007.pdf

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Extraction Summary

8
People
5
Organizations
5
Locations
3
Events
4
Relationships
7
Quotes

Document Information

Type: Memorandum of law (federal court filing)
File Size: 342 KB
Summary

This document is a legal memorandum filed on November 20, 2019, in the Southern District of New York, supporting a motion for 'Jane Doe 1000' to proceed anonymously in her civil suit against the Estate of Jeffrey Epstein. The plaintiff alleges she was sexually trafficked and abused by Epstein and Ghislaine Maxwell, detailing forced sexual acts and the use of sex toys. The motion argues that anonymity is necessary to protect the plaintiff from severe emotional distress, public scrutiny, and potential retaliation from Maxwell, who was described as being 'at large' at the time of the filing.

People (8)

Name Role Context
Jane Doe 1000 Plaintiff
Victim of Jeffrey Epstein and Ghislaine Maxwell seeking to proceed anonymously in civil lawsuit.
Jeffrey Edward Epstein Deceased/Perpetrator
Deceased financier accused of sex trafficking. The lawsuit is against his estate.
Darren K. Indyke Defendant
Executor of the Estate of Jeffrey Edward Epstein.
Richard D. Kahn Defendant
Executor of the Estate of Jeffrey Edward Epstein.
Ghislaine Maxwell Alleged Perpetrator
Accused of sexually assaulting Jane Doe 1000 and threatening victims; described as 'still alive and at large' at the ...
Joshua I. Schiller Attorney
Counsel for Plaintiff, Boies Schiller Flexner LLP.
David Boies Attorney
Counsel for Plaintiff, Boies Schiller Flexner LLP.
Sigrid McCawley Attorney
Counsel for Plaintiff, Boies Schiller Flexner LLP (Pro Hac Vice Pending).

Timeline (3 events)

2008
Epstein entered into a Non-Prosecution Agreement with the U.S. Attorney for the Southern District of Florida.
Florida
Jeffrey Epstein U.S. Attorney SD FL
2019-07
U.S. Attorney for the Southern District of New York indicted Epstein for federal sex-trafficking crimes.
New York
Jeffrey Epstein U.S. Attorney SDNY
2019-08-10
Death of Jeffrey Epstein in prison.
Prison
Jeffrey Epstein

Relationships (4)

Jane Doe 1000 Victim/Abuser Jeffrey Epstein
Complaint alleges years-long sexual abuse, forced sexual massages, and sex acts.
Jane Doe 1000 Victim/Abuser Ghislaine Maxwell
Complaint alleges Maxwell sexually assaulted Plaintiff and Epstein forced Plaintiff to engage in sex acts with Maxwell.
Darren K. Indyke Executor Jeffrey Epstein
Named as executor of Epstein's estate.
Richard D. Kahn Executor Jeffrey Epstein
Named as executor of Epstein's estate.

Key Quotes (7)

"This lawsuit arises out of Jeffrey Epstein’s years-long sexual abuse of Plaintiff."
Source
007.pdf
Quote #1
"Epstein forced Plaintiff to give him sexual massages in which he ended up forcing her to engage in various sex acts with him."
Source
007.pdf
Quote #2
"He also forced her to let him use sex toys on her, and he forced her to engage in sex acts with Ghislaine Maxwell."
Source
007.pdf
Quote #3
"She also alleges, in graphic detail, that Ghislaine Maxwell sexually assaulted her."
Source
007.pdf
Quote #4
"Maxwell is still alive and at large, and has been known to threaten both the lives and livelihoods of her victims."
Source
007.pdf
Quote #5
"Plaintiff is rightfully afraid of Maxwell and how she might retaliate against Plaintiff for the allegations against Maxwell in the Complaint."
Source
007.pdf
Quote #6
"Epstein’s crimes have been widely publicized, as has his modus operandi of recruiting and sexually abusing young, vulnerable women by offering to pay them for massages turned into unwelcome sexual encounters."
Source
007.pdf
Quote #7

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