Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x Plaintiff, Case No. 19 Civ. 10788 COMPLAINT -against- AND JURY DEMAND DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, Defendants. x Plaintiff by and through her attorneys, Cuti Hecker Wang LLP and Allred, Maroko & Goldberg, for her Complaint alleges as follows: NATURE OF THE ACTION 1. When Plaintiff was just seventeen years old, living on her own and working full-time to support herself, Jeffrey Epstein preyed open her, manipulated her to be completely dependent on him, and sexually abused her. 2. Epstein was presented to as someone who had learned about her challenging circumstances and had the resources and interest to assist her — including by helping her to attend college and study abroad to see the world. was introduced to Epstein by her sister, but was unaware that Epstein had been manipulating and sexually abusing her sister, as Epstein's total power and control over sister made it impossible for her to say anything about it. 3. During their early interactions, Epstein led to believe that he would help her achieve her dream of becoming a translator, and he arranged for to study abroad in Spain. gave up her job and her apartment in anticipation of this life-changing opportunity, leaving her completely dependent on Epstein and his continuing generosity. EFTA00025109