EFTA00019101

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I UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF NEW YORK 3 4 5 6 7 8 9 10 a. 11 6 DJ 0 ai 0. 12 ~ E 4p 13 3t 14 P z (6:I 2 a IS § 16 a 2 `') 17 18 19 20 21 22 23 24 25 26 27 28 JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defendants. Case No. COMPLAINT FOR DAMAGES DEMAND FOR JURY TRIAL PlaintiffJane Doe ("Doe" or "Plaintiff") alleges as follows: INTRODUCTION 1. This case arises out of years of sexual abuse and exploitation of a young girl by notorious pedophile and convicted sex offender Jeffrey Epstein ("Epstein"). It all started in 1994 when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a summer camp in Michigan. Jane Doe was their first known victim and was subsequently abused by Epstein and Maxwell for years as a young girl, suffering unimaginable physical and psychological trauma and distress. Despite that, Jane Doe has persevered and survived to tell her story, to hold her perpetrators accountable and to seek justice for the atrocities committed against her. 2. Throughout his life, Epstein systematically perpetrated acts of molestation. exploitation, assault and rape on hundreds of young girls. Epstein's system of abuse was facilitated in large part by his co-conspirator and accomplice, Maxwell, who helped supply him with a steady stream of you