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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
Islands used to facilitate the criminal enterprise carried out by the Epstein Enterprise, including but not limited to Little St. James Island and Greater St. James Island . E. Issue an order forfeiting to the Government of the Virgin Islands any proceeds or funds obtained by Defendants, whether directly
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
Islands used to facilitate the criminal enterprise carried out by the Epstein Enterprise, including but not limited to Little St. James Island and Greater St. James Island . E. Issue an order forfeiting to the Government of the Virgin Islands any proceeds or funds obtained by Defendants, whether directly
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
Islands used to facilitate the criminal enterprise carried out by the Epstein Enterprise, including but not limited to Little St. James Island and Greater St. James Island; E. Issue an order forfeiting to the Government of the Virgin Islands any proceeds or funds obtained by Defendants, whether directly
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
Islands used to facilitate the criminal enterprise carried out by the Epstein Enterprise, including but not limited to Little St. James Island and Greater St. James Island . E. Issue an order forfeiting to the Government of the Virgin Islands any proceeds or funds obtained by Defendants, whether directly
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
Islands used to facilitate the criminal enterprise carried out by the Epstein Enterprise, including but not limited to Little St. James Island and Greater St. James Island . E. Issue an order forfeiting to the Government of the Virgin Islands any proceeds or funds obtained by Defendants, whether directly
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
property used to facilitate the criminal enterprise carried out by the Epstein Enterprise, including but not limited to Little St. James Island and Greater St. James Island; E. Issue an order forfeiting to the Government of the Virgin Islands any proceeds or funds obtained by Defendants, whether directly
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
property used to facilitate the criminal enterprise carried out by the Epstein Enterprise, including but not limited to Little St. James Island and Greater St. James Island; E. Issue an order forfeiting to the Government of the Virgin Islands any proceeds or funds obtained by Defendants, whether directly
Entities connected to both V.I.C. and Greater St.

U.S. Virgin Islands
LOCATION
Jeffrey Epstein
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
New York
LOCATION
St. John
LOCATIONSouthern Trust Company
ORGANIZATION
Great St. James
ORGANIZATION
St. Croix
LOCATION
Financial Trust Company
ORGANIZATIONHyperion Air
ORGANIZATIONL.S.J.
ORGANIZATIONthe Government of the United States Virgin Islands
ORGANIZATIONLarry Visoski
PERSON
Monaco
LOCATION
Condoleezza Rice
PERSON
Vienna
LOCATIONthe The 1953 Trust
ORGANIZATIONFreedom Air Petroleum
ORGANIZATION
NAUTILUS
ORGANIZATION