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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.
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.1.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 255. SORCPA requires that offenders required to register provide information relating to intended travel in foreign commerce. 256. On at least two occasions,
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.
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
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.
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
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
register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 356. SORCPA requires that offenders required to register provide information relating to intended travel in foreign commerce. 357. On at least two occasions,
Entities connected to both the Epstein Enterprise's and SORCPA

Richard Kahn
PERSON
Monaco
LOCATIONDarren Indyke
PERSONV.I.C.
ORGANIZATIONSouthern Trust Company
ORGANIZATION
Vienna
LOCATION
Jeffrey Epstein
PERSON
U.S. Virgin Islands
LOCATIONthe The 1953 Trust
ORGANIZATIONGreater St.
LOCATION
Financial Trust Company
ORGANIZATIONExpedited Motion for Establishment of a
ORGANIZATIONFinancial Informatics, Inc.
ORGANIZATIONthe Coastal Zone
LOCATIONLarry Visoski
PERSONPlan D
ORGANIZATIONDepartment of Justice Investigators
ORGANIZATIONThe Estate lists
ORGANIZATIONL.S.J.
ORGANIZATIONPetition
ORGANIZATION