043-02.pdf

 
1
 
 
 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
JANE DOE, 
 
Plaintiff, 
 
v. 
 
DARREN K. INDYKE and RICHARD D. 
KAHN, in their capacities as executors of the 
ESTATE OF JEFFREY E. EPSTEIN, 
GHISLAINE MAXWELL, an individual, 
 
Defendants. 
 
  
 
 
 
 
Case No. 1:20-cv-00484-JGK 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
DECLARATION OF ROBERT S. GLASSMAN  
ROBERT GLASSMAN, pursuant to 28 U.S.C. § 1746, declares under penalty of perjury 
that the following is true and correct:  
1. 
I am an attorney at the law firm Panish, Shea & Boyle LLP and am admitted before 
this Court.  I represent Plaintiff Jane Doe in this matter. 
2. 
I respectfully submit this Declaration in support of Plaintiff's Motion to Approve 
Alternate Service Pursuant to Federal Rule of Civil Procedure 4(e)(l). 
3. 
Attached hereto as Exhibit 1 are true and correct copies of declarations provided 
by process servers documenting five (5) unsuccessful attempts at service on Maxwell at addresses 
associated with her in both Florida and New York: 116 E. 65th Street, New York, NY 10065; 457 
Madison Avenue, 4th Floor, New York, NY 10022; 1000 Venetian Way, APT 801, Miami Beach, 
FL 33139; 358 El Brillo Way, Palm Beach, FL 33480; 20 E 66th ST, New York, NY 10065.  My 
office conducted extensive Internet searches on Maxwell's whereabouts to find the addresses at 
which service was attempted.   
4. 
Attached hereto as Exhibit 2 is a true and correct copy of an email that my office 
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 1 of 33

 
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sent to gmax@ellmax.com on April 24, 2020 which attached a copy of the Complaint in this 
matter (ECF No. 9) and the summons as to Ghislaine Maxwell (ECF No. 17). We did not receive a 
response to that email, nor did we receive any indication that the email had not been delivered.  
We also sent the same email to several other email addresses associated with Maxwell (namely, 
hello@theterramarproject.org; gmaxwell@theterramarproject.org; 
maxwellg@theterramarproject.org; ghislaine@theterramarproject.org; 
gmax@theterramarproject.org; maxwell@theterramarproject.org; 
ghislaine.maxwell@theterramarproject.org), but received no response. 
5. 
Attached hereto as Exhibit 3 is a true and correct copy of the April 2, 2020 letter 
that my office sent to Maxwell 's attorney Laura A. Menninger of Haddon, Morgan and Foreman, 
P.C.  Enclosed in the letter is a copy of the Complaint in this matter (ECF No. 9) and the summons 
as to Ghislaine Maxwell (ECF No. 17).   
6. 
Attached hereto as Exhibit 4 is a true and correct copy of a letter from Maxwell's 
attorney Laura A. Menninger dated April 13, 2020 in which she indicated she is not authorized to 
accept service on behalf of Maxwell.   
7. 
Despite these enormous efforts, we have been unable to effectuate service on 
Maxwell. 
8. 
Attached hereto as Exhibit 5 is a true and correct copy of the order issued by this 
Court in Ransome v. Epstein, 2018 WL 637421, at *1 (S.D.N.Y. Jan. 30, 2018), in which the Court 
found service upon Maxwell to be impracticable and approved Plaintiff serving the complaint and 
summons on Maxwell's attorneys as Haddon Morgan as an appropriate mode of alternative 
service.   
9. 
In the Farmer v. Indyke, et al., 1:19-cv-10475-LGS-DCF (S.D.N.Y.), which is 
related to this case, the court granted alternate service in a text-only order issued on February 12, 
2020 which appears as ECF No. 27 as follows: "ORDER granting 18 Motion to Approve Alternate 
Service on Defendant Ghislaine Maxwell ("Maxwell...

 
3
 
 
would be impracticable. See Ransome v. Epstein, No. 17cv616 (JGK), 2018 WL 637421, at *1 
(S.D.N.Y. Jan. 30, 2018). This Court further finds that Plaintiff's provision of a copy of the 
Summons and Complaint by email to Maxwell's counsel of record in another action before the 
Court (Giuffre v. Maxwell, 15cv7433 (LAP)(S.D.N.Y.)), as well as to an email address publicly 
associated with Maxwell (see Plaintiff's Memorandum (Dkt. 19), at 3), was reasonably calculated 
to place Maxwell on notice of this suit and to constitute sufficient service under the circumstances. 
No later than 2/14/20, Plaintiff is directed to serve Maxwell with a copy of this Text Order by the 
same means (i.e., by email to Maxwell's counsel of record in the Giuffre case and to the email 
address publicly associated with Maxwell), and to file proof of such service on the Docket of this 
action. Maxwell may then have until 3/6/20 to move, answer, or otherwise respond to the 
Complaint. (HEREBY ORDERED by Magistrate Judge Debra Freeman)(Text Only Order) 
(Freeman, Debra) (Entered: 02/12/2020)." 
 
