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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
ceased. COUNT ONE Human Trafficking — Trafficking an Individual Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"), 14 V.I.C. § 600 et seq. and 14 V.I.0 § 133 216. The Government restates and realleges paragraphs 1 to 215 of this Complaint as if fully set forth herein. 2
4 mentions1 same-page
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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
ations of Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges
2 mentions1 same-page
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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
s engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT TWENTY-TWO Civil Conspiracy 382. The Government restates and realleges paragraphs 1 to 381 of this Complaint as if fully set
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Mutual Connections (171)
Entities connected to both Marla Maples and V.I.C.
Jeffrey Epstein
PERSON138 w/ Marla·52 w/ V.I.C.
George W. Bush
PERSON99 w/ Marla·20 w/ V.I.C.
United States
LOCATION74 w/ Marla·20 w/ V.I.C.
JPMorgan Chase
ORGANIZATION81 w/ Marla·12 w/ V.I.C.
Ghislaine Maxwell
PERSON74 w/ Marla·11 w/ V.I.C.
U.S. Virgin Islands
LOCATION22 w/ Marla·57 w/ V.I.C.
Joi Ito
PERSON68 w/ Marla·4 w/ V.I.C.
Alan Dershowitz
PERSON56 w/ Marla·6 w/ V.I.C.
Samantha Power
PERSON47 w/ Marla·5 w/ V.I.C.
DI
Darren Indyke
PERSON24 w/ Marla·25 w/ V.I.C.
Prince Andrew
PERSON38 w/ Marla·10 w/ V.I.C.
Vicky Ward
PERSON44 w/ Marla·3 w/ V.I.C.
New York
LOCATION22 w/ Marla·24 w/ V.I.C.
Condoleezza Rice
PERSON34 w/ Marla·12 w/ V.I.C.
MF
Maria Farmer
PERSON41 w/ Marla·2 w/ V.I.C.
Woody Allen
PERSON23 w/ Marla·19 w/ V.I.C.
Donald Trump
PERSON38 w/ Marla·3 w/ V.I.C.
Richard Kahn
PERSON19 w/ Marla·20 w/ V.I.C.
Stephen Hawking
PERSON33 w/ Marla·6 w/ V.I.C.
LB
Leon Black
PERSON36 w/ Marla·3 w/ V.I.C.