001.pdf
505 KB
Extraction Summary
7
People
6
Organizations
8
Locations
3
Events
7
Relationships
3
Quotes
Document Information
Type:
Complaint
File Size:
505 KB
Summary
This document is a legal complaint filed by Juliette Bryant against the executors of Jeffrey Edward Epstein's estate. It details allegations of sexual abuse and trafficking by Epstein, beginning when Bryant was 20 years old, and describes Epstein's extensive sex trafficking network and his previous legal actions and statements regarding his conduct.
People (7)
| Name | Role | Context |
|---|---|---|
| Juliette Bryant | Plaintiff |
Plaintiff in the lawsuit against Epstein's estate, sexually abused by Epstein, citizen and resident of South Africa.
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| Darren K. Indyke | Defendant |
Executor of the Estate of Jeffrey Edward Epstein.
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| Richard D. Kahn | Defendant |
Executor of the Estate of Jeffrey Edward Epstein.
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| Jeffrey Edward Epstein | Deceased Subject of Complaint |
Accused of sexual abuse and trafficking, maintained residences in multiple locations, citizen of the United States do...
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| Kenneth Marra | United States District Judge |
Judge who found that Jeffrey Epstein sexually abused minor girls.
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| Amber Sutherland | Reporter |
Author of the New York Post article 'Billionaire Jeffrey Epstein: I'm a Sex Offender Not a Predator'.
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| James B. Stewart | Reporter |
Author of The New York Times article 'The Day Jeffrey Epstein Told Me He Had Dirt on Powerful People'.
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Organizations (6)
| Name | Type | Context |
|---|---|---|
| UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK |
Court where the complaint was filed.
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| Boies Schiller Flexner LLP |
Attorneys representing Plaintiff Juliette Bryant.
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| Estate of Jeffrey Edward Epstein |
The entity being sued, represented by executors Darren K. Indyke and Richard D. Kahn.
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| U.S. Attorney for the Southern District of Florida |
Party involved in the 2008 non-prosecution agreement with Epstein.
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| New York Post |
Publication that interviewed Epstein in 2011.
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| New York Times |
Publication that interviewed Epstein in 2018.
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Timeline (3 events)
1999-2007
Jeffrey Epstein sexually abused more than 30 minor girls at his mansion in Palm Beach, Florida, and elsewhere.
Palm Beach, Florida, and overseas
Jeffrey Epstein
minor girls
2008
Epstein received a minimal charge, pleading guilty to a single Florida state law charge of procuring a minor for prostitution and a non-prosecution agreement (NPA) with the U.S. Attorney for the Southern District of Florida.
Southern District of Florida
Jeffrey Epstein
U.S. Attorney for the Southern District of Florida
2019-08-29
Termination of a criminal action against Epstein related to sex trafficking enterprise.
N/A
Jeffrey Epstein
Locations (8)
| Location | Context |
|---|---|
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Juliette Bryant's country of citizenship and residence, where she was recruited.
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Where Epstein trafficked Plaintiff and maintained residences.
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Where Epstein trafficked Plaintiff and maintained a residence.
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Location of Epstein's mansion where sexual abuse occurred.
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Location of Epstein's residences and where he was seen after jail stint.
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Location of Epstein's residences.
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Location of Epstein's residences and his domicile at time of death.
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Jurisdiction where the complaint is filed and where Epstein maintained a residence.
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Relationships (7)
Epstein sexually abused Plaintiff and trafficked her to his homes.
Darren K. Indyke is an appointed executor of the Estate of Jeffrey E. Epstein.
Richard D. Kahn is an appointed executor of the Estate of Jeffrey E. Epstein.
Epstein sexually abused more than 30 minor girls and trafficked hundreds of young females.
Epstein was dining with a former high U.S. Government official when Juliette Bryant met him.
Epstein was dining with a famous actor when Juliette Bryant met him.
Epstein was dining with a well-known comedian when Juliette Bryant met him.
Key Quotes (3)
"“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
001.pdf
Quote #1
"“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
001.pdf
Quote #2
"“that criminalizing sex with teenage girls was a cultural aberration and that at times in history it was perfectly acceptable.”"Source
001.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (8,129 characters)
Case 1:19-cv-10479-ALC-DCF Document 1 Filed 11/14/19 Page 1 of 16
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
FOR THE SOUTHERN DISTRICT OF NEW YORK
JULIETTE BRYANT,
Plaintiff,
v.
CASENO:
DARREN K. INDYKE and RICHARD D. KAHN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,
Defendants.
COMPLAINT
BOIES SCHILLER FLEXNER LLP
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Case 1:19-cv-10479-ALC-DCF Document 1 Filed 11/14/19 Page 2 of 16
Plaintiff Juliette Bryant, 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:
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 Jeffrey Epstein's sexual abuse of Plaintiff beginning when Plaintiff
was 20 years old that lasted years and included trafficking Plaintiff to each of his homes in the
United States and Paris.
was 20 years old that lasted years and included trafficking Plaintiff to each of his homes in the
United States and Paris.
2. Plaintiff was a young girl living in South Africa with hopes of becoming a model when
she was approached by one of Epstein's recruiters about a prospective modeling opportunity in
the United States and invited to a restaurant to meet Epstein, who was dining with a former high
U.S. Government official, a famous actor, and a well-known comedian. What appeared on the
outside as a legitimate opportunity to break into the modeling business in the United States
turned into years of horrific abuse and manipulation at the hands of Jeffrey Epstein.
she was approached by one of Epstein's recruiters about a prospective modeling opportunity in
the United States and invited to a restaurant to meet Epstein, who was dining with a former high
U.S. Government official, a famous actor, and a well-known comedian. What appeared on the
outside as a legitimate opportunity to break into the modeling business in the United States
turned into years of horrific abuse and manipulation at the hands of Jeffrey Epstein.
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.
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
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
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
2
Case 1:19-cv-10479-ALC-DCF Document 1 Filed 11/14/19 Page 3 of 16
minors not only for his own sexual gratification, but also for the sexual gratification of others.”
Doe V 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.
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 young females a day for his sexual pleasure.
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 young females 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.
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.
continue operating his sex trafficking enterprise with liberty.
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:
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
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Case 1:19-cv-10479-ALC-DCF Document 1 Filed 11/14/19 Page 4 of 16
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),
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),
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 20 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.
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.
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.
13. This action has been timely filed pursuant to N.Y. C.P.L.R. § 213-C, which provides
that a plaintiff shall have 20 years to file civil claims “for physical, psychological or other injury
or condition suffered by such person as a result of conduct which would constitute rape in the
or condition suffered by such person as a result of conduct which would constitute rape in the
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Case 1:19-cv-10479-ALC-DCF Document 1 Filed 11/14/19 Page 5 of 16
first degree as defined in section 130.35 of the penal law.” Epstein raped Plaintiff within 20
years of filing this Complaint.
years of filing this Complaint.
14. Any statute of limitations applicable to Plaintiff's claims, if any, is tolled due to the
continuous and active deception, duress, threats of retaliation, and other forms of misconduct that
Epstein and his co-conspirators used to silence his 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.
Epstein and his co-conspirators used to silence his 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.
15. Defendants are equitably estopped from asserting a statute of limitations defense.
Allowing Defendants to do so would be unjust. Epstein and his co-conspirators 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.
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
16. Plaintiff Juliette Bryant is a citizen and resident of South Africa.
17. Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the Estate
of Jeffrey E. Epstein.
18. Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the Estate
of Jeffrey E. Epstein.
JURISDICTION AND VENUE
19. 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
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