaintiffs. Plaintiffs' counsel has conferred with the Program's designers and administrators, the Program's administrators provided Plaintiffs with a proposed protocol for the Program, and Plaintiffs have provided some feedback to the administrators. The motion for the Superior Court of the United States Virgin Islands to approve the establishment of the Program will be heard on February 4, 2020.
+
+The parties request a conference with the Court on February 6 or 7, 2020, to resolve any potential disagreements as to how these matters should proceed. The parties will provide the Court with their proposed discovery plan(s) 48 hours before any such conference.
+
+Respectfully submitted,
+
+/s/ Joshua I. Schiller
+
+David Boies, Esq. Joshua I. Schiller, Esq. Sigrid S. McCawley, Esq. Boies Schiller Flexner LLP
+
+/s/ Bennet J. Moskowitz
+
+Bennet J. Moskowitz, Esq. Troutman Sanders LLP
+
+cc: Counsel of Record (via ECF)

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marker2/court-redacted-v-indyke-10475/EFTA02777736/EFTA02777736.md

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+The Clerk of Court of the Southern District of New York is directed to docket the within ORDER in each of the following actions:
+
+VE v. Nine East 71st Street et al., No. 1:19-cv-07625 (AJN) (DF)
+
+Katlyn Doe v. Indyke et at, No. 1:19-cv-07771 (PKC) (DF)
+
+Priscilla Doe v. Indyke et al., No. 1:19-cv-07772 (ALC) (DF)
+
+Lisa Doe v. Indyke et al., No. 1:19-cv-07773 (ER) (DF)
+
+Jane Doe v. Indyke et al., No. 1:19-cv-08673 (KPF) (DF)
+
+v. Indyke et aL, No. 1:19-cv-10475 (LGS) (DF)
+
+v. Indyke et aL, No. 1:19-cv-10476 (PGG) (DF)
+
+v. Indyke et aL, No. 1:19-cv-10479 (ALC) (DF)
+
+Jane Doe 1000 v. Indyke et al., No. 1:19-cv-10577 (LGS) (DF)
+
+Jane Doe 15 v. Indyke et al., No. I :19-cv-10653 (PAE) (DF)
+
+Mary Doe v. Indyke et aL, No. 1:19-cv-I 0758 (PAE) (DF)
+
+v. Indyke et al, No. 1:19-cv-10788 (GHW) (DF)
+
+Anastasia Doe v. Indyke et al, No. 1:19-cv-11869 (MN) (DF)
+
+![](_page_0_Picture_15.jpeg)
+
+## DEBRA FREEMAN, United States Magistrate Judge:
+
+The above-referenced cases — all brought by plaintiffs claiming that they were sexually abused by Jeffrey Epstein and seeking damages from his estate — have been neither consolidated for any purpose, nor designated as "related" by the Court. Nonetheless, these cases (together with certain other, similar cases, not listed above) have been referred to the undersigned for general pretrial supervision, so that discovery — and potentially settlement — may be coordinated as reasonable. While, at the parties' request, discovery in the other Jeffrey Epstein cases referred to this Court has been stayed pending a further report on the parties' settlement efforts, the parties to each of the above-referenced cases have requested, by submissions dated January 10, 2020, that this Court set a discovery schedule. This Court's having reviewed the parties' submissions, it is hereby ORDERED that:
+
+- 1. In each of the above-referenced cases in which the parties have not yet submitted a jointly proposed discovery plan pursuant to Rule 26(f) of the Federal Rules of Civil Procedure, the parties are directed to submit a proposed discovery schedule for this Court's review no later
+
+than February 6, 2020. This submission should address all of the matters set out in Rule 26(f)(3), and should specifically include proposed deadlines for:
+
+- a service of initial disclosures under Rule 26(a)(1);
+- b. service of initial document requests and interrogatories;
+- c. any motion for joinder of other parties or amendment of the pleadings;
+- d. completion of fact discovery; and
+- e. expert disclosures and the completion of expert discovery, if any.
