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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
CASE NO.: 
PRISCILLA DOE, 
Plaintiff, 
vs. 
DARREN K. INDYKE AND 
RICHARD D. KAHN AS JOINT 
PERSONAL REPRESENTATIVES OF 
THE ESTATE OF JEFFREY E. EPSTEIN, 
NINE EAST 715T STREET, CORPORATION, 
FINANCIAL TRUST COMPANY, INC., 
NES, LLC, MAPLE, INC., LSJ, LLC, 
HBRK ASSOCIATES, INC., JEGE, INC., 
Defendants. 
COMPLAINT 
Plaintiff, PRISCILLA DOE, by and through her undersigned counsel, for her 
claims against Defendants, alleges as follows: 
1. 
This action is brought pursuant to 18 U.S.C. §1591 - § 1595. Therefore, 
jurisdiction is proper under 28 U.S.C. §1331. 
2. 
Plaintiff files this Complaint under a pseudonym in order to protect her 
identity because this Complaint makes allegations of a sensitive sexual nature the 
disclosure of which, in association with her name, would cause further harm to her. 
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3. 
Plaintiff is currently a resident of and domiciled in the 
4. 
At all times material, Jeffrey Epstein was a citizen of the United States 
and a resident of the U.S. Virgin Islands. Jeffrey Epstein was a man of extraordinary 
wealth who travelled between and stayed regularly in multiple residences, including 
in New York, New York (within the Southern District of New York) at 9 East 7P 
Street, New York, NY 10021; in Palm Beach, Florida at 358 El Brillo Way, Palm 
Beach, Florida 33480; in New Mexico at 49 Zorro Ranch Road, Stanley, New 
Mexico 87056, and in the United States Virgin Islands at Island Little St. James 
Island No. 6B USVI 00802. 
5. 
At all times material to this cause of action Jeffrey Epstein was an adult 
male born in 1953, who died on August 10, 2019. 
6. 
Defendant, Darren K. Indyke and Richard D. Kahn as Joint Personal 
Representatives of the Estate of Jeffrey E. Epstein ("Estate of Jeffrey E. Epstein") 
the Estate of Jeffrey E. Epstein was opened and domiciled in the United States Virgin 
Islands, St. Thomas Division, and is the legal entity responsible for intentional, 
criminal, or tortious conduct committed by Jeffrey Epstein as described in this 
Complaint. 
7. 
At all times material hereto, Defendant Nine East 71st Street, 
Corporation ("Nine East") was a domestic business corporation conducting business 
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in New York, with its principal place of business located at 575 Lexington Avenue, 
Fourth Floor, New York, NY 10022. 
8. 
At all times material hereto, Defendant Financial Trust Company, Inc. 
("Financial Trust"), was and is a U.S. Virgin Islands corporation conducting 
business in multiple locations including New York. 
9. 
At all times material hereto, Defendant NES, LLC, ("NES") was and is 
a domestic limited liability company registered in and conducting business in 
multiple locations including New York. 
10. 
At all times material hereto, Defendant, Maple, Inc., ("Maple") is and 
was a U.S. Virgin Islands corporation which conducted business in New York. 
11. 
At all times material hereto, Defendant L.S.J., LLC, ("LSJ") was a 
Delaware corporation conducting business in the United States Virgin Islands with 
a registered agent located at 1209 Orange Street, Wilmington, Delaware 19801. 
12. 
At all times material hereto, Defendant HBRK Associates, Inc., 
("HBRK") is and was a domestic business corporation registered in and conducting 
business in multiple locations including New York with a Registered Agent located 
at 1365 York Avenue, Apartment 28, New York, New York 10021. 
13. 
At all times material hereto, Defendant JEGE, Inc., ("JEGE") was a 
Delaware corporation conducting business throughout the United States of America, 
including but not limited to, Florida, New York, and the United States Virgin 
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Islands, with a registered agent located at 1209 Orange Street, Wilmington, 
Delaware 19801. 
14. Corporate Defendants NES, LLC; Financial Trust Company, Inc; Nine East 
71 " Street; Maple, Inc.; L.S.J., LLC; HBRK Associates, Inc.; and JEGE, Inc., 
referred to as "Corporate Defendants," each performed business, in whole or part, in 
New York. 
15. 
