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ss to Judicial Records and Discovery Documents. Dated: September 1, 2020 Respectfully submitted, /s/ William H. Narwold William H. Narwold, Esq. Motley Rice LLC One Corporate Center 20 Church Street, 17th Floor Hartford, CT 06103 13 EFTA00073272 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 P
n Defendants and Epstein Estate Executors Darren Indyke and Richard Kahn served, respectively, as Secretary and Treasurer—knowingly participated in the Epstein Enterprise and facilitated the trafficking and sexual servitude of underage girls and young women by providing the secluded properties at, from, or to which E
ss to Judicial Records and Discovery Documents. Dated: September 1, 2020 Respectfully submitted, /s/ William H. Narwold William H. Narwold, Esq. Motley Rice LLC One Corporate Center 20 Church Street, 17th Floor Hartford, CT 06103 13 EFTA00077323 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 P
ch CICO action Defendants and Epstein Estate Executors Darren Indyke and erved, respectively, as Secretary and Treasurer—knowingly participated in the Epstein Enterprise and facilitated the trafficking and sexual servitude of underage girls and young women by providing the secluded properties at, from, or to which E
GREED. 10 EFTA00162372 O2taaa22222ettleD29214SERRCiThitarmanit+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
and death in prison in 2019. 215. The continued criminal conduct by Defendants has caused repeated and continuous injury. The criminal conduct of the Epstein Enterprise was not completed nor were all damages incurred until the wrongdoing ceased. COUNT ONE Human Trafficking — Trafficking an Individual Violation of
Entities connected to both Motley Rice and the Epstein Enterprise

Jeffrey Epstein
PERSON
Condoleezza Rice
PERSONDarren Indyke
PERSON
U.S. Virgin Islands
LOCATIONV.I.C.
ORGANIZATION
Richard Kahn
PERSON
Donald Trump
PERSONthe Epstein Estate
ORGANIZATION
Deutsche Bank
ORGANIZATION
Ghislaine Maxwell
PERSONSecond Circuit
ORGANIZATIONMartindell
PERSONAmodeo
PERSONPellegrino
PERSONNewsday LLC
ORGANIZATIONHartford Courant Co.
ORGANIZATIONOnondaga
LOCATIONthe Superior Court
ORGANIZATIONF.R.D.
ORGANIZATIONGambale v. Deutsche Bank AG
ORGANIZATION