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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
ise was able to hide the trafficking ring from law enforcement, despite the fact that Epstein was a registered sex offender. Given the isolation of the Little St. James and Great St. James and the nature of the crimes and of the victims targeted by the Epstein Enterprise, the activities of the Epstein Enterprise wer
w, Epstein engaged in a pattern and practice of trafficking and sexually abusing young women and female children on this private, secluded island of Little St. James where Epstein and his associates could avoid detection of their illegal activity from Virgin EFTA00162291 CflaseL222 1MOD0194138:2 Geoorm3ati8011.
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
w, Epstein engaged in a pattern and practice of trafficking and sexually abusing young women and female children on this private, secluded island of Little St. James where Epstein and his associates could avoid detection of their illegal activity from Virgin EFTA00161875 Case 1:22-cv-10904-JSR Document 16-1 Fil
ise was able to hide the trafficking ring from law enforcement, despite the fact that Epstein was a registered sex offender. Given the isolation of the Little St. James and Great St. James and the nature of the crimes and of the victims targeted by the Epstein Enterprise, the activities of the Epstein Enterprise wer
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
w, Epstein engaged in a pattern and practice of trafficking and sexually abusing young women and female children on this private, secluded island of Little St. James where Epstein and his associates could avoid detection of their illegal activity from Virgin Islands and federal law enforcement and prevent these y
Entities connected to both the Epstein Estate and Little St. James

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONDarren Indyke
PERSON
U.S. Virgin Islands
LOCATION
Richard Kahn
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSONLeon Black
PERSON
New York
LOCATION
Jean-Luc Brunel
PERSON
Hillary Clinton
PERSON
JPMorgan Chase
ORGANIZATION
Prince Charles
PERSON
David Boies
PERSON
United States
LOCATION
Les Wexner
PERSONFreedom Air Petroleum
ORGANIZATION
Julie K. Brown
PERSON