 
 
 
 
 
 
 
Respectfully submitted, 
 
 
Dated: May 27, 2020  
 
 
 
_____________________________  
 
 
Los Angeles, California 
 
 
Robert Glassman  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 3 of 33
~-zL 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EXHIBIT 1 
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 4 of 33

Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 5 of 33
ATTORNEY OR PARTY WITHOUT ATTORNEY (Norno, Slato Bar numbor, ond address) 
FOR COURT USE ONLY 
... Robert S Glassman.Esq SBN: Bar No.269816 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Blvd Suite 700 GLORIA CELL# 213-444-8132 Los Angeles, CA 90025 
TaEPHONE NO.: (310) 4n-1700 
FAX NO.: (310) 4n-1699 
E-MAIL ADDRESS (Optional): 
ATTORNEY FOR (Namol: 
UNITED STATED DISTRICT·COURT SOUTHERN DISTRICT OF NEW YORK 
STREET ADDRESS: 40 FOLEY SQUARE ROOM 435 
CITY AND ZIP COOE: NEW YORK, NY 10007 
REfERENCE NUMBER: 
HEARING DATE: 
DOE/IN DYKE 
Plaintiff(s): JANE DOE 
Defendant(s): DARREN K. INDYKE, et al. 
CASE NUMBER 
DECLARATION OF DILIGENCE 
1 :20-cv-00484-JG 
I received the within assignment for filing and/or service on April 24, 2020 and that after due and diligent effort I have 
not been able to serve said person.I attempted service on this servee on the following dates and times: 
Servee: 
Ghislaine Maxwell 
Documents: COMPLAINT FOR DAMAGES;SUMMONS IN A CIVIL ACTION; 
Address: 457 Madison Avenue 4th Floor 
New York, NY 10022 
As enumerated below: 
4/24/2020 - 7:40 PM 
457 Madison Avenue, 4th Floor 
Business 
New York, NY 10022 
Bad address. This is a multi dwelling apartment complex under the name of Lotte New York. Spoke with Jerry Parker, Security 
Supervisor for the building who informed me that the whole building is empty at this lime due to the corona virus. No one is 
currently residing here. No further information provided nor guard would confirm nor deny if subject resides here. 
County: 
Registration No.: 
Nationwide Legal, LLC 
1609 James M Wood Blvd. 
Los Angeles, CA 90015 
I declare under penalty of perjury under the laws of the United 
States of America that I am over the age o 18, 
t a party to this 
action and that the foregoing is tr: e 
. This 
declaration was executed on 4/ 
DECLARATION OF DILIGENCE 
Order#: LA51503/D11Fonnalmdl 

Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 6 of 33
ATTORNEY OR PARlY WITHOUT ATTORNEY (Namo, Slato Bar numl>6'. and addrass/ 
FOR COURT USE ONLY 
_ Robert S Glassman.Esq SBN: Bar No.269816 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Blvd Suite 700 GLORIA CELL# 213-444-8132 Los Angeles, CA 90025 
TELEPHONEN0.:(310) 477-1700 
FAX NO.: (310) 477-1699 
E-MAIL ADDRESS (Optional/: 
ATTORNEY FOR (Namo/: 
UNITED STATED DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK 
STREET ADDRESS: 40 FOLEY SQUARE ROOM 435 
CITY AND ZIP CODE: NEW YORK, NY 10007 
REFERENCE NUMBER 
HEARING DATE: 
DOE/INDYKE 
Plaintiff(s): JANE DOE 
Defendant(s): DARREN K. INDYKE, et al. 
CASE NUMBER: 
DECLARATION OF DILIGENCE 
1 :20-cv-00484-JG 
I received the within assignment for filing and/or service on April 24, 2020 and lhat after due and diligent effort I have 
not been able to serve said person.I attempted service on this servee on the following dates and times: 
Servee: Ghislaine Maxwell 
Documents: COMPLAINT FOR DAMAGES;SUMMONS IN A CIVIL ACTION; 
Address: 457 Madison Avenue 4th Floor 
New York, NY 10022 
As enumerated below: 
N 
4124/2020 - 7:17 PM 
116 E. 65th Street 
Home 
New York, NY 10065 
Bad address. This is a 4/5 story brown stone building. Doors locked. No one seen or heard inside the buliding. All shades are 
drawn shut, there is not a single light on in any of the floors nor on in any of the units. The whole builidiing is dark. There a 
2019 construction permit posted on the door from the city of New York for work to be performed there. Could not establish 
contact with anyone at this address. 
4/24/2020 - 7:29 PM 
Home 
20E66TH ST 
New York, NY 10065 
Bad address. This is a multi dwelling apartment complex. No names listed on the directory. Spoke witth buildiing 
superintendant by the name of Cesar Abreu. who stated that subject, Ghislaine Maxwell is not known to him, nor is she a 
tenant there according to his list of tenants. No further Information provided...

Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 7 of 33
Index Number: 1 :20-CV-00484 
Plaintiff: 
JANE DOE 
vs. 
Defendants: 
DARREN K. INDYKE and RICHARD D. 
AFFIDAVIT OF NON-SERVICE 
UNITED STATES DISTRICT COURT 
District of New York 
KAHN, in their capacities as executors of the 
ESTATE OF JEFFREY E. EPSTEIN, 
GHISLAINE MAXWELL, an individual 
For: 
Kevin Boyle, Esquire 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Blvd. 
Suite 700 
Los Angeles, CA 90025 
Date Filed: 1/28/2020 
Received by U Got Served, LLC on the 24th day of April, 2020 at 12:17 pm to be served on GHISLAINE MAXWELL, 358 EL 
BRILLO WAY, PALM BEACH, FL 33480. 
I, Sandra Harris, being duly sworn, depose and say that on the 25th day of April, 2020 at 9:58 am, I: 
NON-SERVED the SUMMONS IN A CIVIL ACTION AND COMPLAINT FOR DAMAGES, DEMAND FOR JURY TRIAL for 
the reason that I failed to find GHISLAINE MAXWELL or any information to allow further search. Read the comments below 
for further details. 
Additional Information pertaining to this Service: 
4/24/2020 3:11 pm Service was attempted at 358 EL BRILLO WAY, PALM BEACH, FL 33480; the property has a gate with a 
call box; no one answered. I was unable to gain access to the property. The windows of the property have shutters. 
4/25/2020 9:58 am Attempted service at 358 EL BRILLO WAY, PALM BEACH, FL 33480; The home caretaker came to the 
house while I was parked on front of the property. He stated that the Defendant does not live at this address. He has been 
living here for the last 3 years. I also spoke with the maintenance man at the house across the street; He stated that he has 
not seen the Defendant at the property. 

Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 8 of 33
✓ 
AFFIDAVIT OF NON-SERVICE For 1 :20-CV-00484 
I certify that I am over the age of 18, have no interest in the above action, and I am a Certified Process Server, in good standing, 
in the Judicial Circuit in which the process was served. Pursuant to F.S. 95.525 "Under penalties of perjury", I declare that I have 
read the foregoing Return of Service and that the facts stated in it are true and correct" Notary not required as per FS 92.525. 
/~~~~~\ 
VICTOR R. GARCIA 
;•: 
:•} MY COMMISSION# GG 968335 
0
~;~• ... 0;'{/ 
EXPIRES: Marcil 11, 2024 
·•.~f.f.~••· 
Bonded Thru Notary Public Underwriters 
State of l=1or: ck, 
County of (Ja..l M.. Gc.a.c.V\. 
Sworn and Subscribed before me on this 2.8 
day 
of r--\r I I l 
___ 
_,20.2.D.By 
Personally known_ or Produce identification~ 
Type of identification . 
produced b1rt11c:.c hc.<::.-aA.§: 
NOTARY P~LIC () 
. 
NAME V1 
r 
o.r-C.-1A.. 
Sandra Harris 
#1682 
U Got Served, LLC 
1279 W. Palmetto Park Road 
Unit 273938 
Boca Raton, FL 33427 
(561) 361-7111 
Our Job Serial Number: AOA-2020000803 
Ref: Kevin Boyle, Esquire 
My Commission Expires 
Vv\AfC..k 
LI l 2..C, ._(~. 
Copyright C 1992-2020 Database Services, Inc. - Process Serve~s Toolbox V8.1c 

Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 9 of 33
Index Number: 1 :20-CV-00484 
Plaintiff: 
JANE DOE 
vs. 
Defendants: 
DARREN K. INDYKE and RICHARD D. 
AFFIDAVIT OF NON-SERVICE 
UNITED STATES DISTRICT COURT 
District of New York 
KAHN, in their capacities as executors of the 
ESTATE OF JEFFREY E. EPSTEIN, 
GHISLAINE MAXWELL, an individual 
For: 
Kevin Boyle, Esquire 
PANISH SHEA & BOYLE LLP 
1111.1 Santa Monica Blvd. 
Suite 700 
Los Angeles, CA 90025 
Date Filed: 1/28/2020 
Received by U Got Served, LLC on the 24th day of April, 2020 at 12:17 pm to be seNed on GHISLAINE MAXWELL, 1000 
VENETIAN WAY, APT 801, MIAMI BEACH, FL 33139. 
I, Natasha Caplan, being duly sworn, depose and say that on the 24th day of April, 2020 at 8:00 pm, I: 
NON-SERVED the SUMMONS IN A CIVIL ACTION AND COMPLAINT FOR DAMAGES, DEMAND FOR JURY TRIAL for 
the reason that I failed to find GHISLAINE MAXWELL or any information to allow further search. Read the comments below 
for further details. 
Additional Information pertaining to this Service: 
4/24/2020 8:00 pm Service was attempted at 1000 VENETIAN WAY, APT 801, MIAMI BEACH, FL 33139; I knocked on the 
door and no one answered. I heard music and noise inside the apartment. I spoke with the security guard; he did not know who 
was GHISLAINE MAXWELL. I showed him a picture of her and he stated that he has not seen her. I also spoke with the 
· 
~mployees at ~he front desk who stated that they have not seen her. They also did not recognize her from the picture. She is not 
listed as a resident. The Keffler Family is listed a living at that unit. 

Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 10 of 33
AFFIDAVIT OF NON-SERVICE For 1:20-CV-00484 
I certify that I am over the age of 18, have no interest in the above action, and I am a Certified Process Server, in good standing, 
in the Judicial Circuit in which the process was served. Pursuant to F.S. 95.525 "Under penalties of perjury", I declare that I have 
read the foregoing Return of Service and that the facts stated in it are true and correct" Notary not required as per FS 92.525. 
S".'te o; t1a::Jfl 
County of 
'tl1t\tfh ~ 
/X} 
Sworn and Subscribed before me on this..L...4-day 
of I 
~N\Of. ~~/)0 
· 
Personally known _:~)produce identification>< 
Type of identification 
produced _________ _ 
Stephanie Nin 
NOTAR't,,P~,,C • 
\\ ' · n 
NAME .::z~AoiG ~ 
! 
q._ NOTARY PUBLIC 
~STATE OF FLORIDA 
.,,, 
,-· ~ Comm# GG299147 
·.r,,No , r,.fb· Expires 2/6/2023 
~ 
CPS #2327 
U Got Served, LLC 
1279 W. Palmetto Park Road 
Unit 273938 
Boca Raton, FL 33427 
(561) 361-7111 
Our Job Serial Number: AOA-2020000802 
Ref: Kevin Boyle, Esquire 
My Commission ExpirfG / 
2 t; 20'2?,, 
Copyright© 1992-2020 Database Services, Inc. - Process Server's Toolbox VB.1 c 

Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 11 of 33
Case 1 :20-cv-00484-JGK-DCF Document 17 Filed 01/28/20 Page 2 of 2 
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2) 
Civil Action No. 
PROOF OF SERVICE 
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (I)) 
This summons for (name of individual and title, if any) 
GHISLAINE MAXWELL 
-
-
-
- ---
- ----
- ----------
was received by me on (date) 
4/24/2020 
□ I personally served the summons on the individual at (place) 
on (date) 
; or 
□ I left the summons at the individual's residence or usual place of abode with (name) 
, a person of suitable age and discretion who resides there, 
Date: 
----------
- ---
-
-
on (date) 
, and mailed a copy to the individual's last known address; or 
o I served the summons on (name of individual) 
designated by law to accept service of process on behalf of (name of organization) 
on (date) 
X... I returned the summons unexecuted - I attempted service on 4/24/2020 at 8:00 
p.m. at 1000 VENETIAN WAY, APT 801, MIAMI BEACH, FL 33139; I knocked 
on the door and no one answered. I heard music and noise inside the apartment. 1 
spoke with the security guard; he did not know who was GHISLAINE MAXWELL. 
I showed him a picture of her and he stated that he has not seen her. 
I also spoke 
with the employees at the front desk who stated that they have not seen her. They 
also did not recognize her from the picture. She is not listed as a resident. The 
Keffler Family is listed a living at that unit. 
D Other (specify) . 
My fees are $ ______ for travel and $ _______ for services, for a total of$ 
I declare under penalty of perjury that this information is true. 
NATASHA CAPLAN, CPS #2327 
Printed name and title 
; or 
UGotServed, LLC, 1279 W Palmetto Park Rd., 
#273938 Boca Raton Fl 33427 
Server's address 
, who is 
0.00 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EXHIBIT 2 
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 12 of 33

1
Keilah Betts
From:
Keilah Betts
Sent:
Friday, April 24, 2020 8:49 AM
To:
'gmax@ellmax.com'
Cc:
Robert Glassman; Nathan Werksman; Claudia Lomeli
Subject:
DOE, Jane v. The Estate of Jeffrey Epstein et al.: 
Attachments:
SUMMONS.pdf; COMPLAINT.pdf
Ms. Maxwell, 
 
Please be advised that this office represents a victim of Jeffrey Epstein, Jane Doe, who filed a lawsuit against you on 
January 22, 2020 in the Southern District of New York (Docket No. 20‐cv‐00484). I am attaching Jane Doe’s summons and 
complaint to this email. We sent these documents to your attorney already and requested that she accept service on 
your behalf. Your attorney refused to accept service. Please confirm receipt of this email. 
 
Thank you, 
 
Keilah Betts 
Panish Shea & Boyle LLP  
11111 Santa Monica Boulevard, Suite 700  
Los Angeles, CA 90025  
Tel: (310) 477-1700  
Fax: (310) 477-1699  
Email: betts@psblaw.com 
Web: www.psblaw.com 
 
CONFIDENTIALITY NOTICE: 
This e‐mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, 
distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the 
recipient), please contact the sender by reply e‐mail or telephone, and delete all copies of this message.  
 
If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the 
full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have 
signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for 
your case or potential case. 
 
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 13 of 33

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EXHIBIT 3 
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 14 of 33

 
 
11111 Santa Monica Boulevard, Suite 700 • Los Angeles, California 90025 • 310.477.1700 phone • 310.477.1699 fax • www.psblaw.com
April 2, 2020 
VIA U.S. MAIL, FACSIMILE & EMAIL 
 
Laura A. Menninger  
Haddon, Morgan and Foreman, P.C 
150 East 10th Avenue 
Denver, Colorado 80203 
Fax: (303) 832-2628  
Email: lmenninger@hmflaw.com 
 
Re: 
Jane Doe v. Darren Indyke, et al., 20-cv-00484 (JGK) (DCF)  
 
