Human Trafficking Expert’s Testimony About Shell Companies Admitted
Posted on October 1, 2025 by Expert Witness Profiler
Jane Doe 3, a victim of Jeffrey Epstein’s abuse, sued Darren K. Indyke and Richard D. Kahn in their capacities as the executors of Jeffrey Epstein’s estate for participating in a sex-trafficking venture in violation of the Trafficking Victims Protection Act (TVPA).
Doe’s rebuttal expert, Jane Khodarkovsky, is a former state and federal prosecutor who served in various roles as a human-trafficking specialist.
Doe engaged Khodarkovsky to “offer her expert testimony regarding sex trafficking and how shell companies, funnel accounts, and other tools can be used by gatekeepers, such as lawyers, bankers and accountants, to support and promote sex trafficking networks.” Khodarkovsky opined that “the use of shell companies is one way in which criminal networks, including in sex trafficking, conceal the source and nature of their criminal activity,” and “Defendants had knowledge of red flag indicators that they reasonably should have known were part of an illicit sex trafficking network.”
Defendants filed a motion to exclude Khodarkovsky’s testimony in full.
Human Trafficking Expert Witness
Jane Khodarkovsky spent almost a decade as a state and federal prosecutor. She served as a Trial Attorney and Human Trafficking Finance Specialist for the U.S. Department of Justice, Money Laundering and Asset Recovery Section (DOJ/MLARS) from December 2018- April 2022. For almost three years, Khodarkovsky served as the sole Human Trafficking Finance Specialist for the entire DOJ.
In January 2023, she founded Chazak Consulting LLC, a sole member limited liability consulting firm focused on providing consulting services related to anti-money laundering and human trafficking, child exploitation, and blockchain related matters.
Also, Khodarkovsky earned her Juris Doctor from the University of Michigan Law School, and Bachelor in Arts from Barnard College, summa cum laude.
Discussion by the Court
To begin with, the Court agreed that some portions of Khodarkovsky’s testimony are inadmissible. Whether Defendants knew or recklessly disregarded that Epstein was engaged in sex trafficking is “a central issue in this case.” Khodarkovsky crossed the line by concluding that “Defendants had knowledge of red flag indicators that they reasonably should have known were part of an illicit sex trafficking network.”
Additionally, as all parties seem to agree, Khodarkovsky may not testify about the scope of the TVPA.
However, the Court disagreed with Defendants that the rest of Khodarkovsky’s testimony is inadmissible under Rule 702 or 403. Khodarkovsky is experienced in investigating human trafficking, and her opinions regarding how shell companies are used by sex traffickers to enable their operations, as well as how Epstein used his shell companies, will assist the jury in determining whether Epstein was engaged in a sex-trafficking enterprise and, without opining directly on the issue, whether Defendants knew or recklessly disregarded that fact. To the extent that certain financial or bank regulations are relevant to her testimony, she may describe those, given that they inform her opinions on corporate-structuring and transactions.
Held
The Court granted in part and denied the Defendants’ motion to exclude the testimony of Jane Khodarkovsky.
Key Takeaway:
Whether Defendants knew or should have known that Epstein was engaged in sex trafficking is a question for the jury, not the experts. In other words, Khodarkovsky can’t offer testimony on what Defendants knew or should have known, which is for the jury to figure out.
Case Details:
| Case Caption: | Doe 3 V. Indyke Et Al |
| Docket Number: | 1:24cv1204 |
| Court Name: | United States District Court, New York Southern |
| Order Date: | September 15, 2025 |