+
+2. As to each of the above-referenced cases, this Court will hold a pretrial conference pursuant to Rule 16 of the Federal Rules of Civil Procedure on February 11, 2020, at 10:00 a.m., in Courtroom 17A at the United States Courthouse, 500 Pearl Street, New York, NY 10007. The parties should be aware, however, that the mere fact that this Court will be holding a single, joint case-management conference does not necessarily mean that this Court will set an identical discovery schedule in each case. At the conference, counsel should be prepared to address whether there are reasons why these cases should be treated differently for scheduling purposes.
+
+Dated: New York, New York January 14, 2019
+
+SO ORDERED
+
+Ahleet A9-7 DEBRA FREEMAN United States Magistrate Judge
+
+Copies to:
+
+All counsel in the above-referenced cases (via ECF)

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marker2/court-redacted-v-indyke-10475/EFTA02777738/EFTA02777738.md

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+Bennet J. Moskowitz bennet.moskowitz@troutman.com
+
+January 24, 2020
+
+ECF
+
+Hon. Lorna G. Schofield Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007
+
+Re: v. Darren K. Indyke and Richard D. Kahn, in their capacities as the executors of the Estate of Jeffrey Edward Epstein, and Ghislaine Maxwell, 19-cv-10475-LGS-DCF
+
+Dear Judge Schofield:
+
+We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"), in the above-referenced action. We write pursuant to Your Honor's Individual Rule III(C)(2) to request a conference on and to explain the bases for the Co-Executors' anticipated motion pursuant to Fed. R. Civ. P. 12(b)(6) to dismiss the time-barred claims and demand for punitive damages in Plaintiff ("Plaintiff") Complaint (ECF No. 1). We propose the following briefing schedule: moving brief by February 24, 2020; opposition brief by March 25, 2020; and reply brief by April 8. 2020.
+
+## 1. Plaintiff is a Texas resident who alleges Decedent committed torts against her in the 1990's, primarily in New Mexico; Plaintiff's causes of action based on torts in New Mexico expired by 1999.
+
+Plaintiff, a Texas citizen and resident, alleges that, in 1995 and/or 1996, when she was 16, Mr. Epstein ("Decedent"), now deceased, committed sexual offenses against her in New York and New Mexico. (Compl. 11111, 18, 53-54, 58, 67.) Plaintiff asserts three causes of action — battery, false imprisonment and intentional infliction of emotional distress — and demands punitive damages. (Id. ¶¶ 79-94, p. 18.)
+
+New York's borrowing statute, CPLR § 202, provides that when a non-New York resident such as Plaintiff sues on causes of action accruing outside New York (here, New Mexico), the complaint must be timely under the statute of limitations of both New York and the jurisdiction where the claim accrued.' New Mexico law provides a 3-year statute of limitations for claims sounding in personal injury (N.M. Stat. § 37-1-8); and minors have 1-year from reaching the age of majority to commence such actions (N.M. Stat. § 37-1-10).
+
+I "In diversity cases in New York, federal courts apply ... C.P.L.R. § 202." Commerzbank AG v. Deutsche Bank Nat? Tr. Co., 234 F. Supp. 3d 462, 467 (S.D.N.Y. 2017) (citation omitted).
+
+Therefore, under New Mexico law, Plaintiff's causes of action based on events occurring there expired by sometime in 1999. Per CPLR § 202, those claims, including Plaintiff's cause of action for false imprisonment in its entirety, are untimely.
+
+## 2. Plaintiff's attempts to plead around the statute of limitations fail.
+
+Plaintiff erroneously alleges her claims are timely per CPLR § 215(8)(a), her claims were equitably tolled, and that the Co-Executors are equitably estopped from asserting a statute of limitations defense. (Compl. ¶¶ 12-15.) Each of these arguments fails as a matter of law.
