MEMY-1805 marker2-fixhub court-doe-v-indyke-00484 (pepper 16-core): 324/324

marker2-fixhub/court-doe-v-indyke-00484/EFTA02751880/EFTA02751880.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE,
+
+Plaintiff,
+
+v.
+
+DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual,
+
+Defendants.
+
+Case No. 1:20-cv-00484
+
+## COMPLAINT FOR DAMAGES
+
+DEMAND FOR JURY TRIAL
+
+Plaintiff Jane Doe ("Doe" or "Plaintiff') alleges as follows:
+
+#### INTRODUCTION
+
+I. This case arises out of years of sexual abuse and exploitation of a young girl by notorious pedophile and convicted sex offender Jeffrey Epstein ("Epstein"). It all started in 1994 when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a summer camp in Michigan. Jane Doe was their first known victim and was subsequently abused by Epstein and Maxwell for years as a young girl, suffering unimaginable physical and psychological trauma and distress. Despite that, Jane Doe has persevered and survived to tell her story, to hold her perpetrators accountable and to seek justice for the atrocities committed against her.
+
+2. Throughout his life, Epstein systematically perpetrated acts of molestation. exploitation, assault and rape on hundreds of young girls. Epstein's system of abuse was facilitated in large part by his co-conspirator and accomplice, Maxwell, who helped supply him with a steady stream of young and vulnerable girls—many of whom were fatherless, like Jane Doe, and came from struggling families.
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+2 3 3. This system, which took years to develop, all started with them exploiting and abusing Jane Doe who they used as a guinea pig to refine their criminal enterprise and widen their network of additional sexual abuse victims.
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+#### 4 THE PARTIES
+
+5 6 7 4. Plaintiff Jane Doe is a citizen of the State of California. At all times relevant to this suit, Doe was a minor child living in Florida and New York and who was sexually abused while she was a minor by Defendants in New York.
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+8 5. Defendant Ghislaine Maxwell is domiciled in the State of New York.
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+9 10 6. Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the Estate of Jeffrey E. Epstein.
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+12 7. Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the Estate of Jeffrey E. Epstein.
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+18 19 9. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at the time of his death. As the legal representatives of the Estate of Jeffrey E. Epstein, Darren K. Indyke and Richard D. Kahn are deemed citizens of the U.S. Virgin Islands. The matter in controversy exceeds the sum of \$75,000, and therefore jurisdiction in this Court is proper. 28 U.S.C. § 1332(c)(2).
+
+20 10. Ghislaine Maxwell is domiciled in New York.
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+21 22 11. A substantial part of the events giving rise to these causes of action occurred in the Southern District of New York, thus venue in this district is proper. 28 U.S.C. § 1391(b)(2).
+
+#### 23 JURY DEMAND
+
+24 12. Plaintiff hereby demands a trial by jury on all of her claims in this action.
+
+#### 25 FACTUAL ALLEGATIONS
+
+#### 26 Epstein and Maxwell's Abuse of Doe
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+27 28 13. In the summer of 1994, Jane Doe met Jeffrey Epstein and Ghislaine Maxwell at Interlochen Arts Camp in Michigan when she was only 13-years-old. Doe was there as a student
+
+## JURISDICTION AND VENUE
+
+8. Plaintiff is domiciled in California.
+
+1 2 3 4 5 6 7 in the voice program. Doe was sitting alone on a bench between classes when Epstein and Maxwell approached her. Epstein bragged to her about being a patron of the arts and giving scholarships to talented young artists like Doe. Epstein and Maxwell probed her at length about her background, family situation and where she lived. As Doe got up to leave, Epstein requested her mother's phone number back in Florida. She was alarmed by his request, but also feared that she could not refuse the older man's request so she complied and provided him with the phone number.
+
+8 9 10 14. Several weeks later, once Doe had returned from Michigan to Florida, Epstein called Doe's home. Epstein first spoke with Doe's mother about how he mentors young kids and provides scholarships for the arts. He requested to speak to Doe and invited her and her mother to his mansion in Palm Beach. He sent a driver across town to pick them up.
+
+-a II -a O act 021 a 14 x 1 cn fa z
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+12 5 13 15 16 17 18 19 20 21 22 23 15. Over the course of the next several months, Epstein and Maxwell attempted to groom and mentor 13-year-old Jan Doe. Epstein gave himself the name of Doe's "godfather" while Maxwell acted like an older sister to her. They took her to movies, went shopping with her and lounged around Epstein's estate with her. Epstein and Maxwell then started to make sexual references when they were with her. For instance, Maxwell told Doe that having sex with exboyfriends was easy because once you slept with them "they've been grandfathered in and you could go back and flick them whenever you wanted." Epstein also started to slowly display his pedophilic ways when shopping with Doe and Maxwell. Instead of Doe picking out clothes she wanted to wear, Epstein insisted that she pick out and wear little children's cotton underwear. Also, after nearly every visit with Epstein and Maxwell, Epstein sent Doe home with two or three one-hundred-dollar bills to give her mother since "she's having a hard time and struggling as a widow."
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+24 25 26 27 28 16. While these visits made Doe extremely uncomfortable, Epstein and Maxwell made her feel she could not refuse them. During this time, Epstein started to pay for voice lessons for Doe and insisted that Doe could not advance her career in any way without him. When Doe expressed hesitation about spending time with Epstein and Maxwell or acquiescing to their desires, Epstein and Maxwell would threaten Doe, and scold her for being "ungrateful".
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+17. During one of Doe's encounters with Epstein, he took her to Mar-a-Lago where he introduced her to its owner, Donald J. Trump. Introducing 14-year-old Doe to Donald J. Trump, Epstein elbowed Trump playfully asking him, referring to Doe, "This is a good one, right?" Trump smiled and nodded in agreement. They both chuckled and Doe felt uncomfortable, but, at the time, was too young to understand why.
+
+18. Towards the end of 1994, Epstein invited Doe into his pool house, where he grabbed her, put her on his lap and started masturbating. Epstein told her that was what to expect from photographers who were soon going to be take modeling pictures of her. However, when Doe was ultimately photographed by these professional photographers, they did no such thing.
+
+19. Over the next few years, the sexual abuse escalated. On a regular basis, Epstein would digitally penetrate Doe, force Doe to perform sexual acts on him and apply vibrators on different parts of Doe's body. The abuse occurred at Epstein's home in Palm Beach, Florida, Epstein's townhouse on 9 East 71st Street in New York City, and Epstein's ranch in New Mexico. When travelling to these places, Doe often flew with Epstein and Maxwell in Epstein's private jet.
+
+20. In 19%, when Doe was 16-years-old, Epstein moved Doe to New York City. At first, Epstein put Doe up in his apartment on 65th Street and 2nd Avenue. After a few months. Epstein co-signed the lease for Doe and Doe's mother for an apartment. Additionally, Epstein paid her tuition at a private high school in Manhattan as well.
+
+21. Once Epstein had secured Doe in New York and made her and her family completely dependent on him financially (including, for the roof over their heads), Epstein's abuse of Doe continued to escalate.
+
+22. In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New York, Epstein asked 17-year-old Doe if she had a boyfriend. Doe replied that she did not. Epstein responded that when she did have a boyfriend she would want the sex to be "good' and that she should "get it over with already," meaning lose her virginity. Despite Doe's resistance, Epstein then pushed Doe down onto her stomach and raped her. From that point forward for several years in New York, Epstein raped Doe on multiple occasions.
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+23. During Doe's time in New York, Maxwell also regularly facilitated Epstein's abuse of Doe and was frequently present when it occurred.
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+24. In 1999, Doe moved to Los Angeles to start a career. Upon moving to Los Angeles and being physically away from Epstein and Maxwell, Doe finally felt like she could escape Epstein's abuse and stopped returning his frequent calls where he would threaten and berate her for not appreciating him.
+
+25. Despite Doe's physical escape from Epstein and Maxwell, the years of abuse and exploitation perpetrated against her by them cause her immeasurable pain and suffering every day.
+
+## Epstein's Death and Will
+
+26. In July 2019, Epstein was indicted by the Unites States Attorney's Office for the Southern District of New York.
+
+27. On August 10, 2019, Epstein was found dead in his jail cell at the Metropolitan Correctional Center, where he was being held pending trial. Upon information and belief, New, York City's medical examiner concluded Epstein died by suicide.
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+28. On August 15, 2019, Epstein's last will and testament (the "Will") was filed in the Probate Division of the Superior Court of the Virgin Islands.
+
+29. The Will indicated that it was executed by Epstein on August 8, 2019 at the Metropolitan Correctional Center. The Will was accompanied by affidavits from Darren K. Indyke and Richard D. Kahn attesting to their "Oath of Willingness to Serve as Executor and Appointment of Local Counsel." Mr. Indyke and Mr. Kahn also filed a Petition for Probate and for Letters Testamentary in the Superior Court of the Virgin Islands.
+
+30. 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 "givers] all of my property, real and personal, wherever situated...to the then acting Trustees of The 1953 Trust."
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+31. On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn are the two Trustees of The 1953 Trust.
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+32. On September 6, 2019, Magistrate Judge Carolyn P. Hermon-Percell of the Superior Court of the Virgin Islands ordered that Epstein's will be admitted to probate and authorized Mr. Indyke and Mr. Kahn to administer the estate.
+
+#### FIRST CAUSE OF ACTION
+
+## (Sexual Assault)
+
+33. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as if set forth fully herein.
+
+34. On numerous occasions over several years, Epstein, with Maxwell's assistance, made violent sexual demands on Plaintiff while placing his hands on her body in a position of dominance and control and while touching Plaintiff in violent and invasive ways.
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+35. These demands, often made when young Plaintiff was alone with Epstein or with only Epstein and Maxwell, were intended to frighten Plaintiff into submitting to his sexual demands and placed Plaintiff in apprehension of harm.
+
+36. This conduct caused Plaintiff serious and persistent harm and contributed to injuries that Plaintiff continues to suffer.
+
+37. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g (McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+
+## SECOND CAUSE OF ACTION
+
+## (Sexual Battery)
+
+38. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as if set forth fully herein.
+
+39. On numerous occasions over several years, Epstein raped Doe.
+
+1 2 40. On numerous occasions over several years, Epstein digitally penetrated Doe with his fingers, tongue and foreign objects.
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+3 4 41. On numerous occasions over several years, Epstein made otherwise unwanted, unlawful, harmful, and offensive physical contact with Plaintiff's body.
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+5 6 42. This conduct caused Plaintiff serious and persistent harm and contributed to injuries that Plaintiff continues to suffer.
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+7 8 9 10 43. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g (McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+
+#### 11 THIRD CAUSE OF ACTION
+
+15 16 45. Epstein and Maxwell's campaign of sexual abuse against a teenaged Plaintiff was extreme and outrageous conduct that shocks the conscience.
+
+18 19 46. Epstein and Maxwell's serial sexual assaults, committed during the course of a methodical plan of recruitment, enticement, and attack, inflicted severe pain and anguish upon Plaintiff.
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+20 21 22 47. Epstein and Maxwell directed this conduct at Plaintiff and knew that it would cause severe and lasting emotional distress. Indeed, the conduct caused Plaintiff severe and lasting emotional distress and serious injuries to her mental health.
+
+23 24 25 26 48. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g (McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+
+#### 27 FOURTH CAUSE OF ACTION
+
+## (Intentional Infliction of Emotional Distress)
+
+44. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as if set forth fully herein.
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+49. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as if set forth fully herein.
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+50. Epstein and Maxwell coaxed Plaintiff, then a teenaged girl, into Epstein's home for a period of several years. They worked hard to groom her. Once under their supervision and influence, Epstein and Maxwell proceeded methodically to sexually abuse Plaintiff.
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+51. Epstein and Maxwell's conduct was extreme and outrageous, breached a duty owed directly to Plaintiff, endangered her physical safety, and caused severe and lasting emotional distress and serious injuries to Plaintiff's mental health.
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+52. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g (McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+
+## FIFTH CAUSE OF ACTION
+
+#### (False Imprisonment)
+
+53. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as if set forth fully herein.
+
+54. Defendants, in perpetrating the above-described non-consensual sexual assaults. did, by use of threat and/or physical force, willfully and intentionally confine, detain, imprison and/or restrain Plaintiff without lawful authority to do so, against her will, and without her consent.
+
+55. Plaintiff was aware of, and suffered the extreme effects of, the Defendants' unlawful confinement.
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+56. As a consequence of Defendants' false imprisonment of Plaintiff, she sustained conscious pain and suffering, Plaintiffs health was impaired, Plaintiff suffered great mental distress, shock, fright and humiliation, and Plaintiffs reputation and character were injured.
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+57. As a consequence of the conduct of Defendants, Plaintiff has incurred severe psychological trauma and damage, has suffered great humiliation, loss of esteem, mental anguish and suffering.
+
+2 3 4 5 6 7 8 9 10 P.. It 15 II 17 n a= 18 19 20 21 22 23 24 25 26 27 28 214-g § C.P.L.R. N.Y. Act, Victims Child the under timely is action of cause This 58. was she when Plaintiff against perpetrated conduct of out arises it because 2019), (McKinney of Thirty Hundred One Article in defined as offense sexual a constitutes that 18 of age the under 130.55. § P.L. N.Y. 130.52; § P.L. N.Y. See 130"). ("Article Law Penal York New the RELIEF FOR PRAYER to: Court this for prays Doe Jane Plaintiff WHEREFORE, by EPSTEIN E. JEFFREY OF ESTATE Defendant that declaring judgment a Issue 59. legal as KAHN, D. RICHARD and INDYKE K. DARREN executors, its through and are MAXWELL GHISLAINE Defendant and Epstein, E. Jeffrey of Estate the of representatives case; this in alleged law of violations the for liable damages; punitive and consequential statutory, compensatory, actual, Award 60. law; by allowed rate highest the at interest -judgment post and -judgment pre Award 61. and proper. and just deem may Court this as relief further such Grant 62. submitted, Respectfully 2020 16, January Dated: pending) (admission Boyle Kevin pending) (admission Glassman Robert pending) (admission Werksman Nathan LLP BOYLE & SHEA PANISH 700 Suite Blvd., Monica Santa 11111 90025 CA Angeles, Los 477-1700 (310) Telephone: 477-1699 (310) Facsimile: boyle@psblaw.com glassman@psblaw.com werksman@psblaw.com Morelli P. Benedict /s/ Morelli P. Benedict Sirotkin T. David Mahoney A. Sara PLLC FIRM LAW MORELLI
+
+A E 12 s aa 13 DW~4 g 14 8 03 98 < 16 E 8 X
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+a. 11 {sup}`u`ee {sup}`12` olf s E 13 14 E 08 5 14 < 3 2 • x la{sup}`2` IS inm gF fa {sup}`16`
+
+777 Third Avenue, 31' Floor New York, NY 10017 Telephone: (212) 751-9800 Facsimile: (212) 751-0046 bmorelli@morellilaw.com dsirotkin@morellilaw.com smahoney@morellilaw.com
+
+Attorneys for Plaintiff