Plaintiff intends to amend this complaint to add or substitute additional 
parties as discovery reveals the identities of other tortious corporate or individual 
actors. 
16. 
Jeffrey Epstein, the leader of a complex commercial sex trafficking and 
abuse ring, was an officer, director, or employee of many corporate entities 
registered in various states throughout the United States, one or more of which may 
also be legally responsible for the crimes he committed against young females, 
including Plaintiff 
17. 
Additionally, individuals who worked at the residences where sexual 
criminal acts were committed, or friends or acquaintances who assisted Jeffrey 
Epstein in committing such violations or those of his wealthy, famous, or socially 
powerful friends with whom Jeffrey Epstein caused Plaintiff to be sexually abused 
by, or those who were employed through, or worked for, numerous other corporate 
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entities whose participation caused or contributed to causing the sexual violations 
that caused harm to Plaintiff, may additionally be added as defendants. 
18. 
A substantial part of the acts, events, and omissions giving rise to this 
cause of action occurred in the Southern District of New York; venue is proper in 
this District. 28 U.S.C. section 1391(b)(2). 
19. 
At all times material to this cause of action, Jeffrey Epstein (legally 
represented now through Darren K. Indyke and Richard D. Kahn as Joint Personal 
Representatives of the Estate of Jeffrey E. Epstein (and referred to herein as "Estate 
of Jeffrey E. Epstein") and Corporate Defendants owed a duty to Plaintiff to treat 
her in a non-negligent manner and not to commit, or conspire to commit, or cause to 
be committed intentional, criminal, fraudulent, or tortious acts against Plaintiff, 
including any acts that would cause Plaintiff to be harmed through conduct 
committed against her in violation of Common law battery, New York Penal Law 
section 130.20; or New York Penal Law 130.35; or New York Penal Law 130.50; or 
New York Penal Law 130.52; or New York Penal Law 130.66; or any violation of 
18 U.S.C. §1591 - §1595. 
FACTUAL ALLEGATIONS 
20. 
At all times material to this cause of action, Jeffrey Epstein was an adult 
male over 45 years old. Epstein was a tremendously wealthy individual, widely 
recognized as a billionaire, who used his wealth, power, resources, and connections 
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to commit illegal sexual crimes in violation of federal and state laws and who 
employed or conspired with other individuals and corporate entities to assist him in 
committing those crimes or torts or who facilitated or enabled those acts to occur. 
21. 
Epstein displayed his enormous wealth, power, and influence to his 
employees; to the employees of the corporate or company entities who worked at his 
direction; to the victims procured for sexual purposes; and to the public, in order to 
advance, carry out and conceal his crimes and torts. 
22. 
At all relevant times, Epstein had access to numerous mansions, as well 
as a fleet of airplanes, motor vehicles, boats and one or more helicopters. For 
example, he regularly traveled by private jet aboard a Boeing aircraft (of make and 
model B-727-31H with tail number N908JE) or a Gulfstream aircraft (of make and 
model G-1159B with tail number N909JE). 
23. 
Jeffrey Epstein also frequently inhabited and travelled between 
numerous properties and homes, each of which he admitted to being owned or 
controlled by him, including a Manhattan townhotne located at 9 East 71' Street, 
New York, NY 10021 valued conservatively by Jeffrey Epstein's own admission at 
$55,931,000.00; a ranch located at 49 Zorro Ranch Road, Stanley, New Mexico 
87056 valued conservatively by Jeffrey Epstein's own admission at $17,246,208.00; 
a home located at 358 El Brillo Way, Palm Beach, Florida 33480 valued 
conservatively by Jeffrey Epstein's own admission at $12,380,209.00; an apartment 
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located at 22 Avenue Foch, Paris, France 75116 valued conservatively by Jeffrey 
Epstein's own admission at $8,672,820.00; an Island located at Great St. James 
Island No. 6A USVI 00802 (parcels A, B, C); and an Island Little St. James Island 
No. 6B USVI 00802 (A, B, C). See Jeffrey Epstein "Asset Summary — June 30, 
2019" filed in Case 1:19-cr-00490-RMB on July 15, 2019 attached hereto as Exhibit 
A. 
24. 
