022.pdf
429 KB
Extraction Summary
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People
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Organizations
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Quotes
Document Information
Type:
Legal complaint
File Size:
429 KB
Summary
This is an amended complaint filed by Maria Farmer against the executors of Jeffrey Edward Epstein's estate. Farmer alleges that Epstein sexually assaulted and trafficked her, and that his actions were part of a larger sex trafficking network. The complaint details Epstein's history of sexual abuse, his lenient 2008 plea deal, and the intimidation tactics used to silence victims.
People (9)
Organizations (4)
Timeline (4 events)
Epstein's sexual assault of Plaintiff
Epstein's sex trafficking scheme
2008 plea deal and non-prosecution agreement
Epstein's death
Locations (9)
Relationships (10)
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Key Quotes (3)
""Billionaire pervert Jeffrey Epstein is back in New York City - and making wisecracks about his just-ended jail stint for having sex with an underage girl. 'I am not a sexual predator, I'm an offender,' the financier told The Post yesterday. 'It's the difference between a murderer and a person who steals a bagel,' said Epstein.""Source
022.pdf
Quote #1
""that criminalizing sex with teenage girls was a cultural aberration and that at times in history it was perfectly acceptable.""Source
022.pdf
Quote #2
""From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 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.""Source
022.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (8,161 characters)
Case 1:19-cv-10474-NRB Document 22 Filed 03/09/20 Page 1 of 17
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
FOR THE SOUTHERN DISTRICT OF NEW YORK
MARIA FARMER,
Plaintiff,
CASE NO: 19-cv-10474-NRB
V.
DARREN K. INDYKE and RICHARD D. KAHN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,
DARREN K. INDYKE and RICHARD D. KAHN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,
Defendants.
AMENDED COMPLAINT
BOIES SCHILLER FLEXNER LLP
Case 1:19-cv-10474-NRB Document 22 Filed 03/09/20 Page 2 of 17
Plaintiff Maria Farmer, by her attorneys Boies Schiller Flexner LLP, for her Complaint
against Defendants, Darren K. Indyke and Richard D. Kahn in their capacities as the executors of
the Estate of Jeffrey Edward Epstein ("Epstein"), avers upon personal knowledge as to her own
acts and status and upon information and belief and to all other matters as follows:
NATURE OF THE ACTION
1.
This suit arises out of Jeffery Epstein's sexual assault of Plaintiff.
2.
Maria Farmer was sexually trafficked by Epstein and a co-conspirator as part of his
organized ring of procuring young females for sex. As an aspiring artist, Maria believed that
Epstein's connections to the art world would help further her career when he offered her a
position to procure art for him. Maria began working for Epstein in his Manhattan mansion,
performing a variety of tasks including procuring art and manning the guest check in at the front
door of the home. Maria was employed by Epstein in the state of New York and permanently
resided in New York at the time. During the course of her employment for Epstein, Epstein and
Ghislaine Maxwell flew Maria to Ohio as part of her employment duties and violently sexually
assaulted her while she was working on an art project at Epstein's guest house on Leslie
Wexner's Ohio estate. Epstein and Maxwell then threatened to ruin her career and her life if she
told anyone about the assault.
3.
Epstein's trafficking scheme involved recruiting young females by making false promises
and using his wealth, power and threats to intimidate the females into submission to his
demands. This same pattern was repeated numerous times with numerous young women.
4.
As United States District Judge Kenneth Marra found, "From between about 1999 and
2007, Jeffrey Epstein sexually abused more than 30 minor girls . . . at his mansion in Palm Beach
Florida, and elsewhere in the United States and overseas. ... In addition to his own sexual abuse
2
Case 1:19-cv-10474-NRB Document 22 Filed 03/09/20 Page 3 of 17
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."
Doe 1 v. United States, 359 F. Supp. 3d 1201, 1204 (S.D. Fla. 2019) (internal citations omitted).
5.
Epstein organized this sex trafficking network to obtain hundreds of young females for
himself for sex, and also lent these females out to other powerful and wealthy individuals to be
sexually abused.
6.
Epstein conspired with others and hired staff to maintain and keep secret this network of
sexual abuse for years, which sprawled throughout Epstein's residences in New York, Florida,
New Mexico, the United States Virgin Islands, and Paris. Epstein's preference was to have three
different girls a day for his sexual pleasure.
