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950613/2020
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SUPREME COURT OF THE STATE OF NEW YORK Index No.: __________/20

COUNTY OF NEW YORK
----------------------------------------------------------------------X
Plaintiffs designate
JANE DOE X, JANE DOE XI, JANE DOE XII, JANE
DOE XIII, JANE DOE XIV, JANE DOE XV, JANE NEW YORK COUNTY
DOE XVI, JANE DOE XVII and JANE DOE XVIII, as place of trial

The basis of venue is

proper as it is the location
Plaintiffs,
where a substantial part of
the events, occurrences
-against- and/or omissions giving
rise to the claims herein
occurred, and it is the
DARREN K. INDYKE and RICHARD D. KAHN, in County in which
their capacities as the executors of the ESTATE OF Defendant Kahn resides
JEFFREY EDWARD EPSTEIN,
SUMMONS

Defendants. Plaintiffs all reside in the

----------------------------------------------------------------------X United States of America
To the above-named Defendants:

YOU ARE HEREBY SUMMONED to Answer the Verified Complaint in this action and to
serve a copy of your Answer or, if the Verified Complaint is not served with this Summons, to
serve a Notice of Appearance on Plaintiffs’ attorneys within 20 days after the service of this
Summons, exclusive of the day of service (or within 30 days after the service is complete if this
Summons is not personally delivered to you within the State of New York); and, in case your
failure to appear or Answer, judgement will be taken for the relief demanded herein.

A COPY OF THIS SUMMONS WAS FILED WITH THE CLERK OF THE COURT,
08/13/20 IN COMPLIANCE WITH CPLR §§305(a) AND
NEW YORK COUNTY ON __________
306(a).

Dated: New York, New York

August 13, 2020
MERSON LAW, PLLC

By:
Jordan K. Merson
Jesse R. Mautner
Attorney for Plaintiffs
150 East 58th Street, 34th Floor
New York, New York 10155
(212) 603-9100

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TO:

RICHARD D. KAHN, in his capacity as a co-executor

of the ESTATE OF JEFFREY EDWARD EPSTEIN
130 East 75th Street
New York, NY 10021

DARREN K. INDYKE, in his capacity as a co-executor

of the ESTATE OF JEFFREY EDWARD EPSTEIN
6030 Le Lac Road
Boca Raton, FL 33496

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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK
-------------------------------------------------------------------X
JANE DOE X, JANE DOE XI, JANE DOE XII, JANE
DOE XIII, JANE DOE XIV, JANE DOE XV, JANE
DOE XVI, JANE DOE XVII and JANE DOE XVIII,

Plaintiffs, Index No.: __________/20

-against-
VERIFIED
COMPLAINT
DARREN K. INDYKE and RICHARD D. KAHN, in
their capacities as the executors of the ESTATE OF
JEFFREY EDWARD EPSTEIN,

Defendants.
-------------------------------------------------------------------X
COMPLAINT AND JURY TRIAL DEMANDED

Plaintiffs JANE DOE X, JANE DOE XI, JANE DOE XII, JANE DOE XIII, JANE

DOE XIV, JANE DOE XV, JANE DOE XVI, JANE DOE XVII and JANE DOE XVIII

(collectively “Plaintiffs”) 1, by and through their attorneys at MERSON LAW, PLLC, and as

for their Verified Complaint in this action against Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN (collectively “Defendants”), hereby allege the following:

NATURE OF THE CLAIMS

1. Jeffrey Edward Epstein (“Epstein”) sexually abused, assaulted and battered

many women and children, including Plaintiffs herein.

1 Plaintiffs use pseudonyms because they are victims of sex crimes pursuant to N.Y. Civ. Rights § 50-b and other
statutory and common law principles, as well as in accord with New York City, Child Victims Act Case
Management Order (CMO) 1.

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2. Now, these nine Plaintiffs come forward to stand up for themselves and others,

after they were sexually abused and assaulted by Epstein.

3. Some Plaintiffs were raped by Epstein, repeatedly.

4. Plaintiffs were all sexually battered, assaulted and abused by Epstein as a part

of the same conduct, occurrence, plan, scheme and/or transaction that was perpetrated,

conducted, organized and/or performed in New York, Florida, New Mexico, South Carolina,

California, the United States Virgin Islands and other places by Epstein and his associates.

5. Over the course of several decades, Epstein orchestrated a massive sex

trafficking network to obtain hundreds of underage girls and young women for not only his

sexual gratification, but also that of several other wealthy and/or powerful individuals within

his social network to whom he trafficked these same underage girls and young women to.

6. As expressed by United States District Judge Kenneth Marra in his opinion in

Doe v. United States, “From between 1999 and 2007, Jeffrey Epstein sexually abused more

than thirty minor girls ... at his mansion in Palm Beach, Florida, and elsewhere in the United

States and overseas ... In addition to his own sexual abuse of the victims, Epstein directed other

persons to abuse the girls sexually. Epstein used paid employees to find and bring minor girls

to him. Epstein worked in concert with others to obtain minors not only for his own sexual

gratification, but also for the sexual gratification of others.” See Doe v. United States, 359 F.

Supp. 3d 1201, 1204 (S.D. Fla. 2019) (internal citations omitted).

7. In performing the acts set forth above, Epstein committed multiple torts

including, but not limited to, sexual assault, sexual battery, intentional infliction of emotional

distress and negligent infliction of emotional distress pursuant to New York common law.

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VENUE, JURISDICTION AND TIMELINESS

8. The Estate of Jeffrey Epstein (the “Estate”), which is being presided over by

Defendants, includes a residence in New York, New York, that was occupied by Jeffrey Epstein

before his death in August of 2019. While the residence is currently listed for sale for

$88,000,000, it has not been sold and is still part and parcel of the Estate.

9. Upon information and belief, this Court has personal jurisdiction over the Estate

of Jeffrey Epstein pursuant to New York Civil Practice Law and Rules (“C.P.L.R.”) Sections

301 and 302, and venue is proper in this Court pursuant to CPLR § 503, because Defendant

RICHARD D. KAHN, in his capacity as a co-executor of the ESTATE OF JEFFREY

EDWARD EPSTEIN is a resident of New York, and Defendants operate in New York, transact

business in New York, own, use or possess real property within New York and many of the acts

of sexual abuse referenced herein as part of Epstein’s nefarious plan and course of conduct

occurred in New York.

10. This action has been timely filed pursuant to CPLR § 214-g or The Child Victims

Act (“CVA”) which provides that a plaintiff, who was a child less than eighteen years of age

when a defendant committed unto them an act in violation of New York Penal Law Article 130,

shall have one year from August 14, 2019 to bring forth the previously time-barred claim

against said defendant.

