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ties' motions for summary judgment and all unified deposition transcripts and exhibits thereto for use in its pending law enforcement action against the Epstein Estate. BACKGOUND Under Virgin Islands law, the CICO authorizes the USVI through its Attorney General to prosecute a civil action against any persons eng
orney General to prosecute a civil action against any persons engaged in a pattern of criminal activity through association with any enterprise. 14 V.I.C. §§ 605, 607. The USVI alleges in its CICO action that decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking enterprise in the Virgin
ties' motions for summary judgment and all unified deposition transcripts and exhibits thereto for use in its pending law enforcement action against the Epstein Estate. BACKGOUND Under Virgin Islands law, the CICO authorizes the USVI through its Attorney General to prosecute a civil action against any persons eng
orney General to prosecute a civil action against any persons engaged in a pattern of criminal activity through association with any enterprise. 14 V.I.C. §§ 605, 607. The USVI alleges in its CICO action that decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking enterprise in the Virgin
e order." V.I. R. CIV. P. Rule 24(b)(2). Specifically, the Government is a rightful participant in any program designed to distribute the assets of the Epstein Estate because of its interest in the assets and disposition of the 2 In full, Rule 24 (a)(2) reads: -On a timely motion, the court must permit anyone to i
Trust, and numerous Epstein business affiliates and associates for violation of the Criminally Influenced and Corrupt Organization Act ("CICO"). 14 V.I.C. § 600 et seq., and civil conspiracy, seeking forfeiture and divestment of assets in favor of the Government, civil penalties, damages, and other re
of Epstein's Enterprise, including the receiving and sending money to other entities they held. 117. Since they were appointed as Co-Executors of the Epstein Estate in 2019, Defendants Indyke and Kahn have approved the release of Estate funds to pay for the legal fees and costs of persons who—like the Co-Execut
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
of Epstein's Enterprise, including the receiving and sending money to other entities they held. 117. Since they were appointed as Co-Executors of the Epstein Estate in 2019, Defendants Indyke and Kahn have approved the release of Estate funds to pay for the legal fees and costs of persons who—like the Co-Execut
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
Entities connected to both the Epstein Estate and V.I.C.

Jeffrey Epstein
PERSON
U.S. Virgin Islands
LOCATIONDarren Indyke
PERSON
New York
LOCATION
Richard Kahn
PERSON
Sarah Ferguson
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Woody Allen
PERSON
St. John
LOCATION
Great St. James
ORGANIZATIONSouthern Trust Company
ORGANIZATION
Condoleezza Rice
PERSON
St. Croix
LOCATION
JPMorgan Chase
ORGANIZATIONthe State of New York
LOCATION
Prince Andrew
PERSONHyperion Air
ORGANIZATIONMartin Weinberg
PERSON
Financial Trust Company
ORGANIZATION