Case 1:20-cv-00484 Document 1 Filed 01/17/20 Page 1 of 10 UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF NEW YORK 3 Case No. 1:20-cv-00484 JANE DOE, 5 Plaintiff, COMPLAINT FOR DAMAGES DARREN K. INDYKE and RICHARD D. 8 KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, 9 DEMAND FOR JURY TRIAL 6 v. 7 Defendants. I0 II 12 Plaintiff Jane Doe ("Doe" or "Plaintiff') alleges as follows: 13 14 INTRODUCTION I. This case arises out of years of sexual abuse and exploitation of a young girl by 15 notorious pedophile and convicted sex offender Jeffrey Epstein ("Epstein"). It all started in 1994 16 when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a 17 summer camp in Michigan. Jane Doe was their first known victim and was subsequently abused 18 by Epstein and Maxwell for years as a young girl, suffering unimaginable physical and 19 psychological trauma and distress. Despite that, Jane Doe has persevered and survived to tell her 20 story, to hold her perpetrators accountable and to seek justice for the atrocities committed against 21 her. 22 2. Throughout his life, Epstein systematically perpetrated acts of molestation. 23 exploitation, assault and rape on hundreds of young girls. Epstein's system of abuse was 24 facilitated in large part by his co-conspirator and accomplice, Maxwell, who helped supply him 25 with a steady stream of young and vulnerable girls—many of whom were fatherless, like Jane 26 Doe, and came from struggling families. 27 28 1 COMPLAINT FOR DAMAGES EFTA02751880