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AS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David 1. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 849-4962 [email protected] CAROL THOMAS-JACOBS (NYS Bar #2941300) Admitted Pro Hac Vice Acting Attorney General of the U
pstein's bestowal of financial and other benefits, including sexual services and forced labor from victims. Id.11 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
rds, airplanes, and other instrumentalities of the Epstein Enterprise. 168. In fact, the main source of funds for the Epstein Enterprise came from Southern Trust. Between 2013 and 2017, Southern Trust reported approximately $184 million in revenues. 169. Defendants Kahn and Indyke directed and controlled th
AS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David I. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 849-4962 [email protected] CAROL THOMAS-JACOBS (NYS Bar #2941300) Admitted Pro Hac Vice Acting Attorney General of the U
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
14SERRCiThitarmanit+261I2 Plagttelnothfl .113 /s/ Linda Singer LINDA SINGER Admitted Pro Hac Vice Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 232-5504 [email protected] Dated: January 9, 2023 SO ORDERED. Dated: New York, New York /— 3 11 /s/ Boyd Johnson WILME
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
, if issued, his limited validity (second valid) passport be lost or stolen, he will report the circumstances immediately to the Passport Office in Washington, DC, or, if abroad, to the nearest U.S. Embassy or Consulate. Thank you for your assistance with this matter. Sincerely, Darren K. K. Indyke Genera
York 10022 Telephone: June 25, 2014 U.S. Passport Office Department of State To Whom It May Concern: Jeffrey Edward Epstein is the President of Southern Trust Company, Inc., an international financial firm, and travels internationally with great frequency. As a consequence, his passport is with him when he travels abro
, if issued, his limited validity (second valid) passport be lost or stolen, he will report the circumstances immediately to the Passport Office in Washington, DC, or, if abroad, to the nearest U.S. Embassy or Consulate. Thank you for your assistance with this matter. Incerely, Darren K. Indy e General Cou
lephone: (212) 971-1314 May 25, 2016 U.S. Passport Office Department of State To Whom It May Concern: Jeffrey Edward Epstein is the President of Southern Trust Company, Inc., an international financial firm, and travels internationally with great frequency. As a consequence, his passport is with him when he travels abro
or, if issued, my limited validity (second valid) passport be lost or stolen, I will report the circumstances immediately to the Passport Office in Washington, DC, or, if abroad, to the nearest U.S. Embassy or Consulate. Thank you for your assistance with this matter. Sincerely, Jeffrey Edward Epstein EFTA
treet, Suite 1520. San Francisco. CA 94111 415.762.8268 Phone I 877.898.1203 Toll Free ' 415.762.8269 Fax I SanFrarcisco4g3visas.com EFTA00316227 SOUTHERN TRUST COMPANY, INC. 6100 Red Hook Quarter, B3 St. Thomas, USVI 00802 May 25, 2016 U.S. Passport Office Department of State To Whom It May Concern: I am the Presid
advantage of the opportunity to say our peace and thank you for allowing us. There is precedent here. Ted Stevens, the Senator from Alaska case in Washington, DC, Judge Emmet Sullivan ordered an independent investigation by a private lawyer when SOUTHERN RS, P.C. EFTA00076210 27 J8RsEPS1 4 5 6 7 8
ey, and I didn't know any better. Sadly, you were the one with an illness that you should have to go and see a doctor and also have a mentor group SOUTHERN RS, P.C. EFTA00076226 43 J8RPEPS2 for the sickness you have. I will continue with writing my book about that secret life, with all the newspaper a
auneettlE62 F(rli£dcDQ11DP.VZ3 Flaajgethottill /s/ Linda Singer LINDA SINGER Admitted Pro Hac Vice Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 232-5504 [email protected] Dated: January 9, 2023 SO ORDERED. Dated: New York, New York /— /pe el 3 11 /s/ Boyd Johnson
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 Washington D.C. and Southern Trust Company

Jeffrey Epstein
PERSONDarren Indyke
PERSONHyperion Air
ORGANIZATION
Richard Kahn
PERSON
United States
LOCATIONLeon Black
PERSON
U.S. Virgin Islands
LOCATION
Martha Stewart
PERSON
Prince Andrew
PERSONGratitude America
ORGANIZATION
George W. Bush
PERSON
David Cameron
PERSON
Donald Trump
PERSON
Ghislaine Maxwell
PERSON
Financial Trust Company
ORGANIZATION
Lesley Groff
PERSON
Julie K. Brown
PERSON
Marc Rich
PERSON
Prince Charles
PERSON
Alan Dershowitz
PERSON