+
+First, CPLR § 215(8)(a) does not apply here. CPLR § 215(8)(a) provides: "Whenever it is shown that a criminal action against the same defendant has been commenced with respect to the event or occurrence from which a claim governed by this section arises, the plaintiff shall have at least one year from the termination of the criminal action ... to commence the civil action" (emphasis added). Decedent's criminal indictment (the "Indictment") attached to Plaintiff's Complaint does not concern Plaintiff's allegations. Rather, the Indictment charges Decedent sexually abused minor girls from 2002 to 2005 in New York and Florida. (Compl., Ex. A at ¶¶ 1, 2.)
+
+Plaintiff alleges the torts against her occurred in 1995 and/or 1996, mostly in New Mexico. Therefore, this action and the Indictment arise from different occurrences.
+
+New York courts apply CPLR § 215(8)(a) narrowly. See Christodoulou v. Terdeman, 262 AD2d 595, 596 (2d Dept. 1999) (CPLR § 215(8)(a) applied only to claims based on events of February 26, 1993 and December 28, 1993, because it was only in connection with events of those two days that criminal prosecution was commenced against defendant); Gallina v. Thatcher, No. 52980/2017, 2018 N.Y. Misc. LEXIS 8435 (Sup. Ct. Dutchess Cnty. Oct. 23, 2018) (CPLR § 215(8)(a) inapplicable where incidents charged in criminal action and those alleged in civil action occurred on different dates); McElligott v. City of N.Y., 15-cv-7107 (LGS), 2017 U.S. Dist. LEXIS 201829, at \*13 (S.D.N.Y. Dec. 7, 2017) (CPLR § 215(8)(a) inapplicable to claims against civil defendants not charged as co-defendants in criminal action, notwithstanding same events gave rise to both actions). Plaintiff alleges a far more tenuous connection to the Indictment than the criminal-civil links unsuccessfully asserted in those cases.
+
+Second, even if § 215(8)(a) applies, which it does not, Plaintiff's claims for torts occurring in New Mexico are still untimely per N.M. Stat. § 37.1-8 and CPLR § 202.
+
+Third, Plaintiff failed to meet her burden to allege extraordinary circumstances sufficient to justify equitable tolling or estoppel. Equitable tolling is only applied where a plaintiff is "prevented in some extraordinary way from exercising h[er] rights." Viti v. Guardian Life Ins. Co. of Am., 10-cv-2908 (ALC) (MHD), 2012 U.S. Dist. LEXIS 189633, at \*30 (S.D.N.Y. Oct. 5, 2012), adopted by, 2013 U.S. Dist. LEXIS 174145 (S.D.N.Y. Dec. 11, 2013) (emphasis added) (citations omitted). Under this doctrine, a court may, "under compelling circumstances, make narrow exceptions to the statute of limitations ... 'to prevent inequity.'" Id. (emphasis added) (citations omitted). "That the doctrine is to be employed only sparingly -- in 'extraordinary and 'compelling' circumstances -- is reflected in the fact that the plaintiff bears the burden of persuasion to show that tolling is
+
+justified." Id. (emphasis added) (citing Boos v. Runyon, 201 F.3d 178, 185 (2d Cir. 2000)). A late-filing party seeking equitable tolling must also demonstrate she acted with "reasonable diligence" in pursuing her claims during the period she seeks to toll. Id. at \*32 (citation omitted). Equitable estoppel only applies where a plaintiff knows her cause of action exists but the defendant's conduct causes her to delay in bringing her lawsuit. Yesh, 2010 U.S. Dist. LEXIS 101744, at '5 (citation omitted). Equitable estoppel requires a plaintiff to show: (i) the defendant made a definite misrepresentation of fact and had reason to believe the plaintiff would rely on it; and (ii) the plaintiff reasonably relied on the misrepresentation to her detriment. Id. (citation omitted). Tolling is inappropriate where, as here, a plaintiff fails to articulate any acts by a defendant that prevented the plaintiff from timely commencing suit. Id. at \*6 (citation omitted).
+
+Plaintiff's threadbare allegations of "deception," "threats" and the like (Compl. ¶16) do not establish "extraordinary" circumstances justifying tolling. Nor has Plaintiff alleged (i) that Decedent made a misrepresentation to her and had reason to believe she would rely on it, or (ii) that Plaintiff reasonably relied on it to her detriment.