7.
Despite his significant criminal activity, in 2008 Epstein received a shockingly minimal
charge pleading guilty to a single Florida state law charge of procuring a minor for prostitution
and a non-prosecution agreement (a "NPA") with the U.S. Attorney for the Southern District of
Florida. Unknown to the public and the victims at the time, Epstein's lawyers were pressuring
the Government to commit to the NPA without informing the victims. Epstein's multiple
victims were kept in the dark and told to be "patient" while Epstein's lawyers worked to protect
him and other potential co-conspirators from prosecution. Epstein served one year in jail, but
was afforded the privilege of being able to leave the jail to go to work for twelve hours per day,
six days per week.
8.
The NPA allowed Epstein to escape proportionate punishment for his actions and to
continue operating his sex trafficking enterprise with liberty.
3
Case 1:19-cv-10474-NRB Document 22 Filed 03/09/20 Page 4 of 17
9.
A few years later, Epstein flippantly referred to his sexual abuse of multiple minors, and
the slap on the wrist he had received for it, in a 2011 interview with the New York Post:
"Billionaire pervert Jeffrey Epstein is back in New York City - and making wisecracks about his
just-ended jail stint for having sex with an underage girl. 'I am not a sexual predator, I'm an
offender,' the financier told The Post yesterday. 'It's the difference between a murderer and a
person who steals a bagel,' said Epstein." Amber Sutherland, Billionaire Jeffrey Epstein: I'm a
Sex Offender Not a Predator, N.Y. Post (Feb. 25, 2011),
https://nypost.com/2011/02/25/billionaire-jeffrey-epstein-im-a-sex-offender-not-a-predator/.
10.
In August 2018, just one year before his death, Epstein told a New York Times reporter
"that criminalizing sex with teenage girls was a cultural aberration and that at times in history it
was perfectly acceptable." James B. Stewart, The Day Jeffrey Epstein Told Me He Had Dirt on
Powerful People, N.Y. Times (Aug. 12, 2019),
https://www.nytimes.com/2019/08/12/business/jeffrey-epstein-interview.html.
11.
When Plaintiff was 26 years old, Epstein added her to his long list of victims by
committing sexual assault and battery against her. As such, Epstein is responsible for battery
and intentional infliction of emotional distress pursuant to New York common law. The damage
to Plaintiff has been severe and lasting.
12.
This action has been timely filed pursuant to N.Y. C.P.L.R. § 215(8)(a), which provides
that a plaintiff shall have at least one year from the termination of a criminal action against the
same defendant to commence an action with respect to the event or occurrence from which the
criminal action arose. A criminal action against Epstein with respect to the same sex trafficking
enterprise from which Plaintiff's claims arise was terminated on August 29, 2019.
4
Case 1:19-cv-10474-NRB Document 22 Filed 03/09/20 Page 5 of 17
13.
Any statute of limitations applicable to Plaintiff's claims, if any, is tolled due to the
continuous and active deception, duress, threats of retaliation, threats of physical harm including
death threats, and other forms of misconduct that Epstein and his co-conspirators used to silence
many victims, including Plaintiff. Epstein's actions deprived Plaintiff of the opportunity to
commence this lawsuit before his death. Until his death, Plaintiff feared that Epstein and his co-
conspirators would harm her or her family, or ruin her life, if she came forward.
14.
Defendants are equitably estopped from asserting a statute of limitations defense.
Allowing Defendants to do so would be unjust. Epstein and his employees intimidated each of
his victims into silence by threatening their lives and their livelihoods. They therefore prevented
Plaintiff from commencing this lawsuit before his death. By using threats, along with his wealth
and power, Epstein was able to escape punishment for his intolerable and brutal crimes against
countless young women and underage girls for the duration of his life.
PARTIES
15.
Plaintiff Maria Farmer is a citizen of Kentucky. At the time of her assault, Maria was
employed by Epstein in New York and permanently resided in New York.
16.
Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the Estate
of Jeffrey E. Epstein.
17.
Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the Estate
of Jeffrey E. Epstein.
JURISDICTION AND VENUE
18.
Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at
the time of his death. Jeffrey Epstein maintained a residence in the Southern District of New
5
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