11. Indeed, the actions described herein constitute sexual offenses by Epstein under

New York Penal Law Article 130 and were committed against Plaintiffs Jane Doe X, XIII, XIV,

XVI and XVIII when they were children less than eighteen years of age, for which they suffered

physical, psychological and other injuries as a result. As such, their claims are, are the very

least, brought timely pursuant to the CVA.

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12. In addition to CPLR § 214-g, this action has also been timely filed pursuant to

CPLR § 215(8)(a) which provides that, “[w]henever it is shown that a criminal action against

the same defendant has been commenced with respect to the event or occurrence from which a

claim governed by this section arises [i.e. assault and battery], the plaintiff shall have at least

one year from the termination of the criminal action as defined in section 1.20 of the criminal

procedure law in which to commence the civil action...”

13. As it pertains to CPLR § 215(8)(a), a criminal action against Epstein with respect

to the same events or occurrences from which Plaintiffs’ claims arise, namely his sex trafficking

and/or sexual abuse of underage girls and young women, was terminated on August 29, 2019

shortly after Epstein committed suicide in the Metropolitan Correctional Center while awaiting

trial.

14. Furthermore, any statute of limitations that would otherwise be applicable to

Plaintiffs’ claims herein is tolled in accord with the doctrine of equitable estoppel based on the

continuous and active deception, duress, fraud, threats of retaliation and other forms of

misconduct that Epstein and his co-conspirators used to silence his victims, including Plaintiffs,

as set forth below. At a minimum, this conduct by Epstein and his co-conspirators deprived

Plaintiffs of their legal right and opportunity to commence this lawsuit before Epstein’s death.

15. Accordingly, Defendants are equitably estopped from asserting a statute of

limitations defense. Allowing Defendants to do so would be unjust. Epstein and his co-

conspirators repeatedly intimidated his victims, including Plaintiffs, into silence by threatening

not only their lives and livelihoods, but the lives and livelihoods of their close family and

friends. Therefore, Epstein and his co-conspirators prevented Plaintiffs from commencing this

lawsuit before his death. By using threats in accompaniment with his wealth and power, Epstein

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was able to escape punishment for his abhorrent brutal and perverse crimes against countless

underage girls and young women, including plaintiffs, for the duration of his life.

16. Plaintiffs intend to take full discovery of the Estate and all associates, family

members and/or friends associated to the same to determine who knew what and when.

17. At all material times herein mentioned, Epstein, and his associates, operated,

transacted business, owned, used, maintained and/or possessed real and other property,

equipment and apparatus within New York, which he utilized as the base of his operations for

his sexual exploitation of underage girls and young women, including Plaintiffs herein.

PARTIES

18. Plaintiffs, victims of sex trafficking and sexual abuse, have been identified by

pseudonym because this matter is of a highly sensitive and personal nature, and public

disclosure of their identities may subject them to further humiliation, shame, and emotional

distress.

19. Plaintiff Jane Doe X is a resident and domiciliary of Tennessee.

20. Plaintiff Jane Doe XI is a resident and domiciliary of New Jersey.

21. Plaintiff Jane Doe XII is a resident and domiciliary of Connecticut.

22. Plaintiff Jane Doe XIII is a resident and domiciliary of Florida.

23. Plaintiff Jane Doe XIV is a resident and domiciliary of Tennessee.

24. Plaintiff Jane Doe XV is a resident and domiciliary of Florida.

25. Plaintiff Jane Doe XVI is a resident and domiciliary of California.

26. Plaintiff Jane Doe XVII is a resident and domiciliary of Missouri.

27. Plaintiff Jane Doe XVIII is a resident and domiciliary of California.

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28. Upon information and belief, Defendants are successors-in-interest and/or

obligors to Epstein’s assets, obligations and/or responsibilities. Upon further information and

belief, the Estate maintained multiple properties in the United States including, but not limited

to, New York, New York, Palm Beach, Florida and New Mexico.

29. Darren K. Indyke, a resident and domiciliary of Florida, is sued in his capacity

as appointed executor of the Estate of Jeffrey Edward Epstein.

30. Richard D. Kahn, a resident and domiciliary of New York, is sued in his capacity

as appointed executor of the Estate of Jeffrey Edward Epstein.

FACTS OF THE CASE

31. In or about 1987, and continuing for a period of time thereafter, when Plaintiff

Jane Doe X was approximately fifteen years old, Epstein and his associates sexually assaulted,

abused, battered and raped her several dozen times.

32. As a result of the aforementioned sexual abuse, Plaintiff Jane Doe X suffered,

and continues to suffer from severe and serious injuries including, but not limited to, severe

emotional distress and physical manifestations thereof.

33. In or about 2002, Epstein repeatedly sexually abused Plaintiff Jane Doe XI

including molesting and penetrating her, and on one occasion, forced her to perform oral sex

on him.

34. As a result of the aforementioned sexual abuse, Plaintiff Jane Doe XI suffered,

and continues to suffer from severe and serious injuries including, but not limited to, severe

emotional distress and physical manifestations thereof.

35. Furthermore, any statute of limitations that would otherwise be applicable to

Plaintiff Jane Doe XI’s claims herein is tolled in accord with the doctrine of equitable estoppel

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based on the continuous and active deception, duress, fraud, threats of retaliation and other

forms of misconduct that Epstein and his co-conspirators used to silence her. Specifically,

throughout the duration of the abuse in 2002, Epstein would repeatedly and specifically threaten

Plaintiff, and tell her that if she told anyone about what he was doing to her, she would be

putting not only her, but also her family’s safety and well-being at risk. Epstein also knew that

Plaintiff’s father owned and operated a business and would tell Plaintiff that if she told anyone

about what was happening to her, he would make sure the business was destroyed.

36. Accordingly, Defendants are equitably estopped from asserting a statute of

limitations defense as to Plaintiff Jane Doe XI’s claims because, at a minimum, this conduct by

Epstein and his co-conspirators deprived Plaintiff of her legal right and opportunity to

commence this lawsuit before Epstein’s death.

37. In or about 1991, when Plaintiff Jane Doe XII was approximately twenty-two

years old, Epstein fondled, groped and molested her.

38. As a result of the aforementioned sexual abuse, Plaintiff Jane Doe XII suffered,

and continues to suffer from severe and serious injuries including, but not limited to, severe

emotional distress and physical manifestations thereof.

39. Furthermore, any statute of limitations that would otherwise be applicable to

Plaintiff Jane Doe XII’s claims herein is tolled in accord with the doctrine of equitable estoppel

based on the continuous and active deception, duress, fraud, threats of retaliation and other

forms of misconduct that Epstein and his co-conspirators used to silence her, including that in

1991, Epstein’s associate that recruited her told Plaintiff after she was abused that she should

never tell anyone about what had happened to her as nobody would believe her word over that

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of an extraordinarily wealthy and well-connected man like Epstein, and that anyone who

crossed Epstein always regretted it.

