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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
ing regulations is to give law enforcement real-time information so that it can act to detect violations of the law and protect public safety. 89. The Government of the Virgin Islands did not know, and could not have known, that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind eye t
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
ing regulations is to give law enforcement real-time information so that it can act to detect violations of the law and protect public safety. 89. The Government of the Virgin Islands did not know, and could not have known, that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind eye t
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
d Little St. James. 35. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 36. The Attorney General brings this action to seek all remedies a
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
d Little St. James. 35. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 36. The Attorney General brings this action to seek all remedies a
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
ing regulations is to give law enforcement real-time information so that it can act to detect violations of the law and protect public safety. 89. The Government of the Virgin Islands did not know, and could not have known, that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind eye t
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
thern 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 amend the Complaint to add these individuals and entities when discovered. 39. The Attorney General brings this action to seek all remedies a
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
d Little St. James. 35. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 36. The Attorney General brings this action to seek all remedies a
Entities connected to both Southern Trust Company and The Government 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
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSON
St Thomas
LOCATION
Sarah Ferguson
PERSON
George W. Bush
PERSONJEGE, Inc.
ORGANIZATIONLarry Visoski
PERSONU.S. Virgin
LOCATION
Prince Charles
PERSON