Case 1:19-cv-10758-PAE-DCF Document 1 Filed 11/20/19 Page 1 of 19

Case 1:19-cv-10758-PAE-DCF Document 1 Filed 11/20/19 Page 1 of 19 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x MARY DOE, Case No. 19 Civ. 10758 Plaintiff, COMPLAINT -against- AND JURY DEMAND DARREN K. INDYKE and RICHARD D. KAHN, as EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, and Defendants. x Plaintiff Mary Doe', by and through her attorneys, Cuti Hecker Wang LLP and Allred, Maroko & Goldberg, for her Complaint alleges as follows: NATURE OF THE ACTION 1. Beginning when Plaintiff Mary Doe was sixteen years old, Jeffrey Epstein preyed upon her, manipulated her to be completely dependent on him, and repeatedly sexually assaulted her. As a result, she attempted suicide multiple times. His degradation of her was total for years. 2. 3. 1. He made clear to Mary how Plaintiff is using the pseudonym "Mary Doe" in this Complaint in place of her real name. "Mary" is not her real first name. Plaintiff intends to file a motion to proceed under a pseudo