40. Accordingly, Defendants are equitably estopped from asserting a statute of

limitations defense as to Plaintiff Jane Doe XII’s claims because, at a minimum, this conduct

by Epstein and his co-conspirators deprived Plaintiff of her legal right and opportunity to

commence this lawsuit before Epstein’s death.

41. In or about 1993, when Plaintiff Jane Doe XIII was approximately eleven years

old, Epstein sexually assaulted, abused, battered and digitally penetrated her on three, separate

occasions. Epstein also forced Plaintiff to perform oral sex on him.

42. As a result of the aforementioned sexual abuse, Plaintiff Jane Doe XIII suffered,

and continues to suffer from severe and serious injuries including, but not limited to, severe

emotional distress and physical manifestations thereof.

43. In or about 1978, and continuing for a period of time thereafter, when Plaintiff

Jane Doe XIV was approximately thirteen years old, Epstein sexually assaulted, abused,

battered and raped her multiple times.

44. As a result of the aforementioned sexual abuse, Plaintiff Jane Doe XIV suffered,

and continues to suffer from severe and serious injuries including, but not limited to, severe

emotional distress and physical manifestations thereof.

45. In or about 2004, when Plaintiff Jane Doe XV was approximately thirty-two

years old, Epstein sexually assaulted, abused, battered and raped her.

46. As a result of the aforementioned sexual abuse, Plaintiff Jane Doe XV suffered,

and continues to suffer from severe and serious injuries including, but not limited to, severe

emotional distress and physical manifestations thereof.

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47. Furthermore, any statute of limitations that would otherwise be applicable to

Plaintiff Jane Doe XV’s claims herein is tolled in accord with the doctrine of equitable estoppel

based on the continuous and active deception, duress, fraud, threats of retaliation and other

forms of misconduct that Epstein and his co-conspirators used to silence her. Specifically, after

Plaintiff informed the associate of Epstein’s who had recruited her that Epstein had just forcibly

raped her, the associate directly threatened Plaintiff and told her that she should leave Epstein’s

home immediately, and that if she told anyone about what had just happened to her, she would

come to regret it.

48. Accordingly, Defendants are equitably estopped from asserting a statute of

limitations defense as to Plaintiff Jane Doe XV’s claims because, at a minimum, this conduct

by Epstein and his co-conspirators deprived Plaintiff of her legal right and opportunity to

commence this lawsuit before Epstein’s death.

49. In or about 2000, when Plaintiff Jane Doe XVI was approximately seventeen

years old, Epstein sexually assaulted, abused, battered and raped her on at least three, separate

occasions.

50. As a result of the aforementioned sexual abuse, Plaintiff Jane Doe XVI suffered,

and continues to suffer from severe and serious injuries including, but not limited to, severe

emotional distress and physical manifestations thereof.

51. In or about 2001, and continuing for a period of time thereafter up to and

including 2002, when Plaintiff Jane Doe XVII was approximately twenty-five years-old,

Epstein repeatedly sexually assaulted, abused and battered her

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52. As a result of the aforementioned sexual abuse, Plaintiff Jane Doe XVII suffered,

and continues to suffer from severe and serious injuries including, but not limited to, severe

emotional distress and physical manifestations thereof.

53. Furthermore, any statute of limitations that would otherwise be applicable to

Plaintiff Jane Doe XVII’s claims herein is tolled in accord with the doctrine of equitable

estoppel based on the continuous and active deception, duress, fraud, threats of retaliation and

other forms of misconduct that Epstein and his co-conspirators used to silence her.

54. Accordingly, Defendants are equitably estopped from asserting a statute of

limitations defense as to Plaintiff Jane Doe XVII’s claims because, at a minimum, this conduct

by Epstein and his co-conspirators deprived Plaintiff of her legal right and opportunity to

commence this lawsuit before Epstein’s death.

55. In or about 2003, when Plaintiff Jane Doe XVIII was approximately thirteen

years old, Epstein sexually assaulted, abused, battered and raped her.

56. As a result of the aforementioned sexual abuse, Plaintiff Jane Doe XVIII

suffered, and continues to suffer from severe and serious injuries including, but not limited to,

severe emotional distress and physical manifestations thereof.

AS AND FOR A FIRST CAUSE OF ACTION FOR

BATTERY OF JANE DOE X AS TO JEFFREY EDWARD EPSTEIN

57. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 56., inclusive, with the

same force and effect as if hereafter set forth at length.

58. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

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EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

59. In or about 1987 and continuing for a period of time thereafter, when Plaintiff

Jane Doe X was approximately fifteen years old, Epstein and his associates sexually assaulted,

abused, battered and raped her several dozen times.

60. Epstein’s predatory, sexual, and unlawful acts against Plaintiff amounted to a

series of harmful and offensive contacts to Plaintiff’s person, all of which were done

intentionally by him to her without her consent.

61. As a proximate result of the aforementioned batteries to Plaintiff, she suffered,

and continues to suffer from, extreme mental distress, humiliation, anguish, emotional and

physical injuries, as well as economic losses, those total damages in amounts to be proven at

trial.

62. By reason of the foregoing, Plaintiff was caused to sustain severe and serious

personal injuries and was caused to suffer severe physical pain and mental anguish as a result

thereof. Upon information and belief these injuries are of a permanent and lasting nature, and

Plaintiff was incapacitated from attending her regular activities and was caused to expend sums

of money for medical care on her behalf.

63. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just, and adequate, and Plaintiff is further

entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

64. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

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65. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A SECOND CAUSE OF ACTION FOR

ASSAULT OF JANE DOE X AS TO JEFFREY EDWARD EPSTEIN

66. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 65., inclusive, with the

same force and effect as if hereafter set forth at length.

67. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

68. Epstein’s predatory, sexual and unlawful acts against Plaintiff, created a

reasonable apprehension in Plaintiff of immediate harmful or offensive contact to Plaintiff’s

person, all of which were done intentionally by him to her without her consent.

69. As a direct and proximate result of the aforementioned assaults, Plaintiff has

sustained in the past, and will continue to sustain in the future, physical injury, pain and

suffering, serious and severe psychological and emotional distress, mental anguish,

embarrassment and humiliation.

70. As a direct and proximate result of the aforementioned assaults, Plaintiff has

incurred medical expenses and other economic damages, and continues to be in physical pain

and suffering, and will now be obligated to expend sums of money for medical care and

attention in an effort to cure herself of her injuries and to alleviate her pain and suffering,

emotional distress, mental anguish, embarrassment and humiliation.

71. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just and adequate, and Plaintiff is further

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entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

72. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

73. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A THIRD CAUSE OF ACTION FOR

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
OF JANE DOE X AS TO JEFFREY EDWARD EPSTEIN

74. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 73., inclusive, with the

same force and effect as if hereafter set forth at length.

75. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

76. Epstein engaged in outrageous conduct towards Plaintiff with the intention to

cause, or with reckless disregard for the probability of causing, Plaintiff to suffer severe

emotional distress.

77. As a proximate result of the aforementioned assaults and batteries to Plaintiff,

she suffered, and continues to suffer from, extreme mental distress, humiliation, anguish and

emotional and physical injuries, as well as economic losses, all her damage in amounts to be

proven at trial.

78. Epstein committed the acts alleged herein maliciously, fraudulently and

oppressively with the wrongful intention of injuring Plaintiff from an improper and evil motive

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amounting to malice and in conscious disregard of Plaintiff’s rights, entitling Plaintiff to recover

punitive and exemplary damages from Defendants in such sums as a jury would find fair, just

and appropriate to deter Defendants and others from future similar misconduct.

79. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

80. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A FOURTH CAUSE OF ACTION FOR

BATTERY OF JANE DOE XI AS TO JEFFREY EDWARD EPSTEIN

81. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 80., inclusive, with the

same force and effect as if hereafter set forth at length.

82. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

83. In or about 2002, when Plaintiff Jane Doe XI was approximately twenty-two

years old, Epstein fondled, groped and molested her over half a dozen times, and on one

occasion, Epstein forced her to perform oral sex on him.

84. Epstein’s predatory, sexual, and unlawful acts against Plaintiff amounted to a

series of harmful and offensive contacts to Plaintiff’s person, all of which were done

intentionally by him to her without her consent.

85. As a proximate result of the aforementioned batteries to Plaintiff, she suffered,

and continues to suffer from, extreme mental distress, humiliation, anguish, emotional and

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physical injuries, as well as economic losses, those total damages in amounts to be proven at

trial.

86. By reason of the foregoing, Plaintiff was caused to sustain severe and serious

personal injuries and was caused to suffer severe physical pain and mental anguish as a result

thereof. Upon information and belief these injuries are of a permanent and lasting nature, and

Plaintiff was incapacitated from attending her regular activities and was caused to expend sums

of money for medical care on her behalf.

87. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

defendants in such sums as a jury would find fair, just, and adequate, and Plaintiff is further

entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

88. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

89. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A FIFTH CAUSE OF ACTION FOR

ASSAULT OF JANE DOE XI AS TO JEFFREY EDWARD EPSTEIN

90. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 89., inclusive, with the

same force and effect as if hereafter set forth at length.

91. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

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92. Epstein’s predatory, sexual and unlawful acts against Plaintiff created a

reasonable apprehension in Plaintiff of immediate harmful or offensive contact to Plaintiff’s

person, all of which were done intentionally by him to her without her consent.

93. As a direct and proximate result of the aforementioned assaults, Plaintiff has

sustained in the past, and will continue to sustain in the future, physical injury, pain and

suffering, serious and severe psychological and emotional distress, mental anguish,

embarrassment and humiliation.

94. As a direct and proximate result of the aforementioned assaults, Plaintiff has

incurred medical expenses and other economic damages, and continues to be in physical pain

and suffering, and will now be obligated to expend sums of money for medical care and

attention in an effort to cure herself of her injuries and to alleviate her pain and suffering,

emotional distress, mental anguish, embarrassment and humiliation.

95. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just and adequate, and Plaintiff is further

entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

96. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

97. This action falls within the exceptions to Article 16 of the C.P.L.R.

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AS AND FOR A SIXTH CAUSE OF ACTION FOR

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
OF JANE DOE XI AS TO JEFFREY EDWARD EPSTEIN

98. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 97., inclusive, with the

same force and effect as if hereafter set forth at length.

99. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

100. Epstein engaged in outrageous conduct towards Plaintiff, with the intention to

cause, or with reckless disregard for the probability of causing, Plaintiff to suffer severe

emotional distress.

101. As a proximate result of the aforementioned assaults and batteries to Plaintiff,

she suffered, and continues to suffer from, extreme mental distress, humiliation, anguish and

emotional and physical injuries, as well as economic losses, all her damage in amounts to be

proven at trial.

102. Epstein committed the acts alleged herein maliciously, fraudulently and

oppressively with the wrongful intention of injuring Plaintiff from an improper and evil motive

amounting to malice and in conscious disregard of Plaintiff’s rights, entitling Plaintiff to recover

punitive and exemplary damages from Defendants in such sums as a jury would find fair, just

and appropriate to deter Defendants and others from future similar misconduct.

103. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

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104. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS FOR A SEVENTH CAUSE OF ACTION FOR

BATTERY OF JANE DOE XII AS TO JEFFREY EDWARD EPSTEIN

105. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 104., inclusive, with the

same force and effect as if hereafter set forth at length.

106. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

107. In or about 1991, when Plaintiff Jane Doe XII was approximately twenty-two

years old, Epstein fondled, groped and molested her.

108. Epstein’s predatory, sexual, and unlawful acts against Plaintiff amounted to a

series of harmful and offensive contacts to Plaintiff’s person, all of which were done

intentionally by him to her without her consent.

109. As a proximate result of the aforementioned batteries to Plaintiff, she suffered,

and continues to suffer from, extreme mental distress, humiliation, anguish, emotional and

physical injuries, as well as economic losses, those total damages in amounts to be proven at

trial.

110. By reason of the foregoing, Plaintiff was caused to sustain severe and serious

personal injuries and was caused to suffer severe physical pain and mental anguish as a result

thereof. Upon information and belief these injuries are of a permanent and lasting nature, and

Plaintiff was incapacitated from attending her regular activities and was caused to expend sums

of money for medical care on her behalf.

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111. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just, and adequate, and Plaintiff is further

entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

112. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

113. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR AN EIGHTH CAUSE OF ACTION FOR

ASSAULT OF JANE DOE XII AS TO JEFFREY EDWARD EPSTEIN

114. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 113., inclusive, with the

same force and effect as if hereafter set forth at length.

115. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

116. Epstein’s predatory, sexual and unlawful acts against Plaintiff created a

reasonable apprehension in Plaintiff of immediate harmful or offensive contact to Plaintiff’s

person, all of which were done intentionally by him to her without her consent.

117. As a direct and proximate result of the aforementioned assaults, Plaintiff has

sustained in the past, and will continue to sustain in the future, physical injury, pain and

suffering, serious and severe psychological and emotional distress, mental anguish,

embarrassment and humiliation.

