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tiOCIEIMME Figtige/36ailVZ'3 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
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
provide a source of income to support his criminal activities and properties in the Virgin Islands. 2. Defendants Cypress, Inc.; Maple, Inc.; and Laurel, Inc. 177. Epstein formed Cypress, Inc.; Maple, Inc.; and Laurel, Inc. as Virgin Islands corporations in or about November 2011. 178. As of December 3
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
0 shares of Cypress, Inc., a U.S. Virgin Islands Corporation, which holds title to 49 Zorro Ranch Road Stanley, New Mexico 87056 10,000 shares of Laurel, Inc., a U.S. Virgin Islands Corporation, which holds tide to 358 El Brillo Way Palm Beach, Florida 33480 999 shares of SCI JEP, a French Company whic
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
pstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT TWENTY-FIVE Fraudulent Claims Upon the Government—Cypress, Inc.; Maple, Inc.; Laurel, Inc. Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §.§. 600 et seq. and 14 V.I.C. § 843 408. The Government restates
Entities connected to both Southern Trust Company and Laurel, Inc.

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
U.S. Virgin Islands
LOCATION
Financial Trust Company
ORGANIZATIONHBRK Associates
ORGANIZATION
United States
LOCATION
Prince Andrew
PERSON
Alfredo Rodriguez
PERSON
Alan Dershowitz
PERSON
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSON
Sarah Ferguson
PERSON
St Thomas
LOCATION
George Mitchell
PERSONErika Kellerhals
PERSON
George W. Bush
PERSON
Apple
ORGANIZATIONLarry Visoski
PERSON
Lesley Groff
PERSON