Epstein Secrets

3 EFTA00103498 Case 1:19-cv-08673 Document 1 Filed 09/18/19 Page 4 of 16 II. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at the time of his death. As the legal representatives of the Estate of Jeffrey E. Epstein, Darren K. Indyke and Richard D. Kahn are deemed

er situated...to the then acting Trustees of The 1953 Trust." 67. On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn are the two Trustees of The 1953 Trust. See Certificate of Trust, In the Ma

f Jeffrey E. Epstein. JURISDICTION AND VENUE S. Plaintiff is domiciled in 9. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at the time of his death. As the legal representatives of the Estate of Jeffrey E Epstein, Darren K. Indyke and Richard D. Kahn arc deemed

3 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 31. On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn arc the two Trustees of The 1953 Trust. 32. On September 6, 2019, Magistr

recognizing the state's interest in "keeping its contract with its citizens to preserve the confidentiality of their records"). The existence of the U.S. Virgin 41 Ex. F at 1 (8/9/21 Press Release) (statement of 42 Ex. F at 1 (8/9/21 Press Release). 43 Ex. C at 2 (6/25/20 Press Release). 44 See Ex. A IV -

arial, [and] confidential" basis.2' For example, the EVCP operates "entirely free from any interference or control by the Epstein " Ex. G (order of the Superior Court of t1 lit• in Islands Division of St. ( Virgin dated June 2, 2020); see Ex. A ¶¶ 8, 13 Decl.). " Ex. C (6/25/20 Press Release). 16 Maxwell's Mo