Jeffrey Epstein controlled or was otherwise affiliated with the 
corporation or business entities that owned, managed, or maintained each of the real 
properties listed in the preceding paragraph. 
25. 
The allegations herein concern Jeffrey Epstein's tortious conduct 
committed against Plaintiff; while at the residence owned by Defendant Nine East 
and then Defendant Maple; or the residence located in the United States Virgin 
Islands owned by LSJ. Many such acts were facilitated by Defendant NES, or 
Defendant HBRK, or Defendant JEGE. 
26. 
Epstein had a compulsive sexual preference for young females, as 
young as 14 years old, and acted on that sexual preference for decades. 
27. 
Epstein enjoyed sexual contact with young females, including minor 
children, and also took pleasure corrupting vulnerable and innocent young females, 
including minor children, into engaging in sexual acts with him. 
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28. 
Epstein directed a complex system of individuals, including employees 
and associates of Defendant entities, to work in concert and at his direction, for the 
purpose of harming young females through sexual exploitation, abuse and 
trafficking. 
29. 
It was widely known among individuals regularly in Epstein's presence 
that he obtained pleasure from corrupting and inducing vulnerable young females 
into engaging in uncomfortable and unwanted sexual acts for his own gratification. 
30. 
Epstein's illegal sexual activities were investigated by law enforcement 
on at least two occasions, once in 2005-2008 by the United States Attorney for the 
Southern District of Florida, and more recently by the United States Attorney for the 
Southern District of New York. 
31. 
On July 2, 2019, the United States Attorney's Office for the Southern 
District of New York filed a Sealed Two Count Indictment including One Count of 
Sex Trafficking Conspiracy and One Count of Sex Trafficking for violations of 18 
U.S.C. §1591, in part due to Epstein's criminal activities against children in the New 
York Mansion located at 9 East 71s1 Street. 
32. 
On July 8, 2019, Jeffrey Epstein was arrested pursuant to the 
aforementioned Indictment, which is attached hereto as Exhibit B. 
33. 
The Indictment stated in part, and Plaintiff herein adopts as true and 
relevant to her Complaint, that "Jeffrey Epstein, the defendant, enticed and recruited, 
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and caused to be enticed and recruited, minor girls to visit his mansion in Manhattan, 
New York (the "New York Residence") and his estate in Palm Beach, Florida (the 
"Palm Beach Residence") to engage in sex acts with him, after which the victims 
were given hundreds of dollars in cash." Criminal Indictment at 1. 
34. 
"Moreover, and in order to maintain and increase his supply of victims, 
Epstein also paid certain of his victims to recruit additional girls to be similarly 
abused by EPSTEIN. In this way, EPSTEIN created a vast network of underage 
victims for him to sexually exploit in locations including New York and Palm 
Beach." Criminal Indictment at 1-2. 
35. 
"The victims described herein were as young as 14 years old at the time 
they were abused by Jeffrey Epstein, and were, for various reasons, often particularly 
vulnerable to exploitation. Epstein intentionally sought out minors and knew that 
many of his victims were in fact under the age of 18, including because, in some 
instances, minor victims expressly told him their age." Criminal Indictment at 2. 
36. 
"In creating and maintaining this network of minor victims in multiple 
states to sexually abuse and exploit, JEFFREY EPSTEIN ... worked and conspired 
with others, including employees and associates who facilitated his conduct by, 
among other things, contacting victims and scheduling their sexual encounters with 
EPSTEIN at the New York Residence and at the Palm Beach Residence." Criminal 
Indictment at 2. 
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37. 
The indictment further explained, and Plaintiff adopts and alleges, that, 
"[v]ictims were initially recruited to provide `massages' to Epstein, which would be 
performed nude or partially nude, would become increasingly sexual in nature, and 
would typically include one or more sex acts." Criminal Indictment at 3. 
38. 
"Epstein abused numerous minor victims at the New York Residence 
by causing these victims to be recruited to engage in paid sex acts with him." 
Criminal Indictment at 3. 
39. 
In addition to the allegations in the criminal indictment referenced 
above, Epstein also utilized a similar, if not the same, scheme many years before the 
time period that was charged and many years after, as well as in additional locations 
nationally and internationally. 
40. 
Corporate Defendants enabled Jeffrey Epstein to receive daily 
massages from young females, often minors, who were not experienced in massage. 