Dear Ms. Menninger:     
Please be advised that we represent a woman identified as plaintiff Jane Doe in the 
above-referenced litigation filed in the Southern District of New York.  It is our understanding 
that you represent Ghislaine Maxwell in a related action entitled Farmer v. Darren Indyke, et al. 
(19-cv-10475-LGS-DCF) and appeared as counsel of record for Ms. Maxwell in that action on 
March 4, 2020.  Ms. Maxwell has also been named a defendant in our case.       
Pursuant to the Court’s order in Ransome v. Epstein, et al., 17-cv-616 (JGK), ECF No. 
107, and the Court’s order in Farmer, ECF No. 27, the delivery of this letter and its attachments 
(including plaintiff's complaint and summons) to you and your law firm, as counsel of record for 
defendant Maxwell, shall constitute service of the complaint and summons as to defendant 
Ghislaine Maxwell.   
Considering the well-documented impracticability of other methods of service on 
defendant Maxwell and the fact that you and your firm are actively representing Ms. Maxwell in 
other pending related litigation before the same court, this method of service is reasonably 
calculated to provide defendant Maxwell with notice of this lawsuit and an opportunity to 
respond.     
Accordingly, we are requesting that you agree to appear on behalf of Ms. Maxwell and 
respond to the complaint within twenty-one (21) days in lieu of us seeking another court order 
granting permission to effectuate service on Ms. Maxwell by alternative service pursuant to 
FRCP 4(e)(1).  If Ms. Maxwell chooses not to appear, we may pursue an...

Laura A. Menninger 
Haddon, Morgan and Foreman, P.C. 
April 2, 2020 
Page 2 
 
 
 
 
Very truly yours, 
 
PANISH SHEA & BOYLE  
 
 
Robert S. Glassman 
Encls. 
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 16 of 33
PANISH 
SHEA& 
BOYLE 
LLP 

AO 440 (Rev. 06/12)  Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________ 
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v.
Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure.  The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. 
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
DARREN K. INDYKE and RICHARD D. KAHN, in their
capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, et al.
JANE DOE, 
SOUTHERN DISTRICT OF NEW YORK
Ghislaine Maxwell 
116 East 65th Street, 
New York, NY 10065
Kevin R. Boyle
Robert S. Glassman
Panish Shea & Boyle LLP
11111 Santa Monica, Blvd., Suite 700
Los Angeles, CA 90025
1:20-cv-00484
01/28/2020
Case 1:20-cv-00484-JGK-DCF   Document 17   Filed 01/28/20   Page 1 of 2
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 17 of 33

AO 440 (Rev. 06/12)  Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date)
.
u I personally served the summons on the individual at (place)
on (date)
; or
u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date)
, and mailed a copy to the individual’s last known address; or
u I served the summons on (name of individual)
, who is
 designated by law to accept service of process on behalf of (name of organization)
on (date)
; or
u I returned the summons unexecuted because
; or
u Other (specify):
.
My fees are $
for travel and $
for services, for a total of $
.
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
0.00
Case 1:20-cv-00484-JGK-DCF   Document 17   Filed 01/28/20   Page 2 of 2
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 18 of 33

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1
COMPLAINT FOR DAMAGES 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
JANE DOE, 
Plaintiff, 
v. 
DARREN K. INDYKE and RICHARD D. 
KAHN, in their capacities as executors of the 
ESTATE OF JEFFREY E. EPSTEIN, 
GHISLAINE MAXWELL, an individual, 
Defendants. 
Case No. _____________ 
COMPLAINT FOR DAMAGES 
DEMAND FOR JURY TRIAL 
Plaintiff Jane Doe ("Doe" or "Plaintiff") alleges as follows: 
INTRODUCTION 
1.
This case arises out of years of sexual abuse and exploitation of a young girl by
notorious pedophile and convicted sex offender Jeffrey Epstein ("Epstein").  It all started in 1994 
when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a 
summer camp in Michigan.  Jane Doe was their first known victim and was subsequently abused 
by Epstein and Maxwell for years as a young girl, suffering unimaginable physical and 
psychological trauma and distress.  Despite that, Jane Doe has persevered and survived to tell her 
story, to hold her perpetrators accountable and to seek justice for the atrocities committed against 
her.            
2.
Throughout his life, Epstein systematically perpetrated acts of molestation,
exploitation, assault and rape on hundreds of young girls.  Epstein's system of abuse was 
facilitated in large part by his co-conspirator and accomplice, Maxwell, who helped supply him 
with a steady stream of young and vulnerable girls—many of whom were fatherless, like Jane 
Doe, and came from struggling families.   
1:20-cv-00484
Case 1:20-cv-00484-JGK   Document 9   Filed 01/22/20   Page 1 of 10
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page ...

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2
COMPLAINT FOR DAMAGES 
 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
3. 
This system, which took years to develop, all started with them exploiting and 
abusing Jane Doe who they used as a guinea pig to refine their criminal enterprise and widen their 
network of additional sexual abuse victims.   
THE PARTIES 
4. 
Plaintiff Jane Doe is a citizen of the State of California.  At all times relevant to this 
suit, Doe was a minor child living in Florida and New York and who was sexually abused while 
she was a minor by Defendants in New York. 
5. 
Defendant Ghislaine Maxwell is domiciled in the State of New York. 
6. 
Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the 
Estate of Jeffrey E. Epstein. 
7. 
Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the 
Estate of Jeffrey E. Epstein.  
JURISDICTION AND VENUE 
8. 
Plaintiff is domiciled in California. 
9. 
Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin 
Islands at the time of his death. As the legal representatives of the Estate of Jeffrey E. Epstein, 
Darren K. Indyke and Richard D. Kahn are deemed citizens of the U.S. Virgin Islands.  The matter 
in controversy exceeds the sum of $75,000, and therefore jurisdiction in this Court is proper.  28 
U.S.C. § 1332(c)(2).    
10. 
Ghislaine Maxwell is domiciled in New York.  
11. 
A substantial part of the events giving rise to these causes of action occurred in the 
Southern District of New York, thus venue in this district is proper.  28 U.S.C. § 1391(b)(2). 
JURY DEMAND 
12. 
Plaintiff hereby demands a trial by jury on all of her claims in this action. 
FACTUAL ALLEGATIO...