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751890/EFTA02751890.md

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+PLAINTIFFS JANE DOE,
+
+The JS.44 civil cover shoot and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of coud. This form. approved by the Judicial Conference of the United Slates in September 1974. is requited for use of the Clerk of Coun for the purpose of 'nitrating the chnl docket sheet.
+
+ATTORNEYS (FIRM NAME. ADDRESS. AND TELEPHONE NUMBER Panish Shea & Boyle LLP 11111 Santa Monica Blvd., Suite 700 Los Angeles, CA 90025
+
+DEFENDANTS DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual,
+
+ATTORNEYS (IF KNOWN) Bennet Moskowitz (Attorney for Darren K. Indyke and Richard D. Kahn ) 875 Third Avenue New York. NY 10022
+
+CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE (DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)
+
+28 USC 1332; New York causes of action.
+
+Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY at any time? No aYesO Judge Previously Assigned
+
+If yes, was this case Vol. 0 Invol. D Dismissed. No 0 Yes 0 II yes, give date & Case No.
+
+IS THIS AN INTERNATIONAL ANIMATION PAM
+
+(PLACE AN (x) IN ONE BOX ONLY)
+
+| TORTS |  | PERSONAL INJURY |  | PERSONAL INJURY |  | FORFEITURE/PENALTY |  | BANKRUPTCY |  | OTHER STATUTES |  |  |
+| ---------- | ----------------- | ----------------- | ------------------ | ------------------------- | -------------------------- | -------------------- | --------------------- | ----------------------------------------- | ------------ | ------------------------------------- | ----------------- | ------------- |
+| CONTRACT |  | PERSONAL INJURY |  | PERSONAL INJURY |  | FORFEITURE/PENALTY |  | BANKRUPTCY |  | OTHER STATUTES |  |  |
+| [ ] 110 | INSURANCE | [ ] 310 | AIRPLANE | [ ] 367 | HEALTHCARE/ | [ ] 625 | DRUG RELATED | [ ] 422 | APPEAL | [ ] 375 | FALSE CLAIMS |  |
+| [ ] 120 | MARINE | [ ] 315 | AIRPLANE PRODUCT | PHARMACEUTICAL PERSONAL | INJURY/PRODUCT LIABILITY | [ ] 625 | DRUG RELATED | [ ] 422 | APPEAL | [ ] 376 | QUI TAM |  |
+| [ ] 130 | [ ] 140 | [ ] 130 | [ ] 320 | LIABILITY | [ ] 365 | PERSONAL INJURY | SEIZURE OF PROPERTY | [ ] 423 | WITHDRAWAL | [ ] 400 | STATE |  |
+| [ ] 140 | NEGOTIABLE | [ ] 140 | [ ] 320 | ASSAULT, LIBEL & | PRODUCT LIABILITY | [ ] 690 | OTHER | [ ] 28 USC 158 |  | REAPPORTIONMENT |  |  |
+| [ ] 150 | RECOVERY OF | [ ] 150 | [ ] 330 | FEDERAL | [ ] 368 | ASBESTOS PERSONAL | INJURY PRODUCT | [ ] 490 | OTHER | [ ] 410 | ANTITRUST |  |
+| [ ] 150 | OVERPAYMENT & | [ ] 150 | [ ] 330 | EMPLOYERS' | LIABILITY | [ ] 680 | OTHER | [ ] 28 USC 157 |  | [ ] 430 | BANKS & BANKING |  |
+| [ ] 151 | ENFORCEMENT | [ ] 151 | [ ] 340 | MARINE | [ ] 820 | COPYRIGHTS | [ ] 830 | PATENT | [ ] 450 | COMMERCE | [ ] 460 | DEPORTATION |
+| [ ] 152 | OF JUDGMENT | [ ] 152 | [ ] 345 | MARINE PRODUCT | [ ] 370 | OTHER FRAUD | [ ] 835 | PATENT-ABBREVIATED NEW DRUG APPLICATION | [ ] 470 | RACKETER INFLU- | ENCED & CORRUPT |  |
+| [ ] 152 | MEDICARE ACT | [ ] 152 | [ ] 350 | MARINE PRODUCT | [ ] 370 | OTHER FRAUD | [ ] 840 | TRADEMARK | [ ] 480 | ORGANIZATION ACT | (RICO) |  |
+| [ ] 153 | OF JUDGMENT | [ ] 153 | [ ] 355 | MOTOR VEHICLE | [ ] 375 | TRUTH IN LENDING | [ ] 835 | PATENT-ABBREVIATED NEW DRUG APPLICATION | [ ] 490 | CABLE/SATELLITE TV | (RICO) |  |
+| [ ] 153 | STUDENT LOANS | [ ] 153 | [ ] 355 | MOTOR VEHICLE | [ ] 380 | OTHER PERSONAL | [ ] 680 | OTHER PERSONAL | [ ] 850 | CONSUMER CREDIT | (RICO) |  |
+| [ ] 153 | (EXCL VETERANS) | [ ] 153 | [ ] 365 | MOTOR VEHICLE | [ ] 380 | OTHER PERSONAL | [ ] 680 | OTHER PERSONAL | [ ] 490 | CABLE/SATELLITE TV | (RICO) |  |
+| [ ] 153 | RECOVERY OF | [ ] 153 | [ ] 368 | MOTOR VEHICLE | [ ] 380 | OTHER PERSONAL | [ ] 680 | OTHER PERSONAL | [ ] 850 | CONSUMER CREDIT | (RICO) |  |
+| [ ] 153 | OVERPAYMENT | [ ] 153 | [ ] 368 | MOTOR VEHICLE | [ ] 380 | OTHER PERSONAL | [ ] 680 | OTHER PERSONAL | [ ] 850 | CONSUMER CREDIT | (RICO) |  |
+| [ ] 150 | ENFORCEMENT | [ ] 150 | [ ] 368 | MALPRACTICE | [ ] 385 | PROPERTY DAMAGE | [ ] 710 | FAIR LABOR | [ ] 862 | COMMODITIES/ |  |  |
+| [ ] 160 | STOCKHOLDERS | [ ] 160 | [ ] 368 | MED MALPRACTICE | [ ] 385 | PROPERTY DAMAGE | [ ] 710 | STANDARDS ACT | [ ] 863 | EXCHANGE |  |  |
+| [ ] 160 | SUITS | [ ] 160 | [ ] 368 | SUITS | [ ] 385 | PROPERTY DAMAGE | [ ] 720 | LABOR/MGMT | [ ] 864 | SSID TITLE XVI |  |  |
+| [ ] 190 | OTHER | [ ] 190 | [ ] 368 | SUITS | [ ] 380 | OTHER PERSONAL | [ ] 720 | RELATIONS | [ ] 865 | RSI (405(g)) |  |  |
+| [ ] 190 | CONTRACT | [ ] 190 | [ ] 368 | CONTRACT | [ ] 380 | OTHER PERSONAL | [ ] 740 | RAILWAY LABOR ACT | [ ] 865 | RSI (405(g)) |  |  |
+| [ ] 195 | CONTRACT | [ ] 195 | [ ] 368 | CONTRACT | [ ] 375 | OTHER FRAUD | [ ] 375 | FEDERAL TAX SUITS | [ ] 870 | TAXES (U.S. Plaintiff or Defendant) |  |  |
+| [ ] 195 | PRODUCT | [ ] 195 | [ ] 368 | PRODUCT | [ ] 375 | OTHER FRAUD | [ ] 375 | FEDERAL TAX SUITS | [ ] 871 | IRS-THIRD PARTY |  |  |
+| [ ] 196 | LIABILITY | [ ] 196 | [ ] 368 | LIABILITY | [ ] 375 | OTHER FRAUD | [ ] 375 | FEDERAL TAX SUITS | [ ] 870 | TAXES (U.S. Plaintiff or Defendant) |  |  |
+| [ ] 196 | FRANCHISE | [ ] 196 | [ ] 368 | FRANCHISE | [ ] 380 | OTHER PERSONAL | [ ] 390 | IMMIGRATION | [ ] 893 | ENVIRONMENTAL |  |  |
+| [ ] 196 | FRANCHISE | [ ] 196 | [ ] 368 | FRANCHISE | [ ] 380 | OTHER PERSONAL | [ ] 390 | IMMIGRATION | [ ] 895 | FREEDOM OF |  |  |
+| [ ] 196 | FRANCHISE | [ ] 196 | [ ] 368 | FRANCHISE | [ ] 380 | OTHER PERSONAL | [ ] 390 | IMMIGRATION | [ ] 895 | INFORMATION ACT |  |  |
+| [ ] 210 | LAND | [ ] 210 | [ ] 440 | OTHER CIVIL RIGHTS | [ ] 530 | HABEAS CORPUS | [ ] 790 | OTHER LABOR | [ ] 896 | ARBITRATION |  |  |
+| [ ] 210 | CONDEMNATION | [ ] 210 | [ ] 440 | OTHER CIVIL RIGHTS | [ ] 530 | HABEAS CORPUS | [ ] 790 | LITIGATION | [ ] 899 | ADMINISTRATIVE |  |  |
+| [ ] 220 | FORECLOSURE | [ ] 220 | [ ] 440 | ACCOMMODATIONS | [ ] 540 | MANDAMUS & OTHER | [ ] 791 | EMPL RET INC | [ ] 870 | PROCEDURE ACT/REVIEW OR |  |  |
+| [ ] 230 | RENT LEASE & | [ ] 230 | [ ] 440 | AMERICANS WITH | [ ] 540 | MANDAMUS &am |  |  |  |  |  |  |
+
+No a Yes 0
+
+NATURE OF SUIT
+
+REAL PROPERTY
+
+Check if demanded M complaint:
+
+CHECK IF THIS IS ACLASS ACTION UNDER F.R.C.P. 23
+
+DEMAND \$ OTHER JUDGE DOCKET NUMBER
+
+DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y. AS DEFINED BY LOCAL RULE FOR DIVISION OF BUSINESS 137 IF SO, STATE:
+
+ 1 Original Proceeding  2 Removed from State Court  3 Remanded from Appellate Court  4 Reinstated or Reopened  5 Transferred from (Specify District)  6 Multidistrict Litigation (Transferred)  7 Appeal to District Judge from Magistrate Judge
+
+ a. all parties represented
+
+ b. At least one party is pro se.
+
+ 8 Multidistrict Litigation (Direct File)
+
+(PLACE AN x IN ONE BOX ONLY) BASIS OF JURISDICTION IF DIVERSITY, INDICATE
+
+ 1 U.S. PLAINTIFF  2 U.S. DEFENDANT  3 FEDERAL QUESTION  4 DIVERSITY  
+(U.S. NOT A PARTY)
+
+## CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)
+
+(Place an IX) in one box for Plaintiff and one box for Defendant)
+
+|  | PTF | DEF |  | PTF DEF |  | PTF | DEF |
+| -------------------------- | -------- | ------ | --------------------------------- | ---------- | ---------------------------------- | ------ | ------ |
+| CITIZEN OF THIS STATE | ft | (4 1 | CITIZEN OR SUBJECT OF A | ( )3 13 | INCORPORATED and PRINCIPAL PLACE | L 15 | ( )5 |
+|  |  |  | FOREIGN COUNTRY |  | OF BUSINESS IN ANOTHER STATE |  |  |
+| CITIZEN OF ANOTHER STATE | ir,4 2 | ( )2 | INCORPORATED or PRINCIPAL PLACE | ( )4 [ 4 | FOREIGN NATION | ( 16 | 16 |
+
+PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES) Jane Doe, Los Angeles , California do Panish Shea & Boyle LLP 11111 Santa Monica Blvd., Suite 700 Los Angeles, CA 90025
+
+DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)
+
+Darren K. Indyke, U.S. Virgin Islands 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. Indyke and Richard D. Kahn are sued as executors of the Estate of Jeffrey Epstein. Per 28 U.S.C. §1332 , Defendants are deemed citzens of the U.S. Virgin Islands (USVI) , Decedent Jeffrey Epstein's domicile. Defendants' residential addresses are unknown to Plaintiff. Their counsel is listed above.
+
+## 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 ACTION SHOULD BE ASSIGNED TO: O PLAINS g MANHATTAN
+
+DATE 1 /16/2020 SIGNATURE OF ATTORNEY OF RECORD ADMITTED TO PRACTICE IN THIS DISTRICT
+
+brI NO I I YES (DATE ADMITTED Mo. Yr. RECEIPT ri Attorney Bar Code SI
+
+Magistrate Judge is to be designated by the Clerk of the Court.
+
+Magistrate Judge is so Designated.

