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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
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
19-JSR Document 36 Filed 01/13/23 Page 72 of 130 and the identities of the individual Class members are ascertainable through records maintained by the Epstein Estate and JP Morgan, including but not limited to JP Morgan's records for Epstein-related accounts (e.g., account ledgers reflecting payments from Epstei
g to JP Morgan. 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 expense
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
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
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
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 the Epstein Estate and Hyperion Air

Jeffrey Epstein
PERSONDarren Indyke
PERSONSouthern Trust Company
ORGANIZATIONGratitude America
ORGANIZATIONLarry Visoski
PERSONHBRK Associates
ORGANIZATION
Richard Kahn
PERSON
United States
LOCATION
Marc Rich
PERSON
U.S. Virgin Islands
LOCATION
Ghislaine Maxwell
PERSON
David Boies
PERSON
Prince Andrew
PERSON
Hyperion
ORGANIZATIONJane Doe
PERSON
Keystone
ORGANIZATIONLeon Black
PERSONthe Southern District
LOCATION
New York
LOCATION
Virginia Giuffre
PERSON