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3
COMPLAINT FOR DAMAGES 
 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
in the voice program.  Doe was sitting alone on a bench between classes when Epstein and 
Maxwell approached her.  Epstein bragged to her about being a patron of the arts and giving 
scholarships to talented young artists like Doe.  Epstein and Maxwell probed her at length about 
her background, family situation and where she lived.  As Doe got up to leave, Epstein requested 
her mother’s phone number back in Florida.  She was alarmed by his request, but also feared that 
she could not refuse the older man's request so she complied and provided him with the phone 
number. 
14. 
Several weeks later, once Doe had returned from Michigan to Florida, Epstein 
called Doe's home.  Epstein first spoke with Doe's mother about how he mentors young kids and 
provides scholarships for the arts. He requested to speak to Doe and invited her and her mother to 
his mansion in Palm Beach.  He sent a driver across town to pick them up. 
15. 
Over the course of the next several months, Epstein and Maxwell attempted to 
groom and mentor 13-year-old Jan Doe.  Epstein gave himself the name of Doe’s “godfather” 
while Maxwell acted like an older sister to her.  They took her to movies, went shopping with her 
and lounged around Epstein’s estate with her.  Epstein and Maxwell then started to make sexual 
references when they were with her.  For instance, Maxwell told Doe that having sex with ex-
boyfriends was easy because once you slept with them “they’ve been grandfathered in and you 
could go back and fuck them whenever you wanted.”  Epstein also started to slowly display his 
pedophilic ways when shopping with ...

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4
COMPLAINT FOR DAMAGES 
 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
17. 
During one of Doe's encounters with Epstein, he took her to Mar-a-Lago where he 
introduced her to its owner, Donald J. Trump.  Introducing 14-year-old Doe to Donald J. Trump, 
Epstein elbowed Trump playfully asking him, referring to Doe, "This is a good one, right?"  
Trump smiled and nodded in agreement. They both chuckled and Doe felt uncomfortable, but, at 
the time, was too young to understand why.     
18. 
Towards the end of 1994, Epstein invited Doe into his pool house, where he 
grabbed her, put her on his lap and started masturbating.  Epstein told her that was what to expect 
from photographers who were soon going to be take modeling pictures of her.  However, when 
Doe was ultimately photographed by these professional photographers, they did no such thing.  
19. 
Over the next few years, the sexual abuse escalated.  On a regular basis, Epstein 
would digitally penetrate Doe, force Doe to perform sexual acts on him and apply vibrators on 
different parts of Doe’s body.  The abuse occurred at Epstein’s home in Palm Beach, Florida, 
Epstein’s townhouse on 9 East 71st Street in New York City, and Epstein’s ranch in New Mexico.  
When travelling to these places, Doe often flew with Epstein and Maxwell in Epstein’s private jet. 
20. 
In 1996, when Doe was 16-years-old, Epstein moved Doe to New York City.  At 
first, Epstein put Doe up in his apartment on 65th Street and 2nd Avenue.  After a few months, 
Epstein co-signed the lease for Doe and Doe's mother for an apartment.  Additionally, Epstein paid 
her tuition at a private high school in Manhattan as well.   
21. 
Once Epstein ...

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5
COMPLAINT FOR DAMAGES 
 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
23. 
During Doe's time in New York, Maxwell also regularly facilitated Epstein's abuse 
of Doe and was frequently present when it occurred. 
24. 
In 1999, Doe moved to Los Angeles to start a career.  Upon moving to Los Angeles 
and being physically away from Epstein and Maxwell, Doe finally felt like she could escape 
Epstein's abuse and stopped returning his frequent calls where he would threaten and berate her for 
not appreciating him. 
25. 
Despite Doe's physical escape from Epstein and Maxwell, the years of abuse and 
exploitation perpetrated against her by them cause her immeasurable pain and suffering every day.   
Epstein's Death and Will 
26. 
In July 2019, Epstein was indicted by the Unites States Attorney’s Office for the 
Southern District of New York. 
27. 
On August 10, 2019, Epstein was found dead in his jail cell at the Metropolitan 
Correctional Center, where he was being held pending trial. Upon information and belief, New 
York City’s medical examiner concluded Epstein died by suicide. 
28. 
On August 15, 2019, Epstein’s last will and testament (the “Will”) was filed in the 
Probate Division of the Superior Court of the Virgin Islands. 
29. 
The Will indicated that it was executed by Epstein on August 8, 2019 at the 
Metropolitan Correctional Center.  The Will was accompanied by affidavits from Darren K. 
Indyke and Richard D. Kahn attesting to their “Oath of Willingness to Serve as Executor and 
Appointment of Local Counsel.” Mr. Indyke and Mr. Kahn also filed a Petition for Probate and for 
Letters Testamentary in the Superior Court of the Virgin Islands.  
30. 
The Will...