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751892/EFTA02751892.md

@@ -0,0 +1,39 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE,
+
+Plaintiff,
+
+-against-DARREN/. 1NDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, et al.
+
+Defendant.
+
+The motion of Robert Samuel Glassman, Esq. , for admission to practice Pro Hac Vice in the above captioned action is granted.
+
+CV ( )
+
+ORDER FOR ADMISSION PRO HAC VICE
+
+Applicant has declared that he/she is a member in good standing of the bar(s) of the state(s) of California, District of Columbia ; and that his/her contact information is as follows
+
+(please print):
+
+Applicant's Name: Robert Samuel Glassman
+
+Firm Name: Panish Shea & Boyle LLP
+
+Address: 11111 Santa Monica Blvd., Suite 700
+
+City / State / Zip: Los Angeles, CA 90025
+
+Telephone / Fax: 310-477-1700/ 310.477-1699
+
+Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for
+
+Plaintiff, Jane Doe in the above entitled action;
+
+IT IS HEREBY ORDERED that Applicant is admitted to practice Pro I lac 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 / Magistrate Judge

marker2-fixhub/court-doe-v-indyke-00484/EFTA02751892/EFTA02751892.receipt.json

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751893/EFTA02751893.md

@@ -0,0 +1,71 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+►ANE **DOE,** 
+
+Plaintiff,
+
+-against- Civ.
+
+DARREN K. INDYKE and RICHARD D. KAHN, in their MOTION FOR ADMISSION capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, et al.
+
+### PRO HAC VICE
+
+Defendant.
+
+Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern Districts of New York, Robert Samuel Glassman, Esq. hereby move this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for Plaintiff, Jane Doe in the above-captioned action.
+
+I am in good standing of the bar(s) of the state(s) of California, District of Columbia 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: January 16, 2020 Respectfully Submitted,
+
+Robert Samuel Glassman
+
+Applicant Signature: ? -(96.-----
+
+Applicant's Name: Robert Samuel Glassman
+
+Firm Name: Panish Shea & Boyle LLP
+
+Address: 11111 Santa Monica Blvd., Suite 700
+
+City/State/Lip: Los Angeles, CA 90025
+
+Telephone/Fax: 310-477-1700 / 310.477-1699
+
+Email: glassman@psblaw.com
+
+![](_page_1_Picture_1.jpeg)
+
+## The State Bar of California
+
+OFFICE OF ATTORNEY REGULATION
+
+& CONSUMER RESOURCES
+
+180 Howard Street, San Francisco, CA 94105 888-800.3400 AttomeyRegulation@calbar.ca.gov
+
+# CERTIFICATE OF STANDING
+
+January 11, 2020
+
+TO WHOM IT MAY CONCERN:
+
+This is to certify that according to the records of the State Bar, ROBERT SAMUEL GLASSMAN, #269816 was admitted to the practice of law in this state by the Supreme Court of California on June 1, 2010 and has been since that date, and is at date hereof, an ACTIVE licensee of the State Bar of California; and that no recommendation for discipline for professional or other misconduct has ever been made by the Board of Trustees or a Disciplinary Board to the Supreme Court of the State of California.
+
+THE STATE BAR OF CALIFORNIA
+
+Dina DiLoreto Custodian of Records
+
+![](_page_2_Picture_1.jpeg)
+
+![](_page_2_Picture_2.jpeg)
+
+On behalf of JULIO A. CASTILLO, Clerk of the District of Columbia Court of Appeals. the District of Columbia Bar does hereby certify that
+
+atete t9T-Letto
+
+was duly qualified and admitted on May 13.2011 as an attorney and counselor entitled to practice before this Court; and is. on the date indicated below, an Active member in good standing of this Bar.
+
+![](_page_2_Picture_6.jpeg)
+
+Issued By: District of Columbia Bar Membership

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751896/EFTA02751896.md

@@ -0,0 +1,35 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE
+
+Plaintiff,
+
+1:20-cv -00484 ( )
+
+-against-DARREN'. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, et.al Defendant.
+
+The motion of Kevin R. Boyle practice Pro Hac Vice in the above captioned action is granted. , for admission to
+
+Applicant has declared that he/she is a member in good standing of the bar(s) of the state(s) of California and Washington D.C. ; and that his/her contact information is as follows
+
+(please print):
+
+Applicant's Name: Kevin R. Boyle
+
+Firm Name: PANISH SHEA & BOYLE, LLP
+
+Address: 11111 Santa MonicaBlvd. Ste 700
+
+ORDER FOR ADMISSION PRO HAC VICE
+
+City / State / Zip: Los Angeles, California 90025
+
+Telephone / Fax: 310-477-1700/310-477-1699
+
+Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Plaintiff, Jane Doe 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 / Magistrate Judge

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751897/EFTA02751897.md

@@ -0,0 +1,78 @@
+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE
+
+Plaintiff,
+
+-against-
+
+DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, et.al
+
+Defendant.
+
+1:20- Civ, 00484
+
+#### 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, Kevin R. Boyle hereby move this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for Jane Doe in the above-captioned action.
+
+I am in good standing of the bar(s) of the state(s) of California and Washington D.0 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: January 10, 2020 Respectfully Submitted,
+
+Kevin R. Boyle
+
+Applicant Signature:
+
+Applicant's Name: Kevin R Boyle
+
+Firm Name: PANISH SHEA & BOYLE, LLP
+
+Address: 11111 Santa Monica Blvd. Ste 700
+
+City/State/Zip: Los Angeles, California 90025
+
+Telephone/Fax: 310-477-1700/ 310-477-1699
+
+Email: Boyle@psblaw.com
+
+![](_page_1_Picture_78.jpeg)
+
+![](_page_1_Picture_79.jpeg)
+
+On behalf of JULIO A. CASTILLO, Clerk of the District of Columbia Court of Appeals,  
+the District of Columbia Bar does hereby certify that
+
+*Kevin R Boyle*
+
+was duly qualified and admitted on June 4, 1999 as an attorney and counselor entitled to  
+practice before this Court; and is, on the date indicated below, an Active member in good  
+standing of this Bar.
+
+![](_page_1_Picture_83.jpeg)
+
+![](_page_2_Picture_1.jpeg)
+
+## The State Bar of California
+
+OFFICE OF ATTORNEY REGULATION
+
+& CONSUMER RESOURCES
+
+180 Howard Street, San Francisco, CA 94105 888-800-3400
+
+# CERTIFICATE OF STANDING
+
+TO WHOM IT MAY CONCERN:
+
+AttomeyRegulation@calba cca.gov
+
+January 11, 2020
+
+This is to certify that according to the records of the State Bar, KEVIN RICHARD BOYLE, #192718 was admitted to the practice of law in this state by the Supreme Court of California on December 11, 1997 and has been since that date, and is at date hereof, an ACTIVE licensee of the State Bar of California; and that no recommendation for discipline for professional or other misconduct has ever been made by the Board of Trustees or a Disciplinary Board to the Supreme Court of the State of California.
+
+THE STATE BAR OF CALIFORNIA
+
+Dina DiLoreto Custodian of Records

