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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
d to, making fraudulent claims upon the Government. 392. The Epstein Enterprise misrepresented the purpose, activities, employment, and income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epste
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
d to, making fraudulent claims upon the Government. 291. The Epstein Enterprise misrepresented the purpose, activities, employment, and income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epstei
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
d to, making fraudulent claims upon the Government. 392. The Epstein Enterprise misrepresented the purpose, activities, employment, and income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epste
Entities connected to both Southern Trust Company and the Southern Trust Company, Inc.

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
U.S. Virgin Islands
LOCATION
New York
LOCATION
Condoleezza Rice
PERSON
Jes Staley
PERSON
Apple
ORGANIZATIONV.I.C.
ORGANIZATION
Vienna
LOCATIONSouthern District
LOCATION
Monaco
LOCATIONthe The 1953 Trust
ORGANIZATIONGreater St.
LOCATION
Washington D.C.
LOCATIONSORCPA
LOCATION
Marla Maples
PERSONthe Epstein Enterprise's
ORGANIZATIONMotley Rice
PERSON
Laurel
LOCATION