+
+Plaintiff's own allegations refute any notion that she was prevented from exercising her rights. Rather, Plaintiff's allegations establish she was both willing and able to come forward about the alleged wrongdoing—she disclosed it long ago to Vanity Fair Magazine (Id. ¶ 75). There is no "extraordinary" basis to toll the statute of limitations or estop the Co-Executors from asserting a statute of limitations defense given these allegations.
+
+## 3. Plaintiff's claim for punitive damages fails as a matter of law.2
+
+Plaintiff's punitive damages claim must be dismissed as a matter of law. Neither New Mexico law nor New York law permits punitive damages against a decedent tortfeasor's estate. See Jaramillo v. Providence Wash. Ins. Co., 117 N.M. 337, 346 (N.M. 1994) ("punishment and deterrence are not accomplished by enabling recovery of punitive damages from the estate"); NY EPTL § 11-3.2 (a)(1) ("an action may be brought or continued against the personal representative of the decedent, but punitive damages shall not be awarded nor penalties adjudged in any such action brought to recover damages for personal injury."). That is the law in most jurisdictions, as reflected in the Restatement. See Restat. (Second) Of Torts § 908 cmt. a (punitive damages not available against representatives of deceased tortfeasor).
+
+Respectfully submitted,
+
+s/Bennet J. Moskowitz
+
+Bennet J. Moskowitz
+
+<sup>2</sup> Courts in this District regularly dismiss punitive damages claims. See The Cookware Co. (USA). LW v. Austin, 15-5796, 2016 U.S. Dist. LEXIS 177691, at '17 (S.D.N.Y. Dec. 8, 2016) (dismissing punitive damages claim without leave to replead); SJB v. N.Y.C. Dept of Educ., 03-6653, 2004 U.S. Dist. LEXIS 13227, at '25.26 (S.D.N.Y. Jul. 14, 2004) (dismissing punitive damages claims not statutorily available).

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marker2/court-redacted-v-indyke-10475/EFTA02777741/EFTA02777741.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+Plaintiff, CASE NO: 19-cv-10475-LOS-DCF
+
+v.
+
+DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN and GHISLAINE MAXWELL,
+
+Defendants.
+
+## NOTICE OF PLAINTIFF'S MOTION TO APPROVE ALTERNATE SERVICE PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 4(e)(1)
+
+PLEASE TAKE NOTICE that upon the accompanying memorandum of law dated January 27, 2020, Plaintiff will move this Court for an order granting Plaintiff's Motion to Approve Alternative Service Pursuant to Federal Rule of Civil Procedure 4(e)( I ) upon Defendant Ghislaine Maxwell and finding that the service efforts made by Plaintiff's counsel are sufficient to notify Defendant Maxwell of the claims against her in this matter.
+
+Dated: January 27, 2020 Respectfully Submitted,
+
+/s/ Joshua I. Schiller
+
+David Boies BOWS SCHILLER FLEXNER LLP 333 Main Street Armonk, NY 10504 (914) 749-8200
+
+Joshua I. Schiller Bows SCHILLER FLEXNER LLP 55 Hudson Yards New York, NY 10001 (212) 446-2300
+
+Sigrid McCawley (Pro Hac Vice) BOIES SCHILLER FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011
+
+Counsel for Plaintiff,

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+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+Plaintiff, CASE NO: 19-cv-10475-LOS-DCF
+
+v.
+
+DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN and GHISLAINE MAXWELL,
+
+Defendants.
+
+## MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION TO APPROVE ALTERNATE SERVICE PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 4(e)(1)
+
+Plaintiff by and through her undersigned attorneys, respectfully submits this memorandum of law in support of her motion to approve alternate service upon Defendant Ghislaine Maxwell.