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751900/EFTA02751900.md

@@ -0,0 +1,48 @@
+DOE, JANE
+
+## COURT DISTRICT STATES UNITED YORK NEW OF DISTRICT SOUTHERN
+
+1:20-cv-00484 No. Case
+
+## Plaintiff,
+
+v.
+
+D. RICHARD and INDYKE K. DARREN the of executors as capacities their in KAHN, 7 EPSTEIN, E. JEFFREY OF ESTATE individual, an MAXWELL, GHISLAINE 8
+
+## Defendants. 911
+
+17 • 2020 16, January Dated: II
+
+## MOTION PLAINTIFF'S OF NOTICE UNDER PROCEED TO LEAVE FOR PSEUDONYM
+
+allowing order an for Court this move record, of attorneys her through Doe, Jane Plaintiff in request this makes Plaintiff pseudonyms. using matter -captioned above the in proceed to her herewith files Plaintiff support, In injury. and retaliation harassment, from herself protect to order Pseudonym. by Proceed to Motion her of Support in Memorandum Plaintiffs the
+
+submitted, Respectfully
+
+pending) (admission Boyle Kevin pending) (admission Glassman Robert pending) (admission Werksman Nathan
+
+LLP BOYLE & SHEA PANISH 700 Suite Blvd., Monica Santa 11111
+
+90025 CA Angeles, Los 477-1700 (310) Telephone: 477-1699 (310) Facsimile:
+
+boyle@psblaw.com glassman@psblaw.com werksman@psblaw.com
+
+Morelli P. Benedict /s/ Morelli P. Benedict Sirotkin T. David Mahoney A. Sara
+
+PLLC FIRM LAW MORELLI II 28
+
+PANISH SHEA & BOYLE LLP  
+11111 Santa Monica Boulevard, Suite 700  
+Los Angeles, California 90025  
+310.477.1700 phone • 310.477.1699 fax
+
+777 Third Avenue, 31{sup}`st` Floor  
+New York, NY 10017  
+Telephone: (212) 751-9800  
+Facsimile: (212) 751-0046  
+bmorelli@morellilaw.com  
+dsirotkin@morellilaw.com  
+smahoney@morellilaw.com
+
+*Attorneys for Plaintiff*

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751902/EFTA02751902.md

@@ -0,0 +1,44 @@
+1  
+2 **UNITED STATES DISTRICT COURT**  
+3 **SOUTHERN DISTRICT OF NEW YORK**
+
+4 JANE DOE,
+
+5 Plaintiff,
+
+6 v.
+
+7 DARREN K. INDYKE and RICHARD D.  
+8 KAHN, in their capacities as executors of the  
+9 ESTATE OF JEFFREY E. EPSTEIN,  
+10 GHISLAINE MAXWELL, an individual,
+
+11 Defendants.
+
+12 Case No. 1:20-cv-00484
+
+13 **[PROPOSED] ORDER ON**  
+14 **PLAINTIFF'S MOTION FOR LEAVE**  
+15 **TO PROCEED UNDER**  
+16 **PSEUDONYM**
+
+17  
+18 The Court, having reviewed the Plaintiff's Motion to Proceed by Pseudonym, the  
+19 Plaintiff's memorandum of law in support of her motion and any opposition thereto, the pleadings  
+20 and papers filed herein, and upon any such other matters as may be presented to the Court at the  
+21 time of the hearing on this motion, if any, hereby GRANTS the Plaintiff's Motion to Proceed by  
+22 Pseudonym as follows:
+
+23 Jane Doe is permitted to proceed by pseudonym in the above-captioned matter.  
+24
+
+25  
+26 DATED: \_\_\_\_\_
+
+27 \_\_\_\_\_  
+28 United States District Judge
+
+PANISH SHEA & BOYLE LLP  
+11111 Santa Monica Boulevard, Suite 700  
+Los Angeles, California 90025  
+310.477.1700 phone • 310.477.1699 fax

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+  "text_format": "markdown"
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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751903/EFTA02751903.md

