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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
. The Virgin Islands Legislature enacted the CICO Act with the purpose to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14
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
. The Virgin Islands Legislature enacted the CICO Act with the purpose to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14
rovide services). 85. Some of these companies held considerable assets: Financial Informatics, Inc. (incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of approximately $391 million in 2015; and Financial Trust Company, Inc. (incorporated November 6, 1998) had assets of $212 million whe
man Trafficking Act, 14 V.I.C. §131 er seq, and violates CICO, enacted to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14 V
rovide services). 85. Some of these companies held considerable assets: Financial Informatics, Inc. (incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of approximately $391 million in 2015; and Financial Trust Company, Inc. (incorporated November 6, 1998) had assets of $212 million whe
man Trafficking Act, 14 V.I.C. §131 et seq, and violates CICO, enacted to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14 V
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 7 EFTA00145672 Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 8 of 42 owned—applied for economic benefits
. The Virgin Islands Legislature enacted the CICO Act with the purpose to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14
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
man Trafficking Act, 14 V.I.C. §131 et seq, and violates CICO, enacted to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14 V
rovide services). 85. Some of these companies held considerable assets: Financial Informatics, Inc. (incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of approximately $391 million in 2015; and Financial Trust Company, Inc. (incorporated November 6, 1998) had assets of $212 million whe
man Trafficking Act, 14 V.I.C. §131 et seq, and violates CICO, enacted to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14 V
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
rovide services). 88. Some of these companies held considerable assets: Financial Informatics, Inc. (incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of EFTA00018795 --- PAGE BREAK --- Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 19 of 55 GVI v. Estate of Jeffrey Epst
Page: EFTA00018796 →man Trafficking Act, 14 V.I.C. §131 et seq, and violates CICO, enacted to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14 V
Page: EFTA00018798 →Entities connected to both Southern Trust Company and the Territory of the Virgin Islands

Jeffrey Epstein
PERSONDarren Indyke
PERSONHyperion Air
ORGANIZATION
Richard Kahn
PERSONGratitude America
ORGANIZATION
U.S. Virgin Islands
LOCATION
Financial Trust Company
ORGANIZATIONHBRK Associates
ORGANIZATION
Deutsche Bank
ORGANIZATION
United States
LOCATION
Les Wexner
PERSON
Alfredo Rodriguez
PERSON
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSONLarry Visoski
PERSONJEGE, Inc.
ORGANIZATION
Samantha Power
PERSON
Prince Charles
PERSON
New York
LOCATION
Condoleezza Rice
PERSON