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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
uropean surnames who were publicly and internally identified as Epstein recruiters and/or victims. For example, Epstein paid more than $600,0000 to Jane Doe 1, a woman who—according to news reports contained in JP Morgan's due diligence reports-Epstein purchased at the age of 14. Like other women who recei
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
of 18 U.S.C. §§ 1591(a)(1) & (a)(2) by aiding, abetting, and inducing Epstein's and his conspirators sex-trafficking venture and sex trafficking of Jane Doe 1, as well as other Class Members. As a consequence, Jane Doe 1, as well as other members of the Class, are victims of JP Morgan's criminally aiding,
ove). 486. Among the acts constituting a pattern of racketeering activity, on or about August 19, 2013, Deutsche Bank opened brokerage accounts for Southern Trust Company Inc., a self-described "database company and services" founded in the U.S. Virgin Islands in 2011, and Southern Financial LLC, a wholly owned subsidiary
t limitation, physical, psychological, emotional, financial, and reputational harm. 368. Deutsche Bank's knowing and intentional conduct has caused Jane Doe 1 and the other Members of the Class harm that is sufficiently serious, under all the surrounding circumstances, to compel a reasonable person of the
eutsche Bank reasonably could foresee, and did in fact foresee, that its negligent failure to prevent physical harm would result in physical harm to Jane Doe I and the Class Members. Deutsche Bank owed a duty to prevent that physical harm. 560. Deutsche Bank failed to act objectively reasonably in failin
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
ews reports contained in JP Morgan's due diligence reports-Epstein purchased at the age of 14. Like other women who received payments from Epstein, Jane Doe 1 listed Epstein's apartments on 66th Street in New York City as her address, which should have been a red flag to JP Morgan. 67. Epstein and/or his
ey, and I didn't know any better. Sadly, you were the one with an illness that you should have to go and see a doctor and also have a mentor group SOUTHERN RS, P.C. EFTA00076226 43 J8RPEPS2 for the sickness you have. I will continue with writing my book about that secret life, with all the newspaper a
HE COURT: Thank you very much. I believe that the next client is going to also be a Jane Doe; so I think for the purposes of the record it will be Jane Doe 2. THE COURT: Yes. JANE DOE NO. 2: Good morning, your Honor. THE COURT: Good morning. How are you? JANE DOE NO. 2: Doing okay. I hadn't prepared an
York 10022 Telephone: June 25, 2014 U.S. Passport Office Department of State To Whom It May Concern: Jeffrey Edward Epstein is the President of Southern Trust Company, Inc., an international financial firm, and travels internationally with great frequency. As a consequence, his passport is with him when he travels abro
HOOK QUARTER Address Lirre4: Cindy labs! Afortherit Coronary, Suite, Unit. Budding, Floor. In Caro Of or Mention if applicable. (a g., In Can Of- Jane Doe, Apt * 0rh B 3 City State Zip Code County If outside the United States ST THOMAS VI 0 0 8 0 2 t. List all other names you have used. (Examp
lephone: (212) 971-1314 May 25, 2016 U.S. Passport Office Department of State To Whom It May Concern: Jeffrey Edward Epstein is the President of Southern Trust Company, Inc., an international financial firm, and travels internationally with great frequency. As a consequence, his passport is with him when he travels abro
f or Attention if applicable. (e.g.. In Cora Of - Jane Doe, Apra 100) City State Tap Code Country. if ou
g firm for Larry Summers, a former Hary Administration official. The wire details indicate that the payment was for "Travel Expenses." $1,196 W Southem Trust 11/24/2014 $37 W Southern Trust Company, Inc. Lawrence Krauss 4/5/2018 Krauss is a physicist, and former professor at Yale and Arizona State
e suit. 5 Gut. thLink & Rockenbach, P.A. Lesley Groff 19 $5,509,464 Jeffrey Epstein Link & Rockenbach represented Groff and Epstein in the Jane Doe 43 lawsuit. It is possible that these payments were made solely for the benefit of Epstein. The transaction dates coincide with the lawsuit. " Se
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
s Kahn and Indyke were Treasurer/Director and Secretary/Director, respectively. Epstein was the sole owner of Southern Trust Company. 38. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will am
Page: EFTA00018786 →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 →Entities connected to both Southern Trust Company and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONDarren Indyke
PERSON
Paul Cassell
PERSON
United States
LOCATION
Alan Dershowitz
PERSONHyperion Air
ORGANIZATIONMaria Farmer
PERSON
George W. Bush
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Ghislaine Maxwell
PERSONSouthern District
LOCATION
Alexander Acosta
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATIONZorro Management LLC
ORGANIZATION
Virginia Giuffre
PERSON
U.S. Virgin Islands
LOCATION