Rather than receive regular body massages, Epstein was predictably sexually 
abusing the young females, including Plaintiff, in violation of New York Penal Law 
Section 130. 
41. 
Additionally, employees of the various Corporate Defendant performed 
actions or failed to perform actions that further placed victims, including Plaintiff, 
in danger of being sexually abused by Epstein, and assisted in the concealment of 
his sexually abusive acts. 
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42. 
Defendants employed many recruiters of young females, or directed 
employees of his related companies, to recruit young females. In order to grow the 
enterprise and satisfy his insatiable sexual desire, Epstein and those working at his 
direction enabled victims themselves to elevate their status within the enterprise to 
that of a paid recruiter of other victims, an elevation only made possible through the 
assistance of Defendants. 
43. 
Recruiters were taught by Jeffrey Epstein or by employees of Corporate 
Defendants to inform targeted young female victims that Epstein possessed 
extraordinary wealth, power, resources, and influence; that he was a philanthropist 
who would help female victims advance their education, careers, and lives; and that 
she only needed to provide Epstein with body massages in order to avail herself of 
his nearly unlimited assistance and influence. 
44. 
Epstein and Corporate Defendants and their many employees fulfilled 
Epstein's compulsive need for sex with young females by preying on their personal, 
psychological, financial, and related vulnerabilities. Epstein and Defendants' tactics 
included promising the victims money, shelter, transportation, gifts, employment, 
admission into educational institutions, educational tuition, profession, licensure, 
protection, healthcare, and other things of value. 
45. 
Jeffrey Epstein's sexual attraction to young, often underage, females 
dated back to at least the mid-nineties and the number of victims increased 
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substantially with the necessary assistance from Defendants and Defendants' 
employees. 
46. 
Defendants, at the direction of Epstein or in furtherance of his demands, 
and with help from assistants, associates and underlings, and even other victims, 
recruited or procured dozens if not hundreds of young females, including minors, 
for the purpose of Epstein's sexual gratification. 
47. 
Jeffrey Epstein, and employees of certain Corporate Defendants, 
including at least Defendant HBRK, specifically targeted underprivileged, 
emotionally vulnerable and/or economically disadvantaged young females to 
sexually molest and abuse. 
48. 
Additionally, Jeffrey Epstein and Corporate Defendants, through 
employees, informed young females, including Plaintiff, that Jeffrey Epstein was 
wealthy, well-connected, and had the power and ability to impact the life of any 
young female recruited or obtained to provide a massage. 
49. 
Each of the Corporate Defendants committed acts of negligence that 
allowed for Epstein to commit acts in violation of New York Penal Law section 130. 
50. 
Each of the Defendants committed acts against Plaintiff in violation of 
18 U.S.C. §I59 I - §1595. 
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PRISCILLA DOE 
51. 
Plaintiff was twenty years old when she met Jeffrey Epstein in 2006, at 
a time when Jeffrey Epstein was under federal criminal investigation by the United 
States Attorney for the Southern District of Florida in relation to his commission of 
various federal crimes, including violations of 18 U.S.C. §1591, against more than 
30 identified minor females. 
52. 
Plaintiff was a_in 
New York when she was recruited to meet 
Jeffrey Epstein by another young female who had also fallen prey to Jeffrey 
Epstein's sex trafficking scheme. 
53. 
The recruiter asked Plaintiff if she wanted a job giving massages to a 
very wealthy man. 
54. 
Plaintiff agreed to meet Jeffrey Epstein, knowing that she would be 
going to a New York mansion to give a wealthy man a massage. 
55. 
The first time to the Mansion at 9 East 71st Street, she was taken 
upstairs and Jeffrey Epstein paid her hundreds of dollars to give him a massage. This 
massage was not sexual and Jeffrey Epstein used the time to ask Plaintiff about her 
life, during which he learned that 
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56. 
Jeffrey Epstein paid Plaintiff for the massage, took her number and told 
her someone would call her to return. 
57. 
Associate I called Plaintiff and told her to come back for a second time. 
58. 
Again, on a second visit, Plaintiff was taken to the massage room in the 
Mansion and Jeffrey Epstein spent much of the time asking questions about Plaintiff, 
learning what she cared about, what professional plans she had, and what problems 
she was experiencing. 