+
+#### BACKGROUND
+
+Jeffrey Epstein was one of the world's most prolific sexual predators, using his wealth and connections to create a transcontinental sex trafficking ring. Ghislaine Maxwell was Epstein's main "recruiter"—she spent years overseeing and managing Epstein's sex trafficking network, and actively recruited underage girls to provide to Epstein and others for sex. Compl. II 10, 27-31. Since Epstein's most recent arrest on July 8, 2019, and his eventual death on August 10, 2019, Compl. yq 32, 35, Maxwell has been in hiding. Numerous media outlets have reported on her unknown whereabouts, including The Sun, the Washington Examiner, Vanity Fair, BBC, CNN, CNBC, the Telegraph, The Guardian, and Page Six.' At the same time, her counsel is actively litigating in this Court to keep shielded from public view thousands of pages of court records that would expose her involvement and participation in Epstein's heinous crimes. v. Maxwell, 15-cv-7433-LAP (S.D.N.Y.).
+
+On November 12, 2019, Plaintiff filed a complaint against Ghislaine Maxwell and the co-executors of Epstein's Estate, alleging that, when she was 16 years old, Maxwell and Epstein trafficked her, sexually assaulted her, and falsely imprisoned her at Epstein's
+
+ISee e.g. https://www.vanityfair.cominews/2019/1 Uhunt-for-jeffrey-epstein-alleged-cnabler-ghislainc-maxwell: https://www.theguardian,comlus-news/2019/nov/18/ghislaine-maxwell-prince-andrew-friend-jeffrey-epsteincontroversy-hiding; httes://www.theetumlian.com/us-news/2019/dec/12/she-was-so-dangerous-where-in-the-worldis-the-notorious-ghislaine-maswell- https://www.bbc.com/news/world-us-canada-50927651 https://edition.cnn.corn/2019/12/08/uldwho-is-ghislainc-maxwell-jeffrey-epstein-intl-gbdindcx.html: hilps://www.enbc.com/2019/08/14/ehislaine-maxwell-location-unknown-ieffrev-eestein-accusers-eve-her.html: hites://www.washinetonexaminer.com/newsfibi-investieatine-ieffrev-epstein-facilitator-ehislaine-maxwell: prosecutors-announced/: hdos://pagesix.com/2020/01/11/ehislaine-maxwell-flies-under-the-radar-while-lawyeringup-for-epstein-lawsuit/.
+
+New Mexico ranch. Comp1.11 1-2, 79—80, 84-85. Plaintiff has attempted to locate and personally serve Maxwell to no avail. Her counsel has conducted extensive public records searches and located various addresses for Maxwell. Some of those addresses belong to properties that Maxwell has sold in recent years, such as her New York City home on 65th Street. And all of those addresses have been available to the media and the public for years, yet no one has been able to locate Maxwell at any of those addresses. Plaintiff's counsel also sent an email attaching a copy of the summons and complaint to the only publicly known email address associated with Maxwell (gmax@ellmax.com). Mariella Decl., Ex. A. That email was not returned as undelivered, but counsel did not receive a response. Mariella Dec1. 13.
+
+Despite being in hiding, Maxwell has been actively participating in a defamation lawsuit that filed against her in this Court. See v. Maxwell, 15-cv-7433-LAP (S.D.N.Y.). In that case, Maxwell is vigorously fighting to keep thousands of pages of court filings under seal in order to shield her own wrongdoing from the public. On December 6, 2019, and December 16, 2019, Plaintiff's counsel sent two emails to Maxwell's attorneys in that matter, Jeffrey S. Pagliuca, Laura A. Menninger, and Ty Gee of Haddon, and P.C. ("Haddon M''), attaching a copy of the summons and Complaint and asking them to accept service on Maxwell's behalf. Mariella Decl., Ex. B. Maxwell's counsel did not respond to either email. Mariella Decl. 1 4. This is despite the fact that Haddon has submitted filings to Judge Loretta A. Preska on Maxwell's behalf in that matter as recently as January 17, 2020. v. Maxwell, 15 Civ. 7433-LAP (S.D.N.Y), ECF No. 1020. In addition, after a conference before Judge Preska on January 16, 2020, Plaintiff's counsel asked Ms. Menninger once again if she would accept service on behalf of Maxwell. Mariella Decl. 1 5. Ms. Menninger said that she was not authorized to do so, despite her active participation at the conference on behalf of Maxwell. Id.