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118. As a direct and proximate result of the aforementioned assaults, Plaintiff has

incurred medical expenses and other economic damages, and continues to be in physical pain

and suffering, and will now be obligated to expend sums of money for medical care and

attention in an effort to cure herself of her injuries and to alleviate her pain and suffering,

emotional distress, mental anguish, embarrassment and humiliation.

119. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just and adequate, and Plaintiff is further

entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

120. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

121. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A NINTH CAUSE OF ACTION FOR

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
OF JANE DOE III AS TO JEFFREY EDWARD EPSTEIN

122. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 121., inclusive, with the

same force and effect as if hereafter set forth at length.

123. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

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124. Epstein engaged in outrageous conduct towards Plaintiff, with the intention to

cause, or with reckless disregard for the probability of causing, Plaintiff to suffer severe

emotional distress.

125. As a proximate result of the aforementioned assaults and batteries to Plaintiff,

she suffered, and continues to suffer from, extreme mental distress, humiliation, anguish and

emotional and physical injuries, as well as economic losses, all her damage in amounts to be

proven at trial.

126. Epstein committed the acts alleged herein maliciously, fraudulently and

oppressively with the wrongful intention of injuring Plaintiff from an improper and evil motive

amounting to malice and in conscious disregard of Plaintiff’s rights, entitling Plaintiff to recover

punitive and exemplary damages from Defendants in such sums as a jury would find fair, just

and appropriate to deter Defendants and others from future similar misconduct.

127. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

128. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A TENTH CAUSE OF ACTION FOR

BATTERY OF JANE DOE XIII AS TO JEFFREY EDWARD EPSTEIN

129. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 128., inclusive, with the

same force and effect as if hereafter set forth at length.

130. Upon information and belief, defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

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131. In or about 1993, when Plaintiff Jane Doe XIII was approximately eleven years

old, Epstein sexually assaulted, abused, battered and digitally penetrated her on three, separate

occasions. Epstein also forced Plaintiff to perform oral sex on him.

132. Epstein’s predatory, sexual, and unlawful acts against Plaintiff amounted to a

series of harmful and offensive contacts to Plaintiff’s person, all of which were done

intentionally by him to her without her consent.

133. As a proximate result of the aforementioned batteries to Plaintiff, she suffered,

and continues to suffer from, extreme mental distress, humiliation, anguish, emotional and

physical injuries, as well as economic losses, those total damages in amounts to be proven at

trial.

134. By reason of the foregoing, Plaintiff was caused to sustain severe and serious

personal injuries and was caused to suffer severe physical pain and mental anguish as a result

thereof. Upon information and belief these injuries are of a permanent and lasting nature, and

Plaintiff was incapacitated from attending her regular activities and was caused to expend sums

of money for medical care on her behalf.

135. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just, and adequate, and Plaintiff is further

entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

136. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

137. This action falls within the exceptions to Article 16 of the C.P.L.R.

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AS AND FOR AN ELEVENTH CAUSE OF ACTION FOR

ASSAULT OF JANE DOE XIII AS TO JEFFREY EDWARD EPSTEIN

138. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 137., inclusive, with the

same force and effect as if hereafter set forth at length.

139. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

140. Epstein’s predatory, sexual and unlawful acts against Plaintiff created a

reasonable apprehension in Plaintiff of immediate harmful or offensive contact to Plaintiff’s

person, all of which were done intentionally by him to her without her consent.

141. As a direct and proximate result of the aforementioned assaults, Plaintiff has

sustained in the past, and will continue to sustain in the future, physical injury, pain and

suffering, serious and severe psychological and emotional distress, mental anguish,

embarrassment and humiliation.

142. As a direct and proximate result of the aforementioned assaults, Plaintiff has

incurred medical expenses and other economic damages, and continues to be in physical pain

and suffering, and will now be obligated to expend sums of money for medical care and

attention in an effort to cure herself of her injuries and to alleviate her pain and suffering,

emotional distress, mental anguish, embarrassment and humiliation.

143. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just and adequate, and Plaintiff is further

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entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

144. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

145. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A TWELTH CAUSE OF ACTION FOR

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
OF JANE DOE XIII AS TO JEFFREY EDWARD EPSTEIN

146. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 145., inclusive, with the

same force and effect as if hereafter set forth at length.

147. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

148. Epstein engaged in outrageous conduct towards Plaintiff, with the intention to

cause, or with reckless disregard for the probability of causing, Plaintiff to suffer severe

emotional distress.

149. As a proximate result of the aforementioned assaults and batteries to Plaintiff,

she suffered, and continues to suffer from, extreme mental distress, humiliation, anguish and

emotional and physical injuries, as well as economic losses, all her damage in amounts to be

proven at trial.

150. Epstein committed the acts alleged herein maliciously, fraudulently and

oppressively with the wrongful intention of injuring Plaintiff from an improper and evil motive

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amounting to malice and in conscious disregard of plaintiff’s rights, entitling Plaintiff to recover

punitive and exemplary damages from Defendants in such sums as a jury would find fair, just

and appropriate to deter Defendants and others from future similar misconduct.

151. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

152. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A THIRTEENTH CAUSE OF ACTION FOR

BATTERY OF JANE DOE XIV AS TO JEFFREY EDWARD EPSTEIN

153. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 152., inclusive, with the

same force and effect as if hereafter set forth at length.

154. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

155. In or about 1978 and continuing for a period of time thereafter, when Plaintiff

Jane Doe XIV was approximately thirteen years old, Epstein sexually assaulted, abused,

battered and raped her multiple times.

156. Epstein’s predatory, sexual, and unlawful acts against Plaintiff amounted to a

series of harmful and offensive contacts to Plaintiff’s person, all of which were done

intentionally by him to her without her consent.

157. As a proximate result of the aforementioned batteries to Plaintiff, she suffered,

and continues to suffer from, extreme mental distress, humiliation, anguish, emotional and

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physical injuries, as well as economic losses, those total damages in amounts to be proven at

trial.

158. By reason of the foregoing, Plaintiff was caused to sustain severe and serious

personal injuries and was caused to suffer severe physical pain and mental anguish as a result

thereof. Upon information and belief these injuries are of a permanent and lasting nature, and

Plaintiff was incapacitated from attending her regular activities and was caused to expend sums

of money for medical care on her behalf.

159. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just, and adequate, and Plaintiff is further

entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

160. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

161. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A FOURTEENTH CAUSE OF ACTION FOR ASSAULT

OF JANE DOE XIV AS TO DEFENDANT JEFFREY EDWARD EPSTEIN

162. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 161., inclusive, with the

same force and effect as if hereafter set forth at length.

163. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

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164. Epstein’s predatory, sexual and unlawful acts against Plaintiff, created a

reasonable apprehension in Plaintiff of immediate harmful or offensive contact to Plaintiff’s

person, all of which were done intentionally by him to her without her consent.

165. As a direct and proximate result of the aforementioned assaults, Plaintiff has

sustained in the past, and will continue to sustain in the future, physical injury, pain and

suffering, serious and severe psychological and emotional distress, mental anguish,

embarrassment and humiliation.

166. As a direct and proximate result of the aforementioned assaults, Plaintiff has

incurred medical expenses and other economic damages, and continues to be in physical pain

and suffering, and will now be obligated to expend sums of money for medical care and

attention in an effort to cure herself of her injuries and to alleviate her pain and suffering,

emotional distress, mental anguish, embarrassment and humiliation.

167. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just and adequate, and Plaintiff is further

entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

168. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

169. This action falls within the exceptions to Article 16 of the C.P.L.R.

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AS AND FOR A FIFTEENTH CAUSE OF ACTION FOR

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
OF JANE DOE XIV AS TO JEFFREY EDWARD EPSTEIN

170. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 169., inclusive, with the

same force and effect as if hereafter set forth at length.

171. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

172. Epstein engaged in outrageous conduct towards Plaintiff, with the intention to

cause, or with reckless disregard for the probability of causing, Plaintiff to suffer severe

emotional distress.

173. As a proximate result of the aforementioned assaults and batteries to Plaintiff,

she has suffered and continues to suffer extreme mental distress, humiliation, anguish and

emotional and physical injuries, as well as economic losses, all her damage in amounts to be

proven at trial.

174. Epstein committed the acts alleged herein maliciously, fraudulently and

oppressively with the wrongful intention of injuring Plaintiff from an improper and evil motive

amounting to malice and in conscious disregard of Plaintiff’s rights, entitling Plaintiff to recover

punitive and exemplary damages from Defendants in such sums as a jury would find fair, just

and appropriate to deter Defendants and others from future similar misconduct.

175. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

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176. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A SIXTEENTH CAUSE OF ACTION FOR

BATTERY OF JANE DOE XV AS TO JEFFREY EDWARD EPSTEIN

177. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 176., inclusive, with the

same force and effect as if hereafter set forth at length.

178. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

179. In or about 2004, when Plaintiff Jane Doe XV was approximately thirty-two

years old, Epstein sexually assaulted, abused, battered and raped her.

180. Epstein’s predatory, sexual, and unlawful acts against Plaintiff amounted to a

series of harmful and offensive contacts to Plaintiff’s person, all of which were done

intentionally by him to her without her consent.

181. As a proximate result of the aforementioned batteries to Plaintiff, she suffered,

and continues to suffer from, extreme mental distress, humiliation, anguish, emotional and

physical injuries, as well as economic losses, those total damages in amounts to be proven at

trial.

182. By reason of the foregoing, Plaintiff was caused to sustain severe and serious

personal injuries and was caused to suffer severe physical pain and mental anguish as a result

thereof. Upon information and belief these injuries are of a permanent and lasting nature, and

Plaintiff was incapacitated from attending her regular activities and was caused to expend sums

of money for medical care on her behalf.

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183. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just, and adequate, and Plaintiff is further

entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

184. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

185. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A SEVENTEENTH CAUSE OF ACTION FOR

ASSAULT OF JANE DOE XV AS TO JEFFREY EDWARD EPSTEIN

186. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 185., inclusive, with the

same force and effect as if hereafter set forth at length.

187. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

188. Epstein’s predatory, sexual and unlawful acts against Plaintiff created a

reasonable apprehension in Plaintiff of immediate harmful or offensive contact to Plaintiff’s

person, all of which were done intentionally by him to her without her consent.

189. As a direct and proximate result of the aforementioned assaults, Plaintiff has

sustained in the past, and will continue to sustain in the future, physical injury, pain and

suffering, serious and severe psychological and emotional distress, mental anguish,

embarrassment and humiliation.

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190. As a direct and proximate result of the aforementioned assaults, Plaintiff has

incurred medical expenses and other economic damages, and continues to be in physical pain

and suffering, and will now be obligated to expend sums of money for medical care and

attention in an effort to cure herself of her injuries and to alleviate her pain and suffering,

emotional distress, mental anguish, embarrassment and humiliation.

191. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just and adequate, and Plaintiff is further

entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

192. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

193. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR AN EIGHTEENTH CAUSE OF ACTION FOR

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
OF JANE DOE XV AS TO JEFFREY EDWARD EPSTEIN

194. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 193., inclusive, with the

same force and effect as if hereafter set forth at length.

195. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

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196. Epstein engaged in outrageous conduct towards Plaintiff, with the intention to

cause, or with reckless disregard for the probability of causing, Plaintiff to suffer severe

emotional distress.

197. As a proximate result of the aforementioned assaults and batteries to Plaintiff,

she suffered, and continues to suffer from, extreme mental distress, humiliation, anguish and

emotional and physical injuries, as well as economic losses, all her damage in amounts to be

proven at trial.

198. Epstein committed the acts alleged herein maliciously, fraudulently and

oppressively with the wrongful intention of injuring Plaintiff from an improper and evil motive

amounting to malice and in conscious disregard of Plaintiff’s rights, entitling Plaintiff to recover

punitive and exemplary damages from Defendants in such sums as a jury would find fair, just

and appropriate to deter Defendants and others from future similar misconduct.

199. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

200. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A NINTEENTH CAUSE OF ACTION FOR

BATTERY OF JANE DOE XVI AS TO JEFFREY EDWARD EPSTEIN

201. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 200., inclusive, with the

same force and effect as if hereafter set forth at length.

202. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

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203. In or about 2000, when Plaintiff Jane Doe XVI was approximately seventeen

years old, Epstein and sexually assaulted, abused, battered and raped her on at least three,

separate occasions.

204. Epstein’s predatory, sexual, and unlawful acts against Plaintiff amounted to a

series of harmful and offensive contacts to Plaintiff’s person, all of which were done

intentionally by him to her without her consent.

205. As a proximate result of the aforementioned batteries to Plaintiff, she suffered,

and continues to suffer from, extreme mental distress, humiliation, anguish, emotional and

physical injuries, as well as economic losses, those total damages in amounts to be proven at

trial.

206. By reason of the foregoing, Plaintiff was caused to sustain severe and serious

personal injuries and was caused to suffer severe physical pain and mental anguish as a result

thereof. Upon information and belief these injuries are of a permanent and lasting nature, and

Plaintiff was incapacitated from attending her regular activities and was caused to expend sums

of money for medical care on her behalf.

207. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just, and adequate, and Plaintiff is further

entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

208. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

209. This action falls within the exceptions to Article 16 of the C.P.L.R.

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AS AND FOR A TWENTIETH CAUSE OF ACTION FOR

ASSAULT OF JANE DOE XVI AS TO JEFFREY EDWARD EPSTEIN

210. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 209., inclusive, with the

same force and effect as if hereafter set forth at length.

211. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

212. Epstein’s predatory, sexual and unlawful acts against Plaintiff created a

reasonable apprehension in Plaintiff of immediate harmful or offensive contact to Plaintiff’s

person, all of which were done intentionally by him to her without her consent.

213. As a direct and proximate result of the aforementioned assaults, Plaintiff has

sustained in the past, and will continue to sustain in the future, physical injury, pain and

suffering, serious and severe psychological and emotional distress, mental anguish,

embarrassment and humiliation.

214. As a direct and proximate result of the aforementioned assaults, Plaintiff has

incurred medical expenses and other economic damages, and continues to be in physical pain

and suffering, and will now be obligated to expend sums of money for medical care and

attention in an effort to cure herself of her injuries and to alleviate her pain and suffering,

emotional distress, mental anguish, embarrassment and humiliation.

215. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just and adequate, and Plaintiff is further

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entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct..

216. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

217. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A TWENTY-FIRST CAUSE OF ACTION FOR

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
OF JANE DOE XVI AS TO JEFFREY EDWARD EPSTEIN

218. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 217., inclusive, with the

same force and effect as if hereafter set forth at length.

219. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

220. Epstein engaged in outrageous conduct towards Plaintiff, with the intention to

cause, or with reckless disregard for the probability of causing, Plaintiff to suffer severe

emotional distress.

221. As a proximate result of the aforementioned assaults and batteries to Plaintiff,

she suffered, and continues to suffer from extreme mental distress, humiliation, anguish and

emotional and physical injuries, as well as economic losses, all her damage in amounts to be

proven at trial.

222. Epstein committed the acts alleged herein maliciously, fraudulently and

oppressively with the wrongful intention of injuring Plaintiff from an improper and evil motive

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amounting to malice and in conscious disregard of Plaintiff’s rights, entitling Plaintiff to recover

punitive and exemplary damages from Defendants in such sums as a jury would find fair, just

and appropriate to deter Defendants and others from future similar misconduct.

223. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

224. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A TWENTY-SECOND CAUSE OF ACTION FOR

BATTERY OF JANE DOE XVII AS TO JEFFREY EDWARD EPSTEIN

225. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 224., inclusive, with the

same force and effect as if hereafter set forth at length.

226. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

227. In or about 2001, and continuing for a period of time thereafter up to and

including 2002, when Plaintiff Jane Doe XVII was approximately twenty-five years-old,

Epstein repeatedly sexually assaulted, abused and battered her

228. Epstein’s predatory, sexual, and unlawful acts against Plaintiff amounted to a

series of harmful and offensive contacts to Plaintiff’s person, all of which were done

intentionally by him to her without her consent.

229. As a proximate result of the aforementioned batteries to Plaintiff, she suffered,

and continues to suffer from, extreme mental distress, humiliation, anguish, emotional and

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physical injuries, as well as economic losses, those total damages in amounts to be proven at

trial.

230. By reason of the foregoing, Plaintiff was caused to sustain severe and serious

personal injuries and was caused to suffer severe physical pain and mental anguish as a result

thereof. Upon information and belief these injuries are of a permanent and lasting nature, and

Plaintiff was incapacitated from attending her regular activities and was caused to expend sums

of money for medical care on her behalf.

231. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just, and adequate, and Plaintiff is further

entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

232. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

233. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A TWENTY-THIRD CAUSE OF ACTION FOR

ASSAULT OF JANE DOE XVII AS TO JEFFREY EDWARD EPSTEIN

234. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 233., inclusive, with the

same force and effect as if hereafter set forth at length.

235. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

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236. Epstein’s predatory, sexual and unlawful acts against Plaintiff created a

reasonable apprehension in plaintiff of immediate harmful or offensive contact to Plaintiff’s

person, all of which were done intentionally by him to her without her consent.

237. As a direct and proximate result of the aforementioned assaults, Plaintiff has

sustained in the past, and will continue to sustain in the future, physical injury, pain and

suffering, serious and severe psychological and emotional distress, mental anguish,

embarrassment and humiliation.

238. As a direct and proximate result of the aforementioned assaults, Plaintiff has

incurred medical expenses and other economic damages, and continues to be in physical pain

and suffering, and will now be obligated to expend sums of money for medical care and

attention in an effort to cure herself of her injuries and to alleviate her pain and suffering,

emotional distress, mental anguish, embarrassment and humiliation.

239. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just and adequate, and Plaintiff is further

entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

240. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

241. This action falls within the exceptions to Article 16 of the C.P.L.R.

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AS AND FOR A TWENTY-FOURTH CAUSE OF ACTION FOR

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
OF JANE DOE XVII AS TO JEFFREY EDWARD EPSTEIN

242. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 242., inclusive, with the

same force and effect as if hereafter set forth at length.

243. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

244. Epstein engaged in outrageous conduct towards Plaintiff, with the intention to

cause, or with reckless disregard for the probability of causing, Plaintiff to suffer severe

emotional distress.

245. As a proximate result of the aforementioned assaults and batteries to Plaintiff,

she has suffered and continues to suffer extreme mental distress, humiliation, anguish and

emotional and physical injuries, as well as economic losses, all her damage in amounts to be

proven at trial.

246. Epstein committed the acts alleged herein maliciously, fraudulently and

oppressively with the wrongful intention of injuring Plaintiff from an improper and evil motive

amounting to malice and in conscious disregard of Plaintiff’s rights, entitling Plaintiff to recover

punitive and exemplary damages from Defendants in such sums as a jury would find fair, just

and appropriate to deter Defendants and others from future similar misconduct.

247. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

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248. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A TWENTY-FIFTH CAUSE OF ACTION FOR

BATTERY OF JANE DOE XVIII AS TO JEFFREY EDWARD EPSTEIN

249. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 248., inclusive, with the

same force and effect as if hereafter set forth at length.

250. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

251. In or about 2003, when Plaintiff Jane Doe XVI was approximately thirteen years

old, Epstein and sexually assaulted, abused, battered and raped her.

252. Epstein’s predatory, sexual, and unlawful acts against Plaintiff amounted to a

series of harmful and offensive contacts to Plaintiff’s person, all of which were done

intentionally by him to her without her consent.

253. As a proximate result of the aforementioned batteries to Plaintiff, she suffered,

and continues to suffer from, extreme mental distress, humiliation, anguish, emotional and

physical injuries, as well as economic losses, those total damages in amounts to be proven at

trial.

