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lected the reality of the above assets held or the above expenses incurred by each entity. 194. The Annual Reports submitted on behalf of Cypress, Maple, and Laurel all were signed by Epstein and Defendant and Co-Executor Kahn with the representation that "ALL STATEMENTS CONTAINED IN THIS APPLICATIO
180. Defendant Maple, Inc. acquired ownership of the property 9 East 71st Street in New York, New York on or about December 23, 2011, shortly after Maple was formed. Maple acquired ownership of the property from Nine East 71st Street Corporation, which was owned by Epstein. 181. Defendant Laurel, I
d and did not include any expenses related to the Palm Beach property in the total expenses it reported to the Government. 193. Neither Cypress's, Maple's, nor Laurel's financial statements ever reflected the reality of the above assets held or the above expenses incurred by each entity. 194. The Ann
Epstein's bestowal of financial and other benefits, including sexual services and forced labor from victims. Id. at 157-195. 25. In October 2012, the Southern Trust Company—one of the companies Epstein owned—applied for economic benefits from the Virgin Islands Economic Development Commission ("EDC") so the company cou
F THE 1953 TRUST; ESTATE OF JEFFREY E. EPSTEIN; THE 1953 TRUST; PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, Inc.; SOUTHERN TRUST COMPANY, INC.; CYPRESS, INC.; MAPLE, INC.; LAUREL, INC.; AND JOHN AND JANE DOES, DEFENDANTS. Case No.: ST-20-CV-14 ACTION FOR DAMAGES JURY TRIAL DEMANDED SE
iled 01/10/23 Page 36 of 77 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 35 of 76 with Epstein. Indyke was a signatory on Southern Trust's primary bank account to which funds were wired, primarily from a single source, as described below. Kahn, as Southern Trust's treasurer, oversaw it
180. Defendant Maple, Inc. acquired ownership of the property 9 East 71st Street in New York, New York on or about December 23, 2011, shortly after Maple was formed. Maple acquired ownership of the property from Nine East 71st Street Corporation, which was owned by Epstein. 181. Defendant Laurel, I
d and did not include any expenses related to the Palm Beach property in the total expenses it reported to the Government. 193. Neither Cypress's, Maple's, nor Laurel's financial statements ever reflected the reality of the above assets held or the above expenses incurred by each entity. 194. The Ann
lected the reality of the above assets held or the above expenses incurred by each entity. 194. The Annual Reports submitted on behalf of Cypress, Maple, and Laurel all were signed by Epstein and Defendant and Co-Executor Kahn with the representation that "ALL STATEMENTS CONTAINED IN THIS APPLICATIO
tiOCIEIMME Figtige/36ailVZ'3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 35 of 76 with Epstein. Indyke was a signatory on Southern Trust's primary bank account to which funds were wired, primarily from a single source, as described below. Kahn, as Southern Trust's treasurer, oversaw it
any, knowing such claims to be false, fictitious, or fraudulent; knowingly and willfully falsified, concealed or covered up material facts regarding the Southern Trust Company; made false or fraudulent statements or representations about the purpose, activities, income, and employment of Southern Trust Company; and made an
nagement, New York Law firms: Seward & Kissel, Maples & Calder Auditor. KPMG 212-257-4930 Administra
firm: Proskauer Rose Dec. 2 S13 Fund Domicile: U.S. eSee Page 6 Somerset Capital, London 44-207-259-1300 Auditor: McGladrey Administrator: Northern Trust Whitehaven Credit Scott Fdchman Credit: Relative value Prime broker: Citigroup Jan. S30+ Opportunities Fund Domicile: U.S. & Cayman Islands
, Janet E Float RaSelIngs, Dana Stilt Frklay, Marla 22, 2013 1 22 PM To: Young, Janet E Co: Ne so
$50 K. Please see the following details and advise which business credit card would be the best one to &room? Jeffrey Epstein will 100 % liability. Southern Trust Company, Inc. Master/Total account limit550.000 Individual limits Jeffrey Epstein S25000 Cecile DeJongh $ 15,000 Jeanne Brennan 510.000 Thank You, Janet vou
1O111111111111314114144iiiiiiiiiiIiiiiii \ \\II II \I. KI. IiIil \II I' \1 \ I I \ IS Toni, BENEFICI %RV B‘NI, ErsrriN Arent iN i Maple, Inc. Maple appears to be an Epstein-controlled entity. Similar to FT Real Estate, this entity shares a USVI address with Epstein and made contributions to Ne
g firm for Larry Summers, a former Hary Administration official. The wire details indicate that the payment was for "Travel Expenses." $1,196 W Southem Trust 11/24/2014 $37 W Southern Trust Company, Inc. Lawrence Krauss 4/5/2018 Krauss is a physicist, and former professor at Yale and Arizona State
e criminal predicate acts as defined by CICO, including but not limited to making fraudulent claims upon the Government. 411. Defendants Cypress, Maple, and Laurel misrepresented the values of their assets held and expenses incurred in their annual reporting to the Government of the United States V
any, knowing such claims to be false, fictitious, or fraudulent; knowingly and willfully falsified, concealed or covered up material facts regarding the Southern Trust Company; made false or fraudulent statements or representations about the purpose, activities, income, and employment of Southern Trust Company; and made an
Entities connected to both Marla Maples and Southern Trust Company

Jeffrey Epstein
PERSONDarren Indyke
PERSONHyperion Air
ORGANIZATION
Richard Kahn
PERSON
U.S. Virgin Islands
LOCATIONGratitude America
ORGANIZATION
Martha Stewart
PERSON
United States
LOCATION
David Cameron
PERSON
Stewart Oldfield
PERSON
Financial Trust Company
ORGANIZATION
JPMorgan Chase
ORGANIZATIONDeutsche Bank Securities Inc.
ORGANIZATION
George W. Bush
PERSONHBRK Associates
ORGANIZATION
Prince Andrew
PERSON
Alan Dershowitz
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSON
Deutsche Bank
ORGANIZATION