@@ -0,0 +1,323 @@
+a., 11 g O1 01,4 {sup}`13` 14 HE a 31 14 x2 2a 15 v) a g X \$k 16
+
+# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE, Case No. 1:20-cv-00484
+
+Plaintiff,
+
+v.
+
+DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual,
+
+Defendants.
+
+#### MEMORANDUM IN SUPPORT OF PLAINTIFF'S MOTION TO PROCEED BY PSEUDONYM
+
+Plaintiff Jane Doe ("Plaintiff"), by her undersigned attorneys, respectfully submits this memorandum of law in support of her motion for leave to proceed under a pseudonym.
+
+#### I. INTRODUCTION
+
+Plaintiff Jane Doe suffered tremendous harm as a result of being sexually abused as a child by the late Jeffrey Epstein. Epstein and his associates, in particular, Ghislaine Maxwell, coerced Jane Doe into becoming their sexual puppet for years through power, money and exploitation. And like countless others, Plaintiff was victimized for so long by Epstein and Maxwell and at such an early age that she has done everything she could to remain anonymous and live a normal life now despite constant media requests for interviews and statements.
+
+The details underlying Plaintiff's sexual abuse are highly personal, intimate and humiliating to Plaintiff. Jane Doe has suffered drastically due to the Defendants' actions. Keeping her identity protected from public disclosure in this already high-profile matter is imperative. Indeed, public disclosure of her name in this litigation will expose some of the most intimate and humiliating moments of Plaintiff's life, furthering her ongoing psychological harm and injuring her family, including young children.
+
+Additionally, there is no public interest in revealing the identity of one of Epstein's many victims; to the contrary, allowing Plaintiff to proceed by pseudonym fosters the public interest in having victims come forward. Further, as other victims have already stated, revealing Plaintiffs
+
+1 identity could interfere with the Government's ongoing investigation of Epstein's associates.
+
+2 For the foregoing reasons and those that follow, Plaintiff Jane Doe respectfully
+
+3 requests that this Court permit her to proceed in this case under a pseudonym.
+
+#### 4 II. ARGUMENT
+
+5 The Federal Rules of Civil Procedure do not explicitly authorize, nor absolutely prohibit,
+
+6 the use of fictitious names by plaintiffs or other parties. In EW v. New York Stook Ctr., 213
+
+7 F.R.D. 108 (2d Cir. 2003), the Second Circuit declared, "(a) plaintiff is entitled to proceed under a
+
+19 nature; (2) whether identification poses a risk of retaliatory physical or mental harm to the ...party
+
+20 seeking proceed anonymously...; (3) whether identification presents other harms and the likely
+
+21 severity of those harms...(4) whether the plaintiff is particularly vulnerable to the possible harms
+
+22 of disclosure; (5) whether the suit is challenging the actions of the government or that of private
+
+23 parties, (6) whether the defendant is prejudiced by allowing the plaintiff to press his claims
+
+24 anonymously, ...; (7) whether the plaintiffs identity has thus far been kept confidential, ; (8)
+
+25 whether the public's interest in the litigation is furthered by requiring the plaintiff to disclose his
+
+26 identity..." Id. at 190 (internal citations removed).
+
+27 New York state has made clear its intentions to protect the identities of survivors of sexual
+
+pseudonym where revealing the plaintiffs name subjects him or her to the risk of public
+
+disapproval, harassment, or bodily harm."
+
+In Does I Thru XXIII v. Advanced Textile Corp. 214 FR.3d 1058 (9th Cir. 2000), the Ninth
+
+Circuit held that "a party may preserve his or her anonymity in judicial proceedings in special
+
+circumstances when the party's need for anonymity outweighs prejudice to the opposing party and
+
+the public's interest in knowing the party's identity." Id. at 1067. The Second Circuit has endorsed
+
+this balancing of interests when determining whether a plaintiff may act under a pseudonym.
+
+Sealed Plaintiff v. Sealed Defendant #1,537 F.3d 189 (2d Cir. 2008). The Second Circuit has
+
+gathered a non-exhaustive list of factors to consider when determining the need for anonymity.
+
+This list of factors includes:
+
+"(1) whether the litigation involves matters that are highly sensitive and of a personal
+
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+have granted anonymity to protect against disclosure of a wide range of issues involving matters of the utmost intimacy, including sexual assault. Indeed, many states in this country, including New York, have enacted laws to protect the anonymity of sexual assault victims." Doe No. 2 v. Kolko, 242 F.R.D. 193, 1% (E.D.N.Y. 2006) (internal citations omitted). Specifically, N.Y. Educ. Law § 6448 states:
+
+Pursuant to subdivision (i) of rule three thousand sixteen of the civil practice law and rules, in any proceeding brought against an institution which seeks to vacate or modify a finding that a student was responsible for violating an institutions rules regarding a violation covered by this article, the name and identifying biographical information of any student shall be presumptively confidential and shall not be included in the pleadings and other papers from such proceeding absent a waiver or cause shown as determined by the court. Such witnesses shall be identified only as numbered witnesses. If such a name or identifying biographical information appears in a pleading or paper filed in such a proceeding, the court, absent such a waiver or cause shown, shall direct the clerk of the court to redact such name and identifying biographical information and so advise the parties.
+
+Additionally, N.Y. Civ. Rights Law § 50-b states:
+
+The identity of any victim of a sex offense, as defined in article one hundred thirty or section 255.25, 255.26 or 255.27 of the penal law, or of an offense involving the alleged transmission of the human immunodeficiency virus, shall be confidential. No report, paper, picture, photograph, court file or other documents, in the custody or possession of any public officer or employee, which identifies such a victim shall be made available for public inspection. No such public officer or employee shall disclose any portion of any police report, court file, or other document, which tends to identify such a victim except as provided in subdivision two of this section.
+
+Further, "[u]pon approving New York's rape shield law, then Governor Mario stated, 'sexual assault victims have unfortunately had to endure a terrible invasion of their physical privacy. They have a right to expect that this violation will not be compounded by a further invasion of their privacy.'" Doe No. 2 v. Kolko, 242 F.R.D. 193, 196 (E.D.N.Y. 2006) (internal citations omitted).
+
+# A. GOOD CAUSE EXISTS FOR PLAINTIFF TO PROCEED USING A PSEUDONYM
+
+Here, all of the relevant factors strongly weigh in favor of granting Plaintiff's motion to file this case using a pseudonym. Indeed, for similar reasons to those discussed below, numerous courts have permitted Epstein's victims to proceed under pseudonyms in prior cases. See Order, Doe v. Epstein, No. 08-cv-80119 (S.D. Fla. Aug. 7, 2009), ECF No. 253 (consolidating 11 Doe
+
+1 2 3 4 5 6 7 8 9 10 11 12 cases against Epstein and every plaintiff to proceed anonymously in the style of the case); see also Hr'g Tr., United States v. Epstein, No. I9-cr-490 (S.D.N.Y. Aug. 27, 2019), ECF No. 53 (allowing eight of Epstein's victims to present testimony under protective pseudonyms after Epstein's death in connection with criminal case); Joint Rule 26(f) Report, Jane Doe 43 v. Epstein et al., No. 17 cv-616 (S.D.N.Y. Apr. 5, 2017), ECF No. 28 at 4 (Rule 26 Report noting that "Idhie to the nature of the claim, the Plaintiff has proceeded anonymously through a pseudonym"); Order, Jane Doe No. 103 v. Epstein, No. 10-cv-80309 (S.D. Fla. Mar. 9, 2010), ECF No. 5 (granting motion to proceed anonymously). These courts have recognized that, throughout their litigation again Epstein, these women "will be required to disclose highly sensitive and intimate information," and disclosure of their real names "will cause . . . much additional embarrassment, humiliation, and psychological trauma," as well as "adverse professional and economic consequences." See Order, Doe v. Epstein, No. 08-cv-80893 (S.D. Fla. Oct. 6, 2008), ECF No. 15 at 2-3.
+
+13
+
+14 15 16 17 18 19 20 Jane Doe filed her complaint using a pseudonym in order to protect her identity so as to mitigate damage done to her and her name as a result of the incidents alleged in her complaint. The details surrounding her sexual abuse are highly sensitive and of a personal nature. There was a fundamental privacy interest that was violated when Jane Doe was sexually assaulted and, as stated by New York's Governor =, exposure of Jane Doe's true identity would only compound that violation. Doe No. 2 v. Kolko, 242 F.R.D. 193, 196 (E.D.N.Y. 2006) (internal citations omitted).
+
+21 22 23 24 25 26 27 28 Indeed, courts have recognized that "sexual assault victims are a paradigmatic example of those entitled to a grant of anonymity." Doe No. 2 v. Kolko, 242 F.R.D. 193, 195 (E.D.N.Y. 2006); see also Doe v. Skyline Automobiles Inc., 375 F. Supp. 3d 401, 405 (S.D.N.Y. 2019) (finding allegations of sexual assault and ongoing sexual harassment were "highly sensitive and of an extremely personal nature"); Doe v. Colgate Univ., No. 15-cv- 1069, 2016 WL 1448829, at \*3 (N.D.N.Y. Apr. 12, 2016); Doe v. Greiner, 662 F. Supp. 2d 355, 363 n.8 (S.D.N.Y. 2009) (noting that "the identity of a minor who was the victim of a sex assault" is among the "exceptional circumstances" justifying anonymity in court materials). For that reason alone,
+
+### 1. This Case Involves Details of a Highly Sensitive and Personal Nature
+
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+permitting Plaintiff to proceed pseudonymously is warranted.
+
+Moreover, because of the significant public attention surrounding Epstein's arrest and untimely death, all of Plaintiffs potential harms would be more likely than not intensified should her identity become public. Plaintiff has a legitimate fear that her public identification could put her job, relationships and family at risk. And even though Epstein is deceased, a number of his associates, like Maxwell, are the subjects of potential criminal investigation and civil lawsuits. Many of these same individuals have already proven that they will intimidate and attempt to silence any of his identifiable victims. See Decision and Order Remanding Def., United States v. Epstein, No. 19- cr-490 (S.D.N.Y. July 18, 2019), ECF No. 32 at 15, 15-18. This well-established history of retaliation justifies permitting Plaintiff to proceed pseudonymously. See, e.g., Doe v. Sclera Capital LLC, No. 18-cv-1769, 2019 WL 1437520, at \*5 (S.D.N.Y. Mar. 31, 2019) ("[C]ourts have allowed plaintiffs to proceed anonymously where disclosure of their identities created a risk of harm from third parties unaffiliated with the case."); L.N. v. Schwarzenegger, No. 06-cv-2042, 2007 WL 662463, at \*16 (E.D. Cal. Feb. 8, 2007); see also Does I thru XXIII v. Advanced Textile Corp., 214 F.3d 1058, 1070 (9th Cir. 2000) (noting that plaintiffs may proceed anonymously "to protect themselves from retaliation by third parties").
+
+#### 2. Defendants Will Not Suffer Prejudice
+
+Allowing Jane Doe to proceed by pseudonym will not prejudice the Defendants or interfere in any way with the policy underlying Rule 10 of the Federal Rules of Civil Procedure which apprises the parties of the identity of their opponent. Moreover, courts also balance the harm to the plaintiff with the potential prejudice to the defendant. See Sealed Plaintiff 537 F.3d at 189. The relevant considerations are the damage to the defendant's reputation caused by responding to anonymous allegations, difficulties in conducting discovery, and the fundamental fairness of proceeding in such a manner. E.W. v. N.Y. Blood Ctr., 213 F.R.D. 108, 112 (E.D.N.Y. 2009). None of these factors weigh against allowing Plaintiff to proceed by pseudonym here.
+
+In light of Epstein's already well-known criminal and notorious actions, this case, more is one in which "any reputational harm to defendants has already been inflicted." Doe #1 v. Syracuse Univ., No. 18- cv-496, 2018 WL 7079489, at\*8 (N.D.N.Y. Sep. 10, 2018). Further, Epstein's
+
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+estate and Maxwell will not be prevented from conducting discovery and reasonably defending this case. Plaintiffs counsel will provide Plaintiff's name to Defendants' counsel under conditions that will reasonably protect the safety of Plaintiff, her family, and potential witnesses. Where a defendant's counsel is made aware of plaintiff's identity, there is no "prejudice to [defendant's] ability to conduct discovery or try the matter if plaintiff were to proceed under a pseudonym." See E. W, 213 F.R.D. at 112; see also Kolko, 242 F.R.D. at 198 (finding that where defendants know plaintiffs identity, "defendants will not be hampered or inconvenienced merely by plaintiffs anonymity in court papers").
+
+## 3. Public Polict\$upports Keeping Plaintiff's Name Protected
+
+Here, there is no public interest served by revealing the identity of Plaintiff Jane Doe who is one of Epstein's many victims. To the contrary, the public interest would be best served by permitting Plaintiff to seek justice under a protective pseudonym. As discussed above, New York State has a strong public policy interest in protecting the privacy interests of victims of sexual abuse, as demonstrated by Section 50-b of the Civil Rights Law, which protects sex-abuse survivors from undesired identification in a range of public administrative contexts, including certain court proceedings. See N.Y. Civil Rights Law § 50-b (McKinney 2019) (shielding sexabuse victims from identification in, among other things, any "police report, court file, or other document").
+
+Moreover, in addition to the public's general interest in protecting the well-being of victims, "the public generally has a strong interest in protecting the identities of sexual assault victims so that other victims will not be deterred from reporting such crimes." See Kolko, 242 F.R.D. at 195-96. In consideration of that strong public policy, federal courts have permitted victims of sexual assault to proceed anonymously in similar cases.
+
+## 4. Plaintiff Jane Doe Has Preserved Her Confidentiality To Date
+
+Plaintiff has worked diligently to protect her identity. Indeed, despite numerous and ongoing attempts to interview her by the media and journalists, she has never spoken to the press or publicly identified herself in any way associated with her allegations. In the related criminal case, federal prosecutors have carefully protected her identity. These efforts weigh in favor of her
+
+1 2 1437520, WL 2019 Capital, Solera e.g., See, action. civil her in pseudonym by proceed to petition date" to preserved been has public the to anonymity Doe's that fact "the that (finding \*7 at
+
+3
+
+pseudonymously). proceeding of favor in counsels
+
+#### CONCLUSION HI. 4
+
+grant Court the that requests respectfully Plaintiff reasons, foregoing the For 5
+
+pseudonym. a using complaint her file to her allow and motion Plaintiff's 6
+
+submitted, Respectfully 7
+
+8
+
+9
+
+2020 16, January Dated:
+
+Boyle Kevin 10 pending) (admission
+
+P.. 11 pending) (admission Glassman Robert pending) (admission Werksman Nathan
+
+12 s e t
+
+LLP BOYLE & SHEA PANISH 700 Suite Blvd., Monica Santa 11111 13 90025 CA Angeles, Los < o1 14 477-1700 (310) Telephone: 15 477-1699 (310) Facsimile: boyle@psblaw.com 16 glassman@psblaw.com werksman@psblaw.com Morelli P. Benedict /s/ Benedict 18 Morelli P. 19 Sirotkin T. David Mahoney A. Sara
+
+:,,4 cf {sup}`O` igg
+
+t• 2 01
+
+II g Can en
+
+X —
+
+17 n <=
+
+20
+
+PLLC FIRM LAW MORELLI
+
+Floor 31" Avenue, Third 777 21 10017 NY York, New 22 751-9800 (212) Telephone: 23 751-0046 (212) Facsimile: bmorelli@morellilaw.com dsirotkin@morellilaw.com 24 smahoney@morellilaw.com
+
+25
+
+26
+
+Plaintiff for Attorneys
+
+27
+
+28

marker2-fixhub/court-doe-v-indyke-00484/EFTA02751903/EFTA02751903.receipt.json

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751910/EFTA02751910.md

@@ -0,0 +1,40 @@
+4 JANE DOE,
+
+5 Plaintiff,
+
+I
+
+a ,a a >- zi
+
+t' 2
+
+02iii < g
+
+X 2
+
+c<8
+
+5. 7-1 In v.
+
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+Case No. 1:20-cv-00484
+
+DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual,
+
+Defendants.
+
+DECLARATION OF ROBERT SAMUEL GLASSMAN IN SUPPORT OF APPLICATION FOR ADMISSION PRO HAC VICE
+
+12 II I, Robert Samuel Glassman, hereby declare as follows:
+
+- 1. I have never been convicted of a felony. 14 2. I have never been censured, suspended, disbarred or denied admission or readmission by 15 any court. 16 3. There is no pending disciplinary proceedings against me in any state or federal court.
+  - 4. I am a member in good standing of the bars of the State of California and Washington D.C.
+
+I hereby declare under penalty of perjury that the foregoing statements are true and correct.
+
+Dated: January 21, 2020
+
+Respectfully submitted,
+
+Robert S. Glassman PANISH SHEA & BOYLE LLP 11111 Santa Monica Blvd., Suite 700 Los Angeles, CA 90025 Telephone: (310) 477-1700 Facsimile: (310) 477-1699 glassman@psblaw.com Attorneys for Plaintiff

marker2-fixhub/court-doe-v-indyke-00484/EFTA02751910/EFTA02751910.receipt.json

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751911/EFTA02751911.md

@@ -0,0 +1,21 @@
+![](_page_0_Picture_1.jpeg)
+
+## The State Bar of California
+
+OFFICE OF ATTORNEY REGULATION
+
+& CONSUMER RESOURCES
+
+{sup}`180`Howard Street, San Francisco, CA 94105 88B-800-3400 Attomeynegulation@calbar.ca.gov
+
+## CERTIFICATE OF STANDING
+
+January 11, 2020
+
+TO WHOM IT MAY CONCERN:
+
+This is to certify that according to the records of the State Bar, ROBERT SAMUEL GLASSMAN, #269816 was admitted to the practice of law in this state by the Supreme Court of California on June 1, 2010 and has been since that date, and is at date hereof, an ACTIVE licensee of the State Bar of California; and that no recommendation for discipline for professional or other misconduct has ever been made by the Board of Trustees or {sup}`a`Disciplinary Board to the Supreme Court of the State of California.
+
+THE STATE BAR OF CALIFORNIA
+
+Dina DiLoreto Custodian of Records