59. 
By the third visit, in 2006, Jeffrey Epstein informed Plaintiff that he had 
resources that he would use to advance Plaintiff's 
career if she would do what 
he wanted her to do. 
60. 
Plaintiff started visiting Jeffrey Epstein more regularly and he began 
making the massages more sexual, digitally penetrating Plaintiff, and using sexual 
objects to insert in Plaintiff. 
61. 
Jeffrey Epstein always reminded Plaintiff that because of the money he 
was paying her for the commercial sex acts that he called "massage," she was able, 
for the first time, to pay for her mother's rent and for her own groceries. 
62. 
During her conversations with Jeffrey Epstein, 
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63. 
Despite the fact that he had assured Plaintiff he would not try to have 
sexual intercourse with her, Jeffrey Epstein forced himself on Plaintiff 
against her will and wishes. 
64. 
In 2006, Jeffrey Epstein told Plaintiff she was going on a trip with him 
to his island in the United States Virgin Islands. 
65. 
On that trip was Jeffrey Epstein, Jean Luc Brunel, Ghislaine Maxwell, 
Associate 2, Associate 8, and two other victims in addition to Plaintiff. 
66. 
It was there that Ghislaine Maxwell taught Plaintiff the "proper way to 
give a blow job," describing to her the exact way that Jeffrey Epstein liked to he 
sexually serviced orally. 
67. 
Ghislaine Maxwell explicitly told Plaintiff she needed to learn how to 
properly sexually service Jeffrey Epstein in the exact way that he preferred. 
68. 
Ghislaine Maxwell then taught Plaintiff step by step, using her own 
hands to demonstrate, how to pleasure Jeffrey Epstein manually so that Plaintiff 
would know exactly how to make Jeffrey Epstein happy. 
69. 
The instruction by Ghislaine Maxwell included training on the proper 
pressure to apply, the location in which pressure should be applied, the location of 
the various nerve endings that should be stimulated, and the areas of the penis that 
are the most sensitive for targeted stimulation. 
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70. 
Ghislaine Maxwell made it clear to Plaintiff that it was very important 
for her to understand and take this instruction seriously. The message delivered to 
Plaintiff by Ghislaine Maxwell was conveyed in a serious manner that instilled 
genuine fear in Plaintiff that her failure to comply would cause her serious harm. 
71. 
When Plaintiff was called in to "massage" Jeffrey Epstein on the Island 
after Ghislaine Maxwell's instruction, he reiterated the same instruction that Plaintiff 
was provided by Ghislaine Maxwell using a hands on approach. 
72. 
In addition to providing sexual instruction, Ghislaine Maxwell further 
made sure that Plaintiff and the other young females were constantly on call to 
sexually service Jeffrey Epstein. 
73. 
While on the Island, Associate 2 also made it clear to Plaintiff that when 
Jeffrey Epstein asked her to engage in certain sexual behavior, she needed to comply. 
74. 
Shortly thereafter, Jeffrey Epstein forced Plaintiff to engage in sexual 
activity with Associate 2 in his presence for his own sexual gratification. The 
experience between Plaintiff and Associate 2 was especially uncomfortable for 
Plaintiff. Jeffrey Epstein directed Associate 2 to use force on Plaintiff even after 
Plaintiff stated that she was uncomfortable and did not want to participate in the 
sexual acts then underway. At one point during the encounter, Jeffrey Epstein put 
his hands around Plaintiff's neck, which caused her a great deal of fear and 
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discomfort. Jeffrey Epstein then masturbated and instructed Plaintiff to leave the 
room. 
75. 
Knowing that Jeffrey Epstein and his associates had confiscated her 
passport to prevent her from having the ability to leave the Island voluntarily, 
Plaintiff feared for her safety and felt forced into engaging in these sexual acts 
against her will. 
76. 
It was clear by this trip that Jeffrey Epstein was extremely powerful and 
could cause serious harm to Plaintiff if she disobeyed. 
77. 
Jeffrey Epstein learned in 2007 that 
78. 
Plaintiff and Epstein talked numerous times about the fact that Plaintiff 
would only introduce him to her relative if he promised not to engage in any sexual 
conduct with her, to which Jeffrey Epstein agreed. 
79. 
