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in GVI's Complaint Page 2 of 48 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
THE UNITED STATES VIRGIN ISLANDS, PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, INC., JOHN AND JANE DOES DEFENDANTS, Case No.: ACTION FOR DAMAGES JURY TRIAL DEMANDED COMPLAINT COMES NOW, the Government of the
in GVI's Complaint Page 2 of 48 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
THE UNITED STATES VIRGIN ISLANDS, PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, INC., JOHN AND JANE DOES DEFENDANTS, Case No.: ACTION FOR DAMAGES JURY TRIAL DEMANDRD rs COMPLAINT COMES NOW, the Government o
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
Y E. EPSTEIN, and ADMINISTRATOR OF 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.; JOHN AND JANE DOES DEFENDANTS, Case No.: ACTION FOR DAMAGES JURY TRIAL DEMANDED C- . : FIR
in GVI's Complaint Page 2 of 48 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
THE UNITED STATES VIRGIN ISLANDS, PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, INC., JOHN AND JANE DOES DEFENDANTS, Case No.: ACTION FOR DAMAGES JURY TRIAL DEMANDED 01 COMPLAINT COMES NOW, the Government of
in GVI's Complaint Page 2 of 48 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
THE UNITED STATES VIRGIN ISLANDS. PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, INC'., JOHN AND JANE DOES DEFENDANTS. Case No.: ACTION FOR DAMAGES JURY TRIAL DEMANDED COMPLAINT COMES NOW, the Government of th
n the matter ESTATE OF JEFFREY E. EPSTEIN, PROBATE NO. ST-19-PB-80, pending in the Superior Court of the Virgin Islands, Division of St. Thomas and St. John. A civil proceeding. Case No. ST-2020-CV-14. having been instituted by the Government of the United States Virgin Islands under Chapter 30 of the V
the Superior Court of the Virgin Islands naming the ESTATE OF JEFFREY E. EPSTEIN; THE 1953 TRUST; PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC.; AND POLAR, INC. as defendants. In conformity with Title 14 VIC. §610(e), from the time of the filing of this Criminal Activity Lien Notice,
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
o JP Morgan. 67. Epstein and/or his associates also made significant cash withdrawals and 95 foreign remittances with no known payee. For example, Hyperion Air, Inc.—the Epstein-controlled company that owned Epstein's private jet—issued over $547,000 in checks payable to cash purportedly for "fuel expenses
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
o JP Morgan. 67. Epstein and/or his associates also made significant cash withdrawals and 95 foreign remittances with no known payee. For example, Hyperion Air, Inc.—the Epstein-controlled company that owned Epstein's private jet—issued over $547,000 in checks payable to cash purportedly for "fuel expenses
Entities connected to both St. John and Hyperion Air

Jeffrey Epstein
PERSONDarren Indyke
PERSONSouthern Trust Company
ORGANIZATIONGratitude America
ORGANIZATIONLarry Visoski
PERSON
Richard Kahn
PERSON
Martha Stewart
PERSON
Marc Rich
PERSON
David Cameron
PERSONHBRK Associates
ORGANIZATION
U.S. Virgin Islands
LOCATION
United States
LOCATION
Lawrence Krauss
PERSON
George W. Bush
PERSON
Lesley Groff
PERSONDaphne Wallace
PERSON
Ghislaine Maxwell
PERSON
St. Croix
LOCATION
Prince Andrew
PERSONLeon Black
PERSON