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751912/EFTA02751912.md

@@ -0,0 +1,13 @@
+![](_page_0_Picture_1.jpeg)
+
+![](_page_0_Picture_2.jpeg)
+
+On behalf of JULIO A. CASTILLO, Clerk of the District of Columbia Court of Appeals, the District of Columbia Bar does hereby certify that
+
+byeasmen
+
+was duly qualified and admitted on May 13.2011 as an attorney and counselor entitled to practice before this Court; and is. on the date indicated below, an Active member in good standing of this Bar.
+
+![](_page_0_Picture_6.jpeg)
+
+Issued By: District of Columbia Bar Membership

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+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-00484/EFTA02751913/EFTA02751913.md

@@ -0,0 +1,37 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE,
+
+Plaintiff,
+
+-against-DARREN/. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, et al.
+
+Defendant.
+
+The motion of Robert Samuel Glassman, Esq. , for admission to practice Pro Hac Vice in the above captioned action is granted.
+
+1:20 cv 00484 ( )
+
+ORDER FOR ADMISSION PRO HAC VICE
+
+Applicant has declared that he/she is a member in good standing of the bar(s) of the state(s) of California, District of Columbia ; and that his/her contact information is as follows
+
+(please print):
+
+Applicant's Name: Robert Samuel Glassman
+
+Firm Name: Panish Shea & Boyle LLP
+
+Address: 11111 Santa Monica Blvd., Suite 700
+
+City / State / Zip: Los Angeles, CA 90025
+
+Telephone / Fax: 310-477-1700/ 310.477-1699
+
+Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for Plaintiff, Jane Doe in the above entitled action;
+
+IT IS HEREBY ORDERED that Applicant is admitted to practice Pro I lac 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 arc subject to the Local Rules of this Court, including the Rules governing discipline of attorneys.
+
+Dated:
+
+United States District / Magistrate Judge

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751914/EFTA02751914.md

@@ -0,0 +1,35 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+►ANE **DOE,** 
+
+**Plaintiff,** 
+
+**-against- 1:20 Civ. 00484 ( )** 
+
+**DARREN g INDYKE and RICHARD D. KAHN, in their** MOTION FOR ADMISSION capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, et al.
+
+## PRO HAC VICE
+
+Defendant.
+
+Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern Districts of New York, Robert Samuel Glassman, Esq. hereby move this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for Plaintiff, Jane Doe in the above-captioned action.
+
+I am in good standing of the bar(s) of the state(s) of California, District of Columbia 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: January 14 2020 Respectfully Submitted,
+
+Robert Samuel Glassman
+
+Applicant Signature:
+
+Applicant's Name: Robert Samuel Glassman
+
+Firm Name: Panish Shea & Boyle LLP
+
+Address: 11111 Santa Monica Blvd., Suite 700
+
+City/State/Lip: Los Angeles, CA 90025
+
+Telephone/Fax: 310.477.1700 / 310.477-1699
+
+Email: glassman@psblaw.com

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751915/EFTA02751915.md

@@ -0,0 +1,52 @@
+1  
+2 **UNITED STATES DISTRICT COURT**  
+3 **SOUTHERN DISTRICT OF NEW YORK**
+
+4 JANE DOE,
+
+5 Plaintiff,
+
+6 v.
+
+7 DARREN K. INDYKE and RICHARD D.  
+8 KAHN, in their capacities as executors of the  
+9 ESTATE OF JEFFREY E. EPSTEIN,  
+GHISLAINE MAXWELL, an individual,
+
+10 Defendants.
+
+Case No. 1:20-cv-00484
+
+11 **DECLARATION OF KEVIN R.  
+12 BOYLE IN SUPPORT OF  
+13 APPLICATION FOR ADMISSION  
+14 PRO HAC VICE**
+
+12 I, Kevin R. Boyle, hereby declare as follows:
+
+1. 13 1. I have never been convicted of a felony.
+2. 14 2. I have never been censured, suspended, disbarred or denied admission or readmission  
+   15 by any court.
+3. 16 3. There is no pending disciplinary proceedings against me in any state or federal court.
+4. 17 4. I am a member in good standing of the bars of the State of California and Washington D.C.
+
+18 I hereby declare under penalty of perjury that the foregoing statements are true and correct.
+
+19  
+20 Respectfully submitted,
+
+21  
+22 Dated: January 21, 2020
+
+23 Kevin Boyle  
+24 PANISH SHEA & BOYLE LLP  
+25 11111 Santa Monica Blvd., Suite 700  
+26 Los Angeles, CA 90025  
+27 Telephone: (310) 477-1700  
+28 Facsimile: (310) 477-1699  
+boyle@psblaw.com
+
+PANISH SHEA & BOYLE LLP  
+11111 Santa Monica Boulevard, Suite 700  
+Los Angeles, California 90025  
+310.477.1700 phone • 310.477.1699 fax

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751916/EFTA02751916.md

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+![](_page_0_Picture_68.jpeg)
+
+![](_page_0_Picture_69.jpeg)
+
+On behalf of JULIO A. CASTILLO, Clerk of the District of Columbia Court of Appeals,  
+the District of Columbia Bar does hereby certify that
+
+*Kevin R Boyle*
+
+was duly qualified and admitted on June 4, 1999 as an attorney and counselor entitled to  
+practice before this Court; and is, on the date indicated below, an Active member in good  
+standing of this Bar.
+
+![](_page_0_Picture_73.jpeg)
+
+![](_page_1_Picture_1.jpeg)
+
+## The State Bar of California
+
+OFFICE OF ATTORNEY REGULATION
+
+& CONSUMER RESOURCES
+
+180 Howard Street, San Francisco, CA 94105 888-800-3400 AttorneyRegulationeacalbar.ca.gov
+
+## CERTIFICATE OF STANDING
+
+January 11, 2020
+
+TO WHOM IT MAY CONCERN:
+
+This is to certify that according to the records of the State Bar, KEVIN RICHARD BOYLE, #192718 was admitted to the practice of law in this state by the Supreme Court of California on December 11, 1997 and has been since that date, and is at date hereof, an ACTIVE licensee of the State Bar of California; and that no recommendation for discipline for professional or other misconduct has ever been made by the Board of Trustees or a Disciplinary Board to the Supreme Court of the State of California.
+
+THE STATE BAR OF CALIFORNIA
+
+Dina Diloreto Custodian of Records

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751918/EFTA02751918.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE
+
+Plaintiff,
+
+1:20-cv -00484 ( JGK )
+
+-against-DARREN.. INDYKE and RICHARD D. KAHN. in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN. et.al Defendant.
+
+> The motion of Kevin R. Boyle for admission to
+
+ORDER FOR ADMISSION PRO HAC VICE
+
+practice Pro Hac Vice in the above captioned action is granted.
+
+Applicant has declared that he/she is a member in good standing of the bar(s) of the state(s) of California and Washington D.C. ; and that his/her contact information is as follows
+
+(please print):
+
+Applicant's Name: Kevin R. Boyle
+
+Firm Name: PANISH SHEA & BOYLE, LLP
+
+Address: 11111 Santa Monica Blvd. Ste 700
+
+City / State / Zip: Los Angeles, California 90025
+
+Telephone / Fax: 310-477-1700/310-477-1699
+
+Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for
+
+Plaintiff, Jane Doe in the above entitled action;
+
+IT IS HEREBY ORDERED that Applicant is admitted to practice Pro I lac 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 / Magistrate Judge

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751919/EFTA02751919.md

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE
+
+Plaintiff,
+
+-against-
+
+DARREN I INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, et.al
+
+Defendant.
+
+1:20- Civ. 00484 ( IGK )
+
+## 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 Kevin R. Boyle hereby move this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for Jane Doe in the above-captioned action.
+
+I am in good standing of the bar(s) of the state(s) of California and Washington D.0 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: January 10, 2020 Respectfully Submitted,
+
+Kevin R. Boyle
+
+Applicant Signature:
+
+Applicant's Name: Kevin R Boyle
+
+Firm Name: PANISH SHEA & BOYLE, LLP
+
+Address: 11111 Santa Monica Blvd. Ste 700
+
+City/State/Zip: Los Angeles, California 90025
+
+Telephone/Fax: 310-477-1700/ 310-477-1699
+
+Email: Boyle@psblaw.com

