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ew York, NY 10021 10,000 shares of Cypress, Inc., a U.S. Virgin Islands Co oration which holds tide to Stanley, New Mexico 87056 10,000 shares of Laurel, Inc., a U.S. Virgin Islands • - title to a eac r, H on a 999 shares of SCI JEP, a French Company which holds title to units 47 with mezzanine, 48 a
of this Honorable Court. 9) Although Petitioners are not residents of the Virgin Islands, they are qualified to serve as Executors pursuant to 15 V.I.C. § 235(c) because they otherwise qualify under 15 V.I.C. § 235(a) and they have appointed the law firm of Kellerhals Ferguson Kroblin PLLC, which ha
00 shares of Cypress, Inc., a U.S. Virgin Islands Corporation, which holds tide to 49 Zorro Ranch Road Stanley, New Mexico 87056 10,000 shares of Laurel, Inc., a U.S. Virgin Islands Corporation, which holds title to 358 El Brillo Way Palm Beach, Florida 33480 999 shares of SCI JEP, a French Company whi
of this Honorable Court. 9) Although Petitioners are not residents of the Virgin Islands, they are qualified to serve as Executors pursuant to 15 V.I.C. § 235(c) because they otherwise qualify under 15 V.I.C. § 235(a) and they have appointed the law firm of Kellerhals Ferguson Kroblin PLLC, which ha
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
Trust, and numerous Epstein business affiliates and associates for violation of the Criminally Influenced and Corrupt Organization Act ("CICO"). 14 V.I.C. § 600 et seq., and civil conspiracy, seeking forfeiture and divestment of assets in favor of the Government, civil penalties, damages, and other re
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
ceased. COUNT ONE Human Trafficking — Trafficking an Individual Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"), 14 V.I.C. § 600 et seq. and 14 V.I.0 § 133 216. The Government restates and realleges paragraphs 1 to 215 of this Complaint as if fully set forth herein. 2
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
s engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT TWENTY-TWO Civil Conspiracy 382. The Government restates and realleges paragraphs 1 to 381 of this Complaint as if fully set
Entities connected to both Laurel, Inc. and V.I.C.

Jeffrey Epstein
PERSON
U.S. Virgin Islands
LOCATIONDarren Indyke
PERSON
Richard Kahn
PERSON
New York
LOCATION
Apple
ORGANIZATION
Sarah Ferguson
PERSONNautilus, Inc.
ORGANIZATIONLarry Visoski
PERSON
Jes Staley
PERSON
Federal Reserve
ORGANIZATION
United States
LOCATION
George W. Bush
PERSON
Great St. James
ORGANIZATIONPoplar, Inc.
ORGANIZATION
Ghislaine Maxwell
PERSONSuperior Court
ORGANIZATION
Mark Epstein
PERSONSouthern Trust Company
ORGANIZATION
New York City
LOCATION