Case 1:20-cv-02365 Document 1 Filed 03/17/20 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE, Plaintiff, -againstCOMPLAINT DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN; Defendants. --------------------------------------------....—X Plaintiff, Jane Doe, by her attorneys, Kaiser Saurbom & Mair, P.C., as and for her complaint against the defendants, alleges as follows: I. BACKGROUND 1. Jane Doe seeks justice for the sexual crimes perpetrated against her by Jeffrey Epstein over the course of many years and for the abuse, manipulation and exploitation she suffered at his hands. Epstein identified Jane Doe as an extremely emotionally vulnerable young woman who, at the time she met him, had been entirely abandoned by her community, friends, and family which enabled him to seduce her into his world of horrific abuse. Every aspect of her life was controlled by Epstein. He dominated her psychologically. Jane Doe was constantly emotionally bullied and coerced by Epstein, including being required to submit to his constant sexual abuse. This lawsuit is about Jane Doe claiming her power, becoming a survivor, not a victim, and getting restitution for the sexual crimes perpetuated against her. She has real damages that are lasting: 1) She has permanent emotional injuries; 2) Her capacity to pursue a professional career has been severely compromised; 3) Her name and reputation has been ruined; 1 EFTA02752550