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751920/EFTA02751920.md

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+JANE DOE,
+
+Plaintiff,
+
+v.
+
+# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, OHISLAINE MAXWELL, an individual,
+
+Defendants.
+
+Case No. 1:20-cv-00484
+
+## COMPLAINT FOR DAMAGES
+
+DEMAND FOR JURY TRIAL
+
+Plaintiff Jane Doe ("Doe" or "Plaintiff") alleges as follows:
+
+## INTRODUCTION
+
+1. This case arises out of years of sexual abuse and exploitation of a young girl by notorious pedophile and convicted sex offender Jeffrey Epstein ("Epstein"). It all started in 1994 when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a summer camp in Michigan. Jane Doe was their first known victim and was subsequently abused by Epstein and Maxwell for years as a young girl, suffering unimaginable physical and psychological trauma and distress. Despite that, Jane Doe has persevered and survived to tell her story, to hold her perpetrators accountable and to seek justice for the atrocities committed against her.
+
+2. Throughout his life, Epstein systematically perpetrated acts of molestation, exploitation, assault and rape on hundreds of young girls. Epstein's system of abuse was facilitated in large part by his co-conspirator and accomplice, Maxwell, who helped supply him with a steady stream of young and vulnerable girls—many of whom were fatherless, like Jane Doe, and came from struggling families.
+
+1 3. This system, which took years to develop, all started with them exploiting and  
+2 abusing Jane Doe who they used as a guinea pig to refine their criminal enterprise and widen their  
+3 network of additional sexual abuse victims.
+
+4 **THE PARTIES**
+
+5 4. Plaintiff Jane Doe is a citizen of the State of California. At all times relevant to this  
+6 suit, Doe was a minor child living in Florida and New York and who was sexually abused while  
+7 she was a minor by Defendants in New York.
+
+8 5. Defendant Ghislaine Maxwell is domiciled in the State of New York.
+
+9 6. Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the  
+10 Estate of Jeffrey E. Epstein.
+
+11 7. Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the  
+12 Estate of Jeffrey E. Epstein.
+
+13 **JURISDICTION AND VENUE**
+
+14 8. Plaintiff is domiciled in California.
+
+15 9. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin  
+16 Islands at the time of his death. As the legal representatives of the Estate of Jeffrey E. Epstein,  
+17 Darren K. Indyke and Richard D. Kahn are deemed citizens of the U.S. Virgin Islands. The matter  
+18 in controversy exceeds the sum of \$75,000, and therefore jurisdiction in this Court is proper. 28  
+19 U.S.C. § 1332(c)(2).
+
+20 10. Ghislaine Maxwell is domiciled in New York.
+
+21 11. A substantial part of the events giving rise to these causes of action occurred in the  
+22 Southern District of New York, thus venue in this district is proper. 28 U.S.C. § 1391(b)(2).
+
+23 **JURY DEMAND**
+
+24 12. Plaintiff hereby demands a trial by jury on all of her claims in this action.
+
+25 **FACTUAL ALLEGATIONS**
+
+26 **Epstein and Maxwell's Abuse of Doe**
+
+27 13. In the summer of 1994, Jane Doe met Jeffrey Epstein and Ghislaine Maxwell at  
+28 Interlochen Arts Camp in Michigan when she was only 13-years-old. Doe was there as a student
+
+I in the voice program. Doe was sitting alone on a bench between classes when Epstein and 2 Maxwell approached her. Epstein bragged to her about being a patron of the arts and giving 3 scholarships to talented young artists like Doe. Epstein and Maxwell probed her at length about 4 her background, family situation and where she lived. As Doe got up to leave, Epstein requested 5 her mother's phone number back in Florida. She was alarmed by his request, but also feared that 6 she could not refuse the older man's request so she complied and provided him with the phone 7 number.
+
+8 14. Several weeks later, once Doe had returned from Michigan to Florida, Epstein 9 called Doe's home. Epstein first spoke with Doe's mother about how he mentors young kids and 10 provides scholarships for the arts. He requested to speak to Doe and invited her and her mother to .-3a. 11 his mansion in Palm Beach. He sent a driver across town to pick them up.
+
+t4 0 t 12 15. Over the course of the next several months, Epstein and Maxwell attempted to O . 4 13 groom and mentor 13-year-old Jan Doe. Epstein gave himself the name of Doe's "godfather" 14 while Maxwell acted like an older sister to her. They took her to movies, went shopping with her i lit 15 and lounged around Epstein's estate with her. Epstein and Maxwell then started to make sexual references when they were with her. For instance, Maxwell told Doe that having sex with exboyfriends was easy because once you slept with them "they've been grandfathered in and you could go back and fuck them whenever you wanted." Epstein also started to slowly display his pedophilic ways when shopping with Doe and Maxwell. Instead of Doe picking out clothes she wanted to wear, Epstein insisted that she pick out and wear little children's cotton underwear. Also, after nearly every visit with Epstein and Maxwell, Epstein sent Doe home with two or three one-hundred-dollar bills to give her mother since "she's having a hard time and struggling as a widow." 18 19 20 21 22 23
+
+16. While these visits made Doe extremely uncomfortable, Epstein and Maxwell made her feel she could not refuse them. During this time, Epstein started to pay for voice lessons for Doe and insisted that Doe could not advance her career in any way without him. When Doe expressed hesitation about spending time with Epstein and Maxwell or acquiescing to their desires, Epstein and Maxwell would threaten Doe, and scold her for being "ungrateful". 24 25 26 27 28
+
+1
+
+2
+
+3
+
+4
+
+5
+
+6
+
+7
+
+8
+
+9
+
+10
+
+11
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+14
+
+I 11 15 20. In 1996, when Doe was 16-years-old, Epstein moved Doe to New York City. At g E 16 first, Epstein put Doe up in his apartment on 65th Street and 2nd Avenue. After a few months, n 17 Epstein co-signed the lease for Doe and Doe's mother for an apartment. Additionally, Epstein paid 18 her tuition at a private high school in Manhattan as well.
+
+17. During one of Doe's encounters with Epstein, he took her to Mar-a-Lago where he introduced her to its owner, Donald J. Trump. Introducing 14-year-old Doe to Donald J. Trump, Epstein elbowed Trump playfully asking him, referring to Doe, "This is a good one, right?" Trump smiled and nodded in agreement. They both chuckled and Doe felt uncomfortable, but, at the time, was too young to understand why.
+
+18. Towards the end of 1994, Epstein invited Doe into his pool house, where he grabbed her, put her on his lap and started masturbating. Epstein told her that was what to expect from photographers who were soon going to be take modeling pictures of her. However, when Doe was ultimately photographed by these professional photographers, they did no such thing.
+
+19. Over the next few years, the sexual abuse escalated. On a regular basis, Epstein would digitally penetrate Doe, force Doe to perform sexual acts on him and apply vibrators on different parts of Doe's body. The abuse occurred at Epstein's home in Palm Beach, Florida, Epstein's townhouse on 9 East 71st Street in New York City, and Epstein's ranch in New Mexico. When travelling to these places, Doe often flew with Epstein and Maxwell in Epstein's private jet.
+
+19 21. Once Epstein had secured Doe in New York and made her and her family 20 completely dependent on him financially (including, for the roof over their heads), Epstein's abuse 21 of Doe continued to escalate.
+
+22 22. In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New 23 York, Epstein asked 17-year-old Doe if she had a boyfriend. Doe replied that she did not. Epstein 24 responded that when she did have a boyfriend she would want the sex to be "good' and that she 25 should "get it over with already," meaning lose her virginity. Despite Doe's resistance, Epstein 26 then pushed Doe down onto her stomach and raped her. From that point forward for several years 27 in New York, Epstein raped Doe on multiple occasions.
+
+1 23. During Doe's time in New York, Maxwell also regularly facilitated Epstein's abuse 2 of Doe and was frequently present when it occurred.
+
+3 24. In 1999, Doe moved to Los Angeles to start a career. Upon moving to Los Angeles 4 and being physically away from Epstein and Maxwell, Doe finally felt like she could escape 5 Epstein's abuse and stopped returning his frequent calls where he would threaten and berate her for 6 not appreciating him.
+
+7 25. Despite Doe's physical escape from Epstein and Maxwell, the years of abuse and 8 exploitation perpetrated against her by them cause her immeasurable pain and suffering every day.
+
+# 9 Epstein's Death and Will
+
+10 26. In July 2019, Epstein was indicted by the Unites States Attorney's Office for the .-1 a. 11 Southern District of New York.
+
+tit 4' 12 27. On August 10, 2019, Epstein was found dead in his jail cell at the Metropolitan ir O -fr 13 Correctional Center, where he was being held pending trial. Upon information and belief, New ckl O • 14 York City's medical examiner concluded Epstein died by suicide.
+
+15 28. On August 15, 2019, Epstein's last will and testament (the "Will") was filed in the IMt .§ a 16 Probate Division of the Superior Court of the Virgin Islands. .)
+
+Z := a ,., .4- 17 29. The Will indicated that it was executed by Epstein on August 8, 2019 at the 18 Metropolitan Correctional Center. The Will was accompanied by affidavits from Darren K. 19 Indyke and Richard D. Kahn attesting to their "Oath of Willingness to Serve as Executor and 20 Appointment of Local Counsel." Mr. Indyke and Mr. Kahn also filed a Petition for Probate and for 21 Letters Testamentary in the Superior Court of the Virgin Islands.
+
+22 30. The Will's first article directs Epstein's executors "to pay from my estate all 23 expenses of my last illness, my funeral and burial expenses, the administration expenses of my 24 estate and all of my debts duly proven and allowed against my estate." The Will further directs 25 that "after the payments and distributions provided in Article FIRST," Epstein "give[s] all of my 26 property, real and personal, wherever situated...to the then acting Trustees of The 1953 Trust."
+
+27
+
+PANISH SHEA & BOYLE LLP  
+310.477.1700 phone • 310.477.1699 fax
+
+31. On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with  
+the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn are  
+the two Trustees of The 1953 Trust.
+
+32. On September 6, 2019, Magistrate Judge Carolyn P. Hermon-Percell of the  
+Superior Court of the Virgin Islands ordered that Epstein's will be admitted to probate and  
+authorized Mr. Indyke and Mr. Kahn to administer the estate.
+
+**FIRST CAUSE OF ACTION**
+
+**(Sexual Assault)**
+
+33. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as  
+if set forth fully herein.
+
+34. On numerous occasions over several years, Epstein, with Maxwell's assistance,  
+made violent sexual demands on Plaintiff while placing his hands on her body in a position of  
+dominance and control and while touching Plaintiff in violent and invasive ways.
+
+35. These demands, often made when young Plaintiff was alone with Epstein or with  
+only Epstein and Maxwell, were intended to frighten Plaintiff into submitting to his sexual  
+demands and placed Plaintiff in apprehension of harm.
+
+36. This conduct caused Plaintiff serious and persistent harm and contributed to  
+injuries that Plaintiff continues to suffer.
+
+37. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g  
+(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was  
+under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of  
+the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+
+**SECOND CAUSE OF ACTION**
+
+**(Sexual Battery)**
+
+38. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as  
+if set forth fully herein.
+
+39. On numerous occasions over several years, Epstein raped Doe.
+
+1 40. On numerous occasions over several years, Epstein digitally penetrated Doe with 2 his fingers, tongue and foreign objects.
+
+3 41. On numerous occasions over several years, Epstein made otherwise unwanted, 4 unlawful, harmful, and offensive physical contact with Plaintiffs body.
+
+5 42. This conduct caused Plaintiff serious and persistent harm and contributed to 6 injuries that Plaintiff continues to suffer.
+
+7 43. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g 8 (McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was 9 under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of 10 the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+
+#### 11 THIRD CAUSE OF ACTION
+
+#### w • 12 (Intentional Infliction of Emotional Distress)
+
+Oa 0 v. 13 44. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as <kl 1 ( • 14 if set forth fully herein.
+
+15 45. Epstein and Maxwell's campaign of sexual abuse against a teenaged Plaintiff was § 16 extreme and outrageous conduct that shocks the conscience.
+
+- 17 46. Epstein and Maxwell's serial sexual assaults, committed during the course of a 18 methodical plan of recruitment, enticement, and attack, inflicted severe pain and anguish upon 19 Plaintiff.
+
+20 47. Epstein and Maxwell directed this conduct at Plaintiff and knew that it would cause 21 severe and lasting emotional distress. Indeed, the conduct caused Plaintiff severe and lasting 22 emotional distress and serious injuries to her mental health.
+
+23 48. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g 24 (McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was 25 under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of 26 the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+
+## 27 FOURTH CAUSE OF ACTION
+
+1 49. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as 2 if set forth fully herein.
+
+3 50. Epstein and Maxwell coaxed Plaintiff, then a teenaged girl, into Epstein's home for 4 a period of several years. They worked hard to groom her. Once under their supervision and 5 influence, Epstein and Maxwell proceeded methodically to sexually abuse Plaintiff.
+
+6 51. Epstein and Maxwell's conduct was extreme and outrageous, breached a duty owed 7 directly to Plaintiff, endangered her physical safety, and caused severe and lasting emotional 8 distress and serious injuries to Plaintiff's mental health.
+
+9 52. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g 10 (McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was I I under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of 1' g 12 the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+
+# -. 13 FIFTH CAUSE OF ACTION
+
+### r\*J t • 14 (False Imprisonment)
+
+N 11.g 15 53. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as E: 16 if set fbrth fully herein. -•
+
+- " 17 54. Defendants, in perpetrating the above-described non-consensual sexual assaults, 18 did, by use of threat and/or physical force, willfully and intentionally confine, detain, imprison 19 and/or restrain Plaintiff without lawful authority to do so, against her will, and without her 20 consent.
+
+21 55. Plaintiff was aware of, and suffered the extreme effects of; the Defendants' 22 unlawful confinement.
+
+23 56. As a consequence of Defendants' false imprisonment of Plaintiff, she sustained 24 conscious pain and suffering, Plaintiff's health was impaired, Plaintiff suffered great mental 25 distress, shock, fright and humiliation, and Plaintiff's reputation and character were injured.
+
+26 57. As a consequence of the conduct of Defendants, Plaintiff has incurred severe 27 psychological trauma and damage, has suffered great humiliation, loss of esteem, mental anguish 28 and suffering.
+
+PANISH SHEA & BOYLE LLP  
+310.477.1700 phone • 310.477.1699 fax
+
+1 58. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g  
+2 (McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was  
+3 under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of  
+4 the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+
+5 **PRAYER FOR RELIEF**
+
+6 WHEREFORE, Plaintiff Jane Doe prays for this Court to:
+
+7 59. Issue a judgment declaring that Defendant ESTATE OF JEFFREY E. EPSTEIN by  
+8 and through its executors, DARREN K. INDYKE and RICHARD D. KAHN, as legal  
+9 representatives of the Estate of Jeffrey E. Epstein, and Defendant GHISLAINE MAXWELL are  
+10 liable for the violations of law alleged in this case;
+
+11 60. Award actual, compensatory, statutory, consequential and punitive damages;
+
+12 61. Award pre-judgment and post-judgment interest at the highest rate allowed by law;  
+13 and
+
+14 62. Grant such further relief as this Court may deem just and proper.
+
+15 Respectfully submitted,
+
+17 Dated: January 16, 2020
+
+18 Kevin Boyle (admission pending)  
+19 Robert Glassman (admission pending)  
+20 Nathan Werksman (admission pending)
+
+21 PANISH SHEA & BOYLE LLP  
+22 11111 Santa Monica Blvd., Suite 700  
+23 Los Angeles, CA 90025  
+24 Telephone: (310) 477-1700  
+25 Facsimile: (310) 477-1699  
+26 boyle@psblaw.com  
+27 glassman@psblaw.com  
+28 werksman@psblaw.com
+
+25 /s/ Benedict P. Morelli  
+26 Benedict P. Morelli  
+27 David T. Sirotkin  
+28 Sara A. Mahoney
+
+MORELLI LAW FIRM PLLC
+
+e. I I g O 13 °ill \* 14 c2< NS s 16 - a 17
+
+777 Third Avenue, 31st Floor New York, NY 10017 Telephone: (212) 751-9800 Facsimile: (212) 751-0046 bmorelli@morellilaw.com dsirotkin@morellilaw.com smahoney@morellilaw.com
+
+Attorneys for Plaintiff