+
+Even before Epstein's 2019 arrest and death, locating and serving Maxwell was impracticable. In 2017, a victim suing Maxwell in yet another matter related to Maxwell's participation in Epstein's sex trafficking scheme, attempted to serve Maxwell in a number of ways, including by providing Maxwell's attorneys at Haddon a copy of the summons and complaint, emailing a copy of the summons and complaint to gmax@ellmax.com and attempting to effectuate service at three locations associated with Maxwell in New York and New Jersey. Jane Doe 43 v. Epstein, et al., 17 Civ. 00616-JGK (S.D.N.Y.), ECF No. 97 at 2-3. Despite those attempts, was unable to personally serve Maxwell and filed a motion asking the court to approve alternative service. Id. On January 30,2018, the Honorable John G. Koeltl held that had demonstrated that serving Maxwell was impracticable under New York law and that providing copies of the summons and complaint to Haddon Maxwell's attorneys in v. Maxwell, was reasonably calculated to provide Maxwell with notice of the lawsuit given that they were presumably in contact with Maxwell. v. Epstein, No. 17- CV-616 (JGK), 2018 WL 637421, at \*1 (S.D.N.Y. Jan. 30,2018).
+
+## ARGUMENT
+
+Rule 4(eX1) of Federal Rule of Civil Procedure provides that service upon a party may be effected by "following state law for serving a summons in an action brought in courts of general jurisdiction in the state where the district court is located or where service is made." Accordingly, Defendant Maxwell may be served pursuant to New York C.P.L.R. § 308, which provides several methods by which service upon a natural person may be effectuated, including personal service; service by "delivering the summons . . . to a person of suitable age and
+
+discretion at the actual place of business, dwelling place or usual place of abode of the person to be served" and then mailing the summons to the individual's "last known residence;" or service by "affixing the summons to the door of either the actual place of business, dwelling place or usual place of abode within the state of the person to be served" and then "mailing the summons to such person at his or her last known residence" or to his or her place of business so called "nail and mail" service. CPLR §§ 308(1), (2) & (4).
+
+If service under CPLR §§ 308(1), (2) & (4) is impracticable, CPLR § 308(5) permits service "in such manner as the court, upon motion without notice, directs." The determination of whether service is impracticable "depends upon the facts and circumstances of the particular case." S.E.C. v. HGI, Inc., No. 99 Civ. 3866 (DLC), 1999 WL 1021087, at \*1 (S.D.N.Y. Nov. 8, 1999). Although the plaintiff must show impracticability of service, there is no requirement of "proof of due diligence or of actual prior attempts to serve a party under the other provisions of the statute." Id. Giving notice under a substitute system is permissible provided that it is "reasonably calculated, under the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections." See SEC v. Tome, 833 F.2d 1086, 1093 (2d Cir. 1987).
+
+New York Courts consistently direct or approve alternative methods of service where regular service has been deemed "impracticable." For example, in Dobkin v. Chapman, 236 N.E.2d 451, 455 (N.Y. 1968), the New York Court of Appeals held that where a plaintiff could not accomplish the methods of service set forth in § 308, a Court is "given the discretion to fashion other means adapted to the particular facts of the case before it" pursuant to § 308(5) (referred to in Dobkin as § 308(4), the predecessor to § 308(5)). Moreover, the Court of Appeals held that a Court's discretion to fashion such methods of service "must be broad" if the statute is to be "meaningful." Id.
+
+Plaintiff has demonstrated that personally serving Maxwell is impracticable "because she has made numerous efforts to obtain information about [Maxwell's] current residence and general contact information to effectuate personal service but has been unable to locate Maxwell." See 2018 WL 637421, at \*1; see also Rampersad v. Deutsche Bank Secs., Inc., No. 02 Civ. 7311 (LTS), 2003 WL21073951, at \*1 (S.D.N.Y. May 9, 2003) (authorizing alternative service under § 308(5) when Plaintiff was unable to determine defendant's residence or place of business after "extensive Internet searches" and inquires with defendant's former clients); HCI, 1999 WL 1021087, at \*1 (service by publication in USA Today authorized because defendant's whereabouts were unknown, efforts to locate his home or business address by searching computer databases failed, and there existed no record that he designated an agent for service).