254. By reason of the foregoing, Plaintiff was caused to sustain severe and serious

personal injuries and was caused to suffer severe physical pain and mental anguish as a result

thereof. Upon information and belief these injuries are of a permanent and lasting nature, and

Plaintiff was incapacitated from attending her regular activities and was caused to expend sums

of money for medical care on her behalf.

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255. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just, and adequate, and Plaintiff is further

entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct.

256. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

257. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A TWENTY-SIXTH CAUSE OF ACTION FOR

ASSAULT OF JANE DOE XVIII AS TO JEFFREY EDWARD EPSTEIN

258. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 257., inclusive, with the

same force and effect as if hereafter set forth at length.

259. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

260. Epstein’s predatory, sexual and unlawful acts against Plaintiff created a

reasonable apprehension in Plaintiff of immediate harmful or offensive contact to Plaintiff’s

person, all of which were done intentionally by him to her without her consent.

261. As a direct and proximate result of the aforementioned assaults, Plaintiff has

sustained in the past, and will continue to sustain in the future, physical injury, pain and

suffering, serious and severe psychological and emotional distress, mental anguish,

embarrassment and humiliation.

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262. As a direct and proximate result of the aforementioned assaults, Plaintiff has

incurred medical expenses and other economic damages, and continues to be in physical pain

and suffering, and will now be obligated to expend sums of money for medical care and

attention in an effort to cure herself of her injuries and to alleviate her pain and suffering,

emotional distress, mental anguish, embarrassment and humiliation.

263. By reason of the foregoing, Plaintiff is entitled to compensatory damages from

Defendants in such sums as a jury would find fair, just and adequate, and Plaintiff is further

entitled to punitive and exemplary damages from Defendants in such sums as a jury would find

fair, just and appropriate to deter Defendants and others from future similar misconduct..

264. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

265. This action falls within the exceptions to Article 16 of the C.P.L.R.

AS AND FOR A TWENTY-SEVENTH CAUSE OF ACTION FOR

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
OF JANE DOE XVIII AS TO JEFFREY EDWARD EPSTEIN

266. Plaintiffs repeat reiterate, and reallege each and every allegation contained in

those paragraphs of the Complaint marked and designated 1. through 265., inclusive, with the

same force and effect as if hereafter set forth at length.

267. Upon information and belief, Defendants DARREN K. INDYKE and

RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY

EDWARD EPSTEIN, act as the successors-in-interest and/or obligors to Epstein’s assets,

obligations and responsibilities.

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268. Epstein engaged in outrageous conduct towards Plaintiff, with the intention to

cause, or with reckless disregard for the probability of causing, Plaintiff to suffer severe

emotional distress.

269. As a proximate result of the aforementioned assaults and batteries to Plaintiff,

she suffered, and continues to suffer from extreme mental distress, humiliation, anguish and

emotional and physical injuries, as well as economic losses, all her damage in amounts to be

proven at trial.

270. Epstein committed the acts alleged herein maliciously, fraudulently and

oppressively with the wrongful intention of injuring Plaintiff from an improper and evil motive

amounting to malice and in conscious disregard of Plaintiff’s rights, entitling Plaintiff to recover

punitive and exemplary damages from Defendants in such sums as a jury would find fair, just

and appropriate to deter Defendants and others from future similar misconduct.

271. The amount of damages sought exceeds the jurisdiction of all lower courts which

would otherwise have jurisdiction.

272. This action falls within the exceptions to Article 16 of the C.P.L.R.

WHEREFORE, Plaintiffs demand judgement against Defendants in such sum as a jury

would find fair, adequate and just containing the following relief:

A. A declaratory judgement that the actions, conduct and practices of Defendants

complained of herein violate the laws of the State of New York;

B. An injunction and order permanently restraining Defendants from engaging in

such unlawful conduct;

C. An award of damages in an amount to be determined at trial, plus prejudgment

interest, to compensate Plaintiffs for all monetary and/or economic harm; harm to their personal

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and professional reputations and loss of career fulfillment; for all non-monetary and/or

compensatory harm including but not limited to, compensation for physical anguish and mental

anguish; all other monetary and/or non-monetary losses suffered by Plaintiffs; and, that by

reason of the foregoing, Plaintiffs sustained damages in a sum, pursuant to C.P.L.R. §3017,

which exceeds the jurisdictional limits of all lower courts;

D. An award of punitive damages;

E. An award of costs that Plaintiffs have incurred in this action, as well as

Plaintiffs’ reasonable attorneys’ fees to the fullest extent permitted by law; and,

F. Such other and further relief as this Honorable Court may deem just and proper.

Dated: New York, New York

August 13, 2020

MERSON LAW, PLLC

By:
Jordan K. Merson
Jesse R. Mautner
Attorney for Plaintiffs
150 East 58th Street, 34th Floor
New York, New York 10155
(212) 603-9100

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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK
-------------------------------------------------------------------X
JANE DOE X, JANE DOE XI, JANE DOE XII, JANE
DOE XIII, JANE DOE XIV, JANE DOE XV, JANE
DOE XVI, JANE DOE XVII and JANE DOE XVIII,

Plaintiffs, Index No.: __________/20

-against-
ATTORNEY
VERIFICATION
DARREN K. INDYKE and RICHARD D. KAHN, in
their capacities as the executors of the ESTATE OF
JEFFREY EDWARD EPSTEIN,

Defendants.
-------------------------------------------------------------------X
JORDAN K. MERSON, ESQ., an attorney duly admitted to practice in the Courts of

New York State, and a member of the firm MERSON LAW, PLLC, attorneys for Plaintiffs in

the within action, hereby affirms under penalty of perjury:

That he has read the within Verified Complaint and knows the contents thereof, and that

the same is true to his own knowledge, except as to the matters therein stated to be alleged upon

information and belief, and that as to those matters, he believes them to be true;

That the sources of his information and knowledge are investigations and records in the

file maintained by his office; and,

That the reason this verification is made by him and not by any Plaintiffs herein is that

Plaintiffs do not reside in the County where he has his office.

Dated: New York, New York

August 13, 2020

JORDAN K. MERSON

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Index No. Year 2020

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK

JANE DOE X, JANE DOE XI, JANE DOE XII, JANE DOE
XIII, JANE DOE XIV, JANE DOE XV, JANE DOE XVI, JANE
DOE XVII and JANE DOE XVIII,

Plaintiffs,

-against-

DARREN K. INDYKE and RICHARD D. KAHN, in their capacities

as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN,

Defendants.

SUMMONS AND VERIFIED COMPLAINT

Merson Law, PLLC

Attorneys for Plaintiff

Office and Post Office Address, Telephone

150 East 58th Street, 34/F
New York, New York 10155
(212) 603-9100

To: All Parties

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