Plaintiffs want court-ordered program to identify and notify all victims
Two women filed a lawsuit this week in U.S. District Court for the Southern District of New York against the co-executors of Jeffrey Epstein’s estate, alleging that Epstein possessed child sexual abuse material (CSAM) for more than two decades and seeking both monetary damages and a court-supervised process to identify and notify every person depicted in images seized from his properties. Epstein died in a Manhattan jail in 2019 while awaiting trial on federal sex-trafficking charges.
The complaint names as defendants Epstein’s former lawyer Darren Indyke and former accountant Richard Kahn, who are sued in their capacities as co-executors of the estate rather than in their personal capacities. Attorneys for Indyke and Kahn did not immediately respond to a request for comment on Wednesday; both have previously said they had no knowledge of Epstein’s crimes during their employment.
The first plaintiff, identified in the complaint as Jane Doe, alleges that Epstein stole partially nude photographs of her when she was around 12 years old. According to the complaint, those photographs had originally been taken “as part of an artist study for and catalogued, numbered and maintained by the artist in a lockbox.” The complaint alleges that Epstein acquired the images “by theft” and transported them across state lines.
The complaint further alleges that “despite contemporaneous reports made to law enforcement, specifically alerting law enforcement that Epstein had obtained these photos of Jane Doe, and similar photos of another minor, no one in law enforcement took action to prosecute anyone or even investigate these reports.” Jane Doe, according to the complaint, “suffered and continues to suffer severe emotional distress” upon learning that Epstein had possessed the images.
The complaint alleges that beginning in the 1990s, Epstein “created and kept” in a locked safe in his New York City home a “‘modeling book’ of sexualized images of children.” Beginning in “at least in the 2000s,” the lawsuit alleges, Epstein had his assistant take nude, sexualized photographs of multiple children, paid them for the images, and used them for his own sexual gratification and possibly that of others.
The second plaintiff, identified in the complaint under the pseudonym “Amy,” alleges that she is a victim of “actively traded CSAM which has been in distribution since the late 1990s to present day.” The lawsuit alleges that, on information and belief, images of Amy are contained within the CSAM collection seized from Epstein’s properties. The complaint also alleges that other people, including Epstein’s employees and coconspirators, had access to, viewed, or otherwise received from Epstein the CSAM images in his possession, including images of Jane Doe and “Amy.”
Margaret Mabie of Marsh Law, one of the lawyers representing the plaintiffs, said in a statement to The Guardian that a report completed on Epstein’s collection identified 15 or more hits of known series like Amy’s, and that “to our knowledge, none of the victims identified in that report, or in any other CSAM discovered in Epstein’s collection, have ever received notice.”
The lawsuit argues that many of those depicted in the CSAM the complaint attributes to Epstein have never been identified or notified through the National Center for Missing and Exploited Children’s victim-identification program.
Hillary Nappi of AWK Survivor Advocate Attorneys said the goal of the lawsuit “is accountability and identification.” “We want the Estate to preserve and account for everything seized from Epstein’s properties, and we want a real, court supervised process to identify and notify every survivor depicted in that collection,” Nappi said. “Many of them have no idea their images exist in his files, and they deserve to know, and they deserve the chance to seek justice.”
“Survivors have waited years for accountability, and this case opens the door for others depicted in his collection who don’t even know they’re in it,” they added.
The plaintiffs are bringing the suit both individually and on behalf of a proposed class of survivors they seek to represent, defined in the complaint as “all persons who were under the age of 18 at the time they appeared in any visual depiction of child pornography, including CSAM, contained within any image, video, or electronic media collections seized from properties or devices controlled by Jeffrey E Epstein, including the media identified in the Epstein Files Transparency Act productions and the materials described in the July 6, 2026 FBI and DOJ Memorandum.”