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tates Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 3 V.I.C. § 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of
y and to the average resident of the Virgin Islands. But because of Epstein's enormous wealth, these fines had little effect in curbing or stopping the Epstein Enterprise's unlawful conduct or conforming its activities to the law. EFTA00104228 GVI v. Estate of Jeffrey E. Epstein GVI's Complaint Page 14 of 48 66.
tates Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 3 V.I.C. § 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of
y and to the average resident of the Virgin Islands. But because of Epstein's enormous wealth, these fines had little effect in curbing or stopping the Epstein Enterprise's unlawful conduct or conforming its activities to the law. EFTA00104303 Case 1:19-cv-08673-KPF-DCF Document 45-1 Filed 01/15/20 Page 14 of 49 GVI
tates Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 3 V.I.C. § 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of
y and to the average resident of the Virgin Islands. But because of Epstein's enormous wealth, these fines had little effect in curbing or stopping the Epstein Enterprise's unlawful conduct or conforming its activities to the law. 69. As a result of illegal construction activity of the Epstein Enterprise, the Virgin
tates Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 3 V.I.C. § 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of
y and to the average resident of the Virgin Islands. But because of Epstein's enormous wealth, these fines had little effect in curbing or stopping the Epstein Enterprise's unlawful conduct or conforming its activities to the law. EFTA00086814 GVI v. Estate of Jeffrey E. Epstein GVI's Complaint Page 14 of 48 66.
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
y and to the average resident of the Virgin Islands. But because of Epstein's enormous wealth, these fines had little effect in curbing or stopping the Epstein Enterprise's unlawful conduct or conforming its activities to the law. EFTA00074784 GVI v. Estate of Jeffrey E. Epstein GVI's Complaint Page 14 of 48 66.
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
tional injury, in violation Virgin Islands criminal laws prohibiting Child Abuse and Neglect in Title 14 V.I.C. § 500 et. seq. 275. As a result of the Epstein Enterprise's actions numerous young girls suffered serious physical, mental and emotional injury. 276. Defendants through a pattern of criminal activity acquir
Entities connected to both V.I.C. and the Epstein Enterprise's

U.S. Virgin Islands
LOCATION
Jeffrey Epstein
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
New York
LOCATION
St. John
LOCATION
Great St. James
ORGANIZATIONSouthern Trust Company
ORGANIZATION
St. Croix
LOCATIONHyperion Air
ORGANIZATION
Financial Trust Company
ORGANIZATIONL.S.J.
ORGANIZATIONthe Government of the United States Virgin Islands
ORGANIZATIONLarry Visoski
PERSON
Monaco
LOCATION
NAUTILUS
ORGANIZATIONFreedom Air Petroleum
ORGANIZATION
Vienna
LOCATIONGREAT ST
ORGANIZATION
Little St.
LOCATION