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6
COMPLAINT FOR DAMAGES 
 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
31. 
On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with 
the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn are 
the two Trustees of The 1953 Trust.  
32. 
On September 6, 2019, Magistrate Judge Carolyn P. Hermon-Percell of the 
Superior Court of the Virgin Islands ordered that Epstein’s will be admitted to probate and 
authorized Mr. Indyke and Mr. Kahn to administer the estate. 
FIRST CAUSE OF ACTION 
(Sexual Assault) 
33. 
Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as 
if set forth fully herein. 
34. 
On numerous occasions over several years, Epstein, with Maxwell's assistance, 
made violent sexual demands on Plaintiff while placing his hands on her body in a position of 
dominance and control and while touching Plaintiff in violent and invasive ways.  
35. 
These demands, often made when young Plaintiff was alone with Epstein or with 
only Epstein and Maxwell, were intended to frighten Plaintiff into submitting to his sexual 
demands and placed Plaintiff in apprehension of harm. 
36. 
This conduct caused Plaintiff serious and persistent harm and contributed to 
injuries that Plaintiff continues to suffer. 
37. 
This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g 
(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was 
under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of 
the New York Penal Law (“Article 130”). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.  
SECOND CAUSE O...

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7
COMPLAINT FOR DAMAGES 
 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
40. 
On numerous occasions over several years, Epstein digitally penetrated Doe with 
his fingers, tongue and foreign objects. 
41. 
On numerous occasions over several years, Epstein made otherwise unwanted, 
unlawful, harmful, and offensive physical contact with Plaintiff’s body. 
42. 
This conduct caused Plaintiff serious and persistent harm and contributed to 
injuries that Plaintiff continues to suffer.  
43. 
This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g 
(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was 
under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of 
the New York Penal Law (“Article 130”). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55. 
THIRD CAUSE OF ACTION 
(Intentional Infliction of Emotional Distress) 
44. 
Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as 
if set forth fully herein. 
45. 
Epstein and Maxwell’s campaign of sexual abuse against a teenaged Plaintiff was 
extreme and outrageous conduct that shocks the conscience.  
46. 
Epstein and Maxwell’s serial sexual assaults, committed during the course of a 
methodical plan of recruitment, enticement, and attack, inflicted severe pain and anguish upon 
Plaintiff.  
47. 
Epstein and Maxwell directed this conduct at Plaintiff and knew that it would cause 
severe and lasting emotional distress. Indeed, the conduct caused Plaintiff severe and lasting 
emotional distress and serious injuries to her mental health. 
48. 
This cause of action is timely under the Child Victims ...

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8
COMPLAINT FOR DAMAGES 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
49.
Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as
if set forth fully herein. 
50.
Epstein and Maxwell coaxed Plaintiff, then a teenaged girl, into Epstein's home for
a period of several years. They worked hard to groom her.  Once under their supervision and 
influence, Epstein and Maxwell proceeded methodically to sexually abuse Plaintiff. 
51.
Epstein and Maxwell’s conduct was extreme and outrageous, breached a duty owed
directly to Plaintiff, endangered her physical safety, and caused severe and lasting emotional 
distress and serious injuries to Plaintiff’s mental health.  
52.
This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g
(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was 
under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of 
the New York Penal Law (“Article 130”). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55. 
FIFTH CAUSE OF ACTION 
(False Imprisonment) 
53.
Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as
if set forth fully herein. 
54.
Defendants, in perpetrating the above-described non-consensual sexual assaults,
did, by use of threat and/or physical force, willfully and intentionally confine, detain, imprison 
and/or restrain Plaintiff without lawful authority to do so, against her will, and without her 
consent. 
55.
Plaintiff was aware of, and suffered the extreme effects of, the Defendants'
unlawful confinement.  
56.
As a consequence of Defendants' false imprisonment of Plaintiff, she sustained...

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COMPLAINT FOR DAMAGES 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
58.
This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g
(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was 
under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of 
the New York Penal Law (“Article 130”). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55. 
PRAYER FOR RELIEF 
WHEREFORE, Plaintiff Jane Doe prays for this Court to: 
59.
Issue a judgment declaring that Defendant ESTATE OF JEFFREY E. EPSTEIN by
and through its executors, DARREN K. INDYKE and RICHARD D. KAHN, as legal 
representatives of the Estate of Jeffrey E. Epstein, and Defendant GHISLAINE MAXWELL are 
liable for the violations of law alleged in this case; 
60.
Award actual, compensatory, statutory, consequential and punitive damages;
61.
Award pre-judgment and post-judgment interest at the highest rate allowed by law;
and 
62.
Grant such further relief as this Court may deem just and proper.
Respectfully submitted, 
Dated: ____________________ 
_____________________________ 
Kevin Boyle (admission pending) 
Robert Glassman (admission pending) 
Nathan Werksman (admission pending) 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Blvd., Suite 700 
Los Angeles, CA 90025 
Telephone:  (310) 477-1700 
Facsimile: (310) 477-1699 
boyle@psblaw.com 
glassman@psblaw.com 
werksman@psblaw.com 
/s/ Benedict P. Morelli 
Benedict P. Morelli  
David T. Sirotkin  
Sara A. Mahoney 
MORELLI LAW FIRM PLLC 
January 16, 2020
Case 1:20-cv-00484-JGK   Document 9   Filed 01/22/20   Page 9 of 10
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/2...

