EFTA00025109.pdf

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Source set: data-set-8

Extracted text

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

Case 1:19-cv-10788-GHW-DCF Document 1 Filed 11/21/19 Page 2 of 13
4.
Epstein exploited this power over seventeen-year-old
to sexually
abuse her repeatedly. Ultimately, he raped and sexually assaulted her frequently and in a variety
of places and settings, including by trafficking
to his homes in New York, New Mexico,
Florida, the Virgin Islands, and France. He treated her like an object for his sexual gratification.
5.
These assaults caused
to feel completely intimidated and fearful…

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