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Maxwell was also employed by several of Epstein's other entities. including. but not limited to. the C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC. JEGE Inc.. and LSJ. LLC. 53. Upon information and belief, the corporate organizational documents of these other entities likely provide a right
ant to 4 V.I.C. § 76. 8. Pursuant to 4 V.I.C. § 78, venue properly lies in the United States Virgin Islands. and in the Division of St. Thomas and St. John. FACTUAL ALLEGATIONS 9. Erom approximately 1999 thromth at least 2006. Maxwell was employed by Epstein individually. and by several of his affili
ly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, LLC, NES, LLC, Plan D, LLC, Southern Financial, LLC, and Southern Trust Company. 28. Epstein used his wealth and power to create the Epstei
ties pursuant to 5 V.I.C. § 4903. 4. The Virgin Islands is an unincorporated territory of the United States. It consists of St. Thomas, St. Croix, St. John, and Water Island, and more than 40 surrounding islands and Cays, some of which are privately owned. Among these privately owned islands are Little
ly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, LLC, NES, LLC, Plan D, LLC, Southern Financial, LLC, and Southern Trust Company. 28. Epstein used his wealth and power to create the Epstei
ties pursuant to 5 V.I.C. § 4903. 4. The Virgin Islands is an unincorporated territory of the United States. It consists of St. Thomas, St. Croix, St. John, and Water Island, and more than 40 surrounding islands and Cays, some of which are privately owned. Among these privately owned islands are Little
Entities connected to both JEGE, Inc. and St. John

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
Richard Kahn
PERSON
United States
LOCATIONLarry Visoski
PERSON
George W. Bush
PERSON
JPMorgan Chase
ORGANIZATION
Marc Rich
PERSON
U.S. Virgin Islands
LOCATION
Eric Trump
PERSON
Lesley Groff
PERSONMaria Farmer
PERSONLeon Black
PERSON
St. Croix
LOCATION
Condoleezza Rice
PERSON
Department of Justice
ORGANIZATION
Alan Dershowitz
PERSON
Prince Charles
PERSONCecile de Jongh
PERSON