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COMPLAINT FOR DAMAGES 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
PANISH SHEA & BOYLE LLP 
11111 Santa Monica Boulevard, Suite 700 
Los Angeles, California 90025 
310.477.1700 phone  •  310.477.1699 fax 
777 Third Avenue, 31st Floor  
New York, NY 10017 
Telephone: (212) 751-9800 
Facsimile: (212) 751-0046  
bmorelli@morellilaw.com  
dsirotkin@morellilaw.com 
smahoney@morellilaw.com 
Attorneys for Plaintiff 
Case 1:20-cv-00484-JGK   Document 9   Filed 01/22/20   Page 10 of 10
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 28 of 33

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EXHIBIT 4 
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 29 of 33

Haddon, Morgan and Foreman, P.C
Laura A. Menninger
150 East 10th Avenue
Denver, Colorado  80203
PH  303.831.7364  FX  303.832.2628
www.hmflaw.com
lmenninger@hmflaw.com
 
 
 
April 13, 2020 
 
Via Email 
 
Robert S. Glassman 
Panish, Shea & Boyle LLP 
11111 Santa Monica Blvd., Suite 700 
Los Angeles, CA 90025 
 
Re: 
20-CV-00484 (JGK-DCF), Jane Doe v. Darren K. Indyke, et al.,  
Dear Mr. Glassman: 
I am not authorized to accept service of any complaint on behalf of Ghislaine 
Maxwell.   
 
Your statement that your letter to me “shall constitute service of the complaint 
and summons as to defendant Ghislaine Maxwell” is an incorrect statement of the 
law. I am unaware of any authority for you to use decisions in other cases with other 
parties under other circumstances to support your own sua sponte service of a 
Complaint under Rule 4. If you have such authority, please share it with me. It also 
appears that you have undertaken no efforts to serve Ms. Maxwell consistent with the 
Rules.  
 
Your threat to seek “default judgment” when you have failed to follow the 
Rules or the applicable authority in New York is not well-founded in law.  Please 
refrain in the future from making such threats. 
 
 
Sincerely, 
 
 
 
 
Laura A. Menninger 
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 30 of 33
HADDON 
MORGAN 
FOREMAN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EXHIBIT 5 
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 31 of 33

Ransome v. Epstein, Not Reported in Fed. Supp. (2018)
2018 WL 637421
 © 2020 Thomson Reuters. No claim to original U.S. Government Works.
1
2018 WL 637421
Only the Westlaw citation is currently available.
United States District Court, S.D. New York.
Sarah RANSOME, Plaintiff,
v.
Jeffrey EPSTEIN, et al., Defendants.
17-cv-616 (JGK)
|
Signed 01/30/2018
Attorneys and Law Firms
Justin Y.K. Chu, Michael Campion Miller, Steptoe &
Johnson, LLP, Alexander Seton Lorenzo, Alston & Bird, LLP,
New York, NY, Laura A. Menninger, Haddon, Morgan and
Foreman, P.C., Denver, CO, John E. Stephenson, Jr., Alston
& Bird LLP, Atlanta, GA, for Defendants.
MEMORANDUM OPINION AND ORDER
John G. Koeltl, United States District Judge
*1  The plaintiff, Sarah Ransome 1 , has moved the Court
to approve alternative service on the defendant Ghislaine
Maxwell and to find that service has been effected. The
plaintiff asserts that, despite diligent measures, she has been
unable to serve Maxwell personally. The plaintiff argues,
however, that she has taken reasonable measures to provide
Maxwell with notice of the pending lawsuit and requests that
this service should be deemed sufficient. Non-party Haddon
Morgan & Foreman, P.C. (“Haddon Morgan”), Maxwell’s
counsel in another litigation pending in this Court, has refused
to accept service on behalf of Maxwell and has objected to
becoming a general agent of process for Maxwell, but has
taken no position on the plaintiff’s application to deem service
effected through the email efforts that the plaintiff has already
made. Neither Maxwell nor any representative of Maxwell
has otherwise opposed the current motion.
Federal Rule of Civil Procedure 4(e)(1) permits a plaintiff
to serve a defendant by following the procedures set forth
by state law in the state where the district court is located.
New York Civil Practice Law and Rules Section 308 sets
forth available methods of service. Where service under
§§ 308(1), (2), or (4)—which generally provide variants of
p...

Ransome v. Epstein, Not Reported in Fed. Supp. (2018)
2018 WL 637421
 © 2020 Thomson Reuters. No claim to original U.S. Government Works.
2
service on Haddon Morgan is likely to provide notice of the
lawsuit to Maxwell, given that Haddon Morgan is presumably
in contact with Maxwell with regards to their representation
of her in the other pending matter. See Bozza, 2015 WL
4039849, at *2.
Accordingly, the motion for alternative service is granted.
The Clerk of Court is directed to close the motion pending
at Docket Number 97. Defendant Maxwell’s time to move
or answer is twenty-one days from the date of this order.
If Maxwell chooses not to appear, the plaintiff may pursue
whatever remedies are available, including the entry of a
default judgment.
SO ORDERED.
All Citations
Not Reported in Fed. Supp., 2018 WL 637421
Footnotes
1
The Clerk of Court is directed to amend the case caption to name Sarah Ransome as the plaintiff. See Docket No. 96.
End of Document
© 2020 Thomson Reuters. No claim to original U.S. Government Works.
Case 1:20-cv-00484-JGK-DCF     Document 43-2     Filed 05/27/20     Page 33 of 33
WESTLAW