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orney General to prosecute a civil action against any persons engaged in a pattern of criminal activity through association with any enterprise. 14 V.I.C. §§ 605, 607. The USVI alleges in its CICO action that decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking enterprise in the Virgin
n Defendants and Epstein Estate Executors Darren Indyke and Richard Kahn served, respectively, as Secretary and Treasurer—knowingly participated in the Epstein Enterprise and facilitated the trafficking and sexual servitude of underage girls and young women by providing the secluded properties at, from, or to which E
2 mentions1 same-page
Page ?Same page
orney General to prosecute a civil action against any persons engaged in a pattern of criminal activity through association with any enterprise. 14 V.I.C. §§ 605, 607. The USVI alleges in its CICO action that decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking enterprise in the Virgin
ch CICO action Defendants and Epstein Estate Executors Darren Indyke and erved, respectively, as Secretary and Treasurer—knowingly participated in the Epstein Enterprise and facilitated the trafficking and sexual servitude of underage girls and young women by providing the secluded properties at, from, or to which E
2 mentions1 same-page
Page ?Same page
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
and death in prison in 2019. 215. The continued criminal conduct by Defendants has caused repeated and continuous injury. The criminal conduct of the Epstein Enterprise was not completed nor were all damages incurred until the wrongdoing ceased. COUNT ONE Human Trafficking — Trafficking an Individual Violation of
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Mutual Connections (64)
Entities connected to both V.I.C. and the Epstein Enterprise
U.S. Virgin Islands
LOCATION57 w/ V.I.C.·3 w/ the
Jeffrey Epstein
PERSON52 w/ V.I.C.·4 w/ the
DI
Darren Indyke
PERSON25 w/ V.I.C.·4 w/ the
Richard Kahn
PERSON20 w/ V.I.C.·2 w/ the
Condoleezza Rice
PERSON12 w/ V.I.C.·3 w/ the
Ghislaine Maxwell
PERSON11 w/ V.I.C.·2 w/ the
Deutsche Bank
ORGANIZATION8 w/ V.I.C.·2 w/ the
MR
Motley Rice
PERSON6 w/ V.I.C.·3 w/ the
the Superior Court
ORGANIZATION6 w/ V.I.C.·2 w/ the
Alan Dershowitz
PERSON6 w/ V.I.C.·2 w/ the
the Epstein Estate
ORGANIZATION5 w/ V.I.C.·2 w/ the
Julie K. Brown
PERSON4 w/ V.I.C.·2 w/ the
Donald Trump
PERSON3 w/ V.I.C.·2 w/ the
First Amended Complaint
ORGANIZATION3 w/ V.I.C.·2 w/ the
Hartford Courant Co.
ORGANIZATION2 w/ V.I.C.·2 w/ the
Onondaga
LOCATION2 w/ V.I.C.·2 w/ the
F.R.D.
ORGANIZATION2 w/ V.I.C.·2 w/ the
Gambale v. Deutsche Bank AG
ORGANIZATION2 w/ V.I.C.·2 w/ the
FO
Foltz
PERSON2 w/ V.I.C.·2 w/ the
JN
Joy v. North
PERSON2 w/ V.I.C.·2 w/ the