+
+In addition to trying to locate contact information for Maxwell, who is purposely evading the media and justice system, Plaintiff has tried alternate avenues to serve Maxwell to no avail, including ( I) sending the documents to her current lawyers at Haddon M, who are actively litigating on Maxwell's behalf in another case and are most certainly in regular contact with her, and (2) emailing the documents to Maxwell's publicly available email address. Personal service under these circumstances is impracticable.
+
+Plaintiff has also demonstrated that the steps she has already taken to serve Maxwell are "reasonably calculated, under the circumstances, to apprise [the] interested partly] of the pendency of the action." See Tome, 833 F.2d at 1093. Haddon is actively litigating on Maxwell's behalf and appeared in court for Maxwell as recently as January 16, 2020. See v. Maxwell, 15 Civ. 7433-LAP (S.D.N.Y), ECF No. 1016 (ordering counsel to appear at January
+
+16, 2020 conference). There is no doubt that Maxwell has had actual notice and knowledge of the claims asserted in Plaintiff's Complaint or that Haddon can easily and quickly notify her of those claims. As a result, this Court should deem the service methods attempted to be sufficient and grant the motion for alternate service. See Bozza v. Love, No. 15-CV-3271 (LGS), 2015 WL 4039849, at \*2 (S.D.N.Y. July 1, 2015) (holding that service upon the defendant's counsel in an unrelated matter was sufficient).
+
+Maxwell should not be permitted to dodge allegations of serious wrongdoing against her while at the same time actively litigating to keep court records exposing that wrongdoing under seal. She has been using this Court as a sword and a shield for many years, and she, Jeffrey Epstein, and their other co-conspirators have attempted to thwart their victims from obtaining justice for decades. Maxwell must face the allegations against her, and the Court should deem the service methods attempted to be sufficient as Judge Koeltl did in 2016.
+
+# CONCLUSION
+
+For all of the foregoing reasons, the Court should grant Plaintiff's Motion to Approve Alternative Service Pursuant to Federal Rule of Civil Procedure 4(e)(1) upon Defendant Ghislaine Maxwell and find that the service efforts made by Plaintiff's counsel as described herein are sufficient to apprise Maxwell of this action.
+
+Dated: January 27, 2020 Respectfully Submitted,
+
+/s/ Joshua I. Schiller
+
+David Boies BOIFS SCHILLER FLEXNER LLP 333 Main Street Armonk, NY 10504 (914) 749-8200
+
+Joshua I. Schiller Bows SCHILLER FLEXNER LLP 55 Hudson Yards New York, NY 10001 (212) 446-2300
+
+Sigrid McCawley (Pro Hac Vice) Bows SCHILLER FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011
+
+Counsel for Plaintiff,

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marker2/court-redacted-v-indyke-10475/EFTA02777751/EFTA02777751.md

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+## EXHIBIT A
+
+From: To: Cc: Subject: Date: Attachments: Sabina Mariana gmaziaelkoaxsam Sigrid MrCawley; lorthiller Summons & Complaint: v. Ghislaine Maxwell (19-cv-10475) Monday, December 23, 2019 3:42:23 PM
+
+M. Maxwell,
+
+Please be advised that we represent a victim of Jeffrey Epstein, who filed a lawsuit against you on November 12, 2019, in the Southern District of New York (Docket No. 19-cv-10475). I am attaching summons and complaint to this email. Please confirm receipt of this email.
+
+Thank you,
+
+Sabina Mariella
+
+Associate
+
+BOIES SCHILLER FLEXNER LLP
+
+55 Hudson Yards
+
+New York, NY 10001
+
+(t) +1 212 754 4541
+
+(m)
+
+crnanellaObcfIlo corn
+
+www bsrllosord

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