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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
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
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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
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
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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
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
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Mutual Connections (39)
Entities connected to both V.I.C. and the Southern Trust Company, Inc.
U.S. Virgin Islands
LOCATION57 w/ V.I.C.·3 w/ the
Jeffrey Epstein
PERSON52 w/ V.I.C.·3 w/ the
DI
Darren Indyke
PERSON25 w/ V.I.C.·3 w/ the
New York
LOCATION24 w/ V.I.C.·2 w/ the
Richard Kahn
PERSON20 w/ V.I.C.·3 w/ the
Southern Trust Company
ORGANIZATION14 w/ V.I.C.·3 w/ the
Condoleezza Rice
PERSON12 w/ V.I.C.·2 w/ the
Apple
ORGANIZATION9 w/ V.I.C.·2 w/ the
Southern District
LOCATION8 w/ V.I.C.·2 w/ the
Greater St.
LOCATION7 w/ V.I.C.·3 w/ the
the The 1953 Trust
ORGANIZATION7 w/ V.I.C.·3 w/ the
Jes Staley
PERSON8 w/ V.I.C.·2 w/ the
Monaco
LOCATION8 w/ V.I.C.·2 w/ the
Vienna
LOCATION8 w/ V.I.C.·2 w/ the
SORCPA
LOCATION7 w/ V.I.C.·2 w/ the
MR
Motley Rice
PERSON6 w/ V.I.C.·2 w/ the
the Epstein Enterprise's
ORGANIZATION6 w/ V.I.C.·2 w/ the
Laurel, Inc.
ORGANIZATION5 w/ V.I.C.·2 w/ the
the United States District Court
ORGANIZATION4 w/ V.I.C.·2 w/ the
Laurel
LOCATION4 w/ V.I.C.·2 w/ the