Jeffrey Epstein constantly reminded Plaintiff that he was going to help 
as a way to force Plaintiff to engage in commercial 
sex acts. 
80. 
While Plaintiff was giving sexual massages, Jeffrey Epstein would 
always answer the phone if someone called. Important Business Person I, Important 
Business Person 2, Important Business Person 3, and Important Business Person 4 
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were regular callers and people with whom Jeffrey Epstein would have telephone 
calls during sexual massages. Plaintiff does not want to reveal the identities of these 
individuals out of fear of retaliation. 
81. 
There were also times when Jeffrey Epstein, during sexual massages, 
would be on the verge of ejaculating and would stop in order to make a phone call, 
at times saying that nearing sexual climax evoked certain important thoughts in 
Jeffrey Epstein's mind. Jeffrey Epstein would then take or initiate up to four 
business calls during any particular sexual massage. 
82. 
During these phone calls, Jeffrey Epstein would seem to be advising 
the individuals he called in a very stern, authoritative voice. 
83. 
On numerous calls, Plaintiff heard Jeffrey Epstein using a very angry 
and threatening tone and voice, making it known to the other party, and to Plaintiff, 
that he had the ability to cause serious harm to powerful people and anyone who did 
not cooperate with him. 
84. 
The reasonable impression that Plaintiff had from overhearing his 
phone calls and listening to what he told her was that Jeffrey Epstein controlled very 
powerful and influential people and that disobeying him would cause serious 
repercussions for the disobedient party. 
85. 
Plaintiff spent considerable time with Jeffrey Epstein and overheard 
many conversation. In most, Jeffrey Epstein seemed to be advising other powerful 
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individuals in a business context. However, Important Business Person 1 was 
someone Jeffrey Epstein spoke to frequently, not only about business matters but 
also about what appeared to be intimate personal matters. 
Based on the 
conversations she heard, and the manner and style of voice Epstein used, Plaintiff 
believed for many months that this person was a female. 
86. 
As Jeffrey Epstein realized Plaintiff's vulnerabilities, he began 
controlling her even more to a point where she felt she had no choice but to engage 
in commercial sex acts without putting herself in serious danger. 
87. 
Jeffrey Epstein would demand that Plaintiff massage him and if he went 
to sleep she was told she had to continue to massage him knowing that he would 
become very angry if he stopped. 
88. 
From 2006, when Jeffrey Epstein first forced himself on her 
, until 2012, he forced her to engage in commercial sex with him—sex 
for money—including intercourse, regularly and consistently. At no time did he 
give her a choice not to cooperate. 
89. 
During that time, Jeffrey Epstein controlled nearly every aspect of 
Plaintiff's life from the clothing and jewelry she was permitted to wear to the career 
path she was permitted to followed, to the food she was allowed to consumed. 
90. 
When Jeffrey Epstein went to jail for sex offenses in Florida, he 
maintained contact with Plaintiff. He and employees of Defendant HBRK and 
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Defendant NES and Defendant JEGE caused Plaintiff to be transported to Florida in 
order to engage in commercial sex with Jeffrey Epstein in his Florida residence while 
on so-called "work release" from jail, while he was still wearing his ankle monitor. 
91. 
After Jeffrey Epstein was no longer in "jail" or on "work release" and 
came back to New York, Plaintiff attempted to discontinue seeing Jeffrey Epstein. 
This attempt angered Jeffrey Epstein. 
92. 
There came a time when Plaintiff, on her own, took a trip to Montreal 
and Jeffrey Epstein immediately knew that she was gone from New York and 
summoned her back to his New York Mansion. He told her she was not permitted 
to leave New York without his permission and that she was required at all time to 
remain in New York, on call to service his needs when told.. 
93. 
This "disciplining" of Plaintiff in connection with her Montreal trip 
caused Plaintiff great fear that if she failed to engage in commercial sex on the terms 
and conditions set by Epstein, he or the Corporate Defendants would cause her 
serious hann. 
94. 
Jeffrey Epstein told Plaintiff to move into an apartment in a building he 
owned or controlled at 301 East 66 Street, which Plaintiff did. 
95. 
There it became obvious to her that she was under constant 
surveillance; that Jeffrey Epstein was able to monitor and know what she was doing 
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 
EFTA_00095926 
EFTA01250000