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751930/EFTA02751930.md

@@ -0,0 +1,21 @@
+Bennet J. Moskowitz
+
+bennet.moskowitz@troutman.com
+
+January 23, 2020
+
+ECF
+
+Hon. J Koeltl Daniell. Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312
+
+Re: Jane Doe v. Darren K. lndyke and Richard D. Kahn, in their capacities as co-executors of the Estate of Jeffrey E. Epstein, and Ghislaine Maxwell, 1:20-cv-00484-JGK
+
+Dear Judge Koeltl:
+
+We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the to -Executors"), in the above-referenced action. We write to respectfully request the Court's approval of the parties' agreement described below.
+
+On January 22, 2020, subject to the Court's approval: (1) we agreed to accept service of Plaintiff's Complaint (ECF #9) on the Co-Executors' behalf; (2) Plaintiff consented to the Co-Executors having through Monday, March 23, 2020 to answer, move or otherwise respond to Plaintiff's Complaint and Motion to Proceed by Pseudonym (ECF #5); and (3) the parties agreed to adjourn the initial case conference in this matter to a mutually agreeable time after the Co-Executors' deadline to respond to the Complaint. There have been no previous requests for adjournments or extensions of time in this action.
+
+Respectfully submitted,
+
+/s/ Bennet J. Moskowitz Bennet J. Moskowitz

marker2-fixhub/court-doe-v-indyke-00484/EFTA02751930/EFTA02751930.receipt.json

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751931/EFTA02751931.md

@@ -0,0 +1,35 @@
+Troutman Sanders LLP 875 Third Avenue New York, New York 10022
+
+troutman.osm
+
+![](_page_0_Picture_3.jpeg)
+
+Bennet J. Moskowitz
+
+bennetmoskowitz@troutrnan.com
+
+January 23, 2020
+
+ECF
+
+Hon. Koeltl Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312
+
+Re: Jane Doe v. Darren K. lndyke and Richard D. Kahn, in their 8aidacities as co-executors of the Estate of Jeffrey E. Epstein, and Ghislaine Maxwell, 1:20-cv-00484-JGK
+
+Dear Judge Koeltl:
+
+We represent 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 to respectfully request the Court's approval of the parties' agreement described below.
+
+gire- traCeie
+
+5't a-c11,42;fi 9-te c:A;4:, ertfc-a-e•-e-iy f r9aLe-ottchi aryl—cf./1, I ,90 yl—cf./1, ? 0 6lam ( 4 6. D.:-C-
+
+10.4/02 O
+
+On January 22, 2020, subject to the Court's approval: (1) we agreed to accept service of Plaintiffs Complaint (ECF #9) on the Co-Executors' behalf; (2) Plaintiff consented to the Co-Executors having through Mondays March 23, 2020 to answer, move or otherwise respond to Plaintiffs Complaint and Motion to Proceed by Pseudonym (ECF #5); and (3) the parties agreed to adjoum the initial case conference in this matter to a mutually agreeable time after the Co-Executors' deadline to respond to the Complaint. There have been no previous requests for adjoumments or extensions of time in this action.
+
+Respectfully submitted,
+
+/s/ Bennet J. Moskowitz Bennet J. Moskowitz
+
+tJSCC SDNY DOCUMENT ELECTRONICALLY FILED DOC# DATE FILED: \_ • '020;0

marker2-fixhub/court-doe-v-indyke-00484/EFTA02751931/EFTA02751931.receipt.json

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751932/EFTA02751932.md

@@ -0,0 +1,81 @@
+## UNITED STATES DISTRICT COURT
+
+for the
+
+SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE,
+
+Plaintiffs)
+
+V.
+
+DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, et al.
+
+Defendant(s)
+
+Civil Action No. 1:20-cv-00484
+
+## SUMMONS IN A CIVIL ACTION
+
+To: (Defendant's name and address)
+
+Richard D. Kahn
+
+do Bennet J. Moskowitz, attorney
+
+Troutman Sanders LLP
+
+875 Third Avenue
+
+New York, NY 10002
+
+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 plaintiffs attorney, whose name and address are: Kevin IL Boyle
+
+Robert S. Glassman
+
+Panish Shea & Boyle LLP
+
+11111 Santa Monica, Blvd., Suite 700
+
+Los Angeles, CA 90025
+
+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, 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 \$ 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:

marker2-fixhub/court-doe-v-indyke-00484/EFTA02751932/EFTA02751932.receipt.json

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+  "text_format": "markdown"
+}

marker2-fixhub/court-doe-v-indyke-00484/EFTA02751934/EFTA02751934.md

@@ -0,0 +1,81 @@
+## UNITED STATES DISTRICT COURT
+
+for the
+
+SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE,
+
+Plaintiff(s)
+
+v.
+
+DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF ►EFFREY **E. EPSTEIN, et at** 
+
+Defendant(s)
+
+Civil Action No. 1:20-cv-00484
+
+## SUMMONS IN A CIVIL ACTION
+
+To: (Defendant's name and address)
+
+DARREN K. INDYKE
+
+do Bennet J. Moskowitz, attorney
+
+Troutman Sanders LLP
+
+875 Third Avenue
+
+New York, NY 10002
+
+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 plaintiffs attorney, whose name and address are: Kevin R. Boyle
+
+Robert S. Glassman
+
+Panish Shea & Boyle LLP
+
+11111 Santa Monica, Blvd., Suite 700
+
+Los Angeles, CA 90025
+
+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 (0)
+
+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 opecin
+
+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:

marker2-fixhub/court-doe-v-indyke-00484/EFTA02751934/EFTA02751934.receipt.json

@@ -0,0 +1,14 @@
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+}

marker2-fixhub/court-doe-v-indyke-00484/EFTA02751936/EFTA02751936.md

@@ -0,0 +1,73 @@
+## UNITED STATES DISTRICT COURT
+
+for the
+
+SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE.
+
+Plaintes)
+
+v.
+
+DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF ►EFFREY **E. EPSTEIN, et al.** 
+
+Defendant(s)
+
+To: (Defendant's name and address)
+
+Ghislainc Maxwell
+
+116 East 65th Street, New York, NY 10065 Civil Action No. 1:20-cv-00484
+
+## SUMMONS IN A CIVIL ACTION
+
+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 plaintiffs attorney, whose name and address are: Kevin R. Boyle
+
+Robert S. Glassman
+
+Panish Shea & Boyle LLP
+
+11111 Santa Monica, Blvd., Suite 700
+
+Los Angeles, CA 90025
+
+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, 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
+
+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:

marker2-fixhub/court-doe-v-indyke-00484/EFTA02751936/EFTA02751936.receipt.json

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marker2-fixhub/court-doe-v-indyke-00484/EFTA02751938/EFTA02751938.md

@@ -0,0 +1,89 @@
+# UNITED STATES DISTRICT COURT
+
+for the
+
+SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE,
+
+*Plaintiff(s)*
+
+v.
+
+DARREN K. INDYKE and RICHARD D. KAHN, in their  
+capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, et al.
+
+*Defendant(s)*
+
+
+Civil Action No. 1:20-cv-00484
+
+## SUMMONS IN A CIVIL ACTION
+
+To: (*Defendant's name and address*)
+
+Richard D. Kahn
+
+c/o Bennet J. Moskowitz, attorney
+
+Troutman Sanders LLP
+
+875 Third Avenue
+
+New York, NY 10002
+
+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:
+
+Kevin R. Boyle
+
+Robert S. Glassman
+
+Panish Shea & Boyle LLP
+
+11111 Santa Monica, Blvd., Suite 700
+
+Los Angeles, CA 90025
+
+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: 01/28/2020
+
+*L./D. Howie*
+
+*Signature of Clerk or Deputy Clerk*
+
+![](_page_0_Picture_175.jpeg)
+
+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 tide. 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 \$ 0.00
+
+I declare under penalty of perjury that this information is true.
+
+Date: Server's signature
+
+Printed name and tide
+
+Server's address
+
+Additional information regarding attempted service, etc:

marker2-fixhub/court-doe-v-indyke-00484/EFTA02751938/EFTA02751938.receipt.json

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