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V.I.C. §§ 604(e) and 605(a) 120. The Government restates and realleges paragraphs 1 to 119 of this Complaint as if funny set forth herein. 121. The Virgin Islands Legislature enacted the CICO Act with the purpose to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islan
such other relief as the Court deems appropriate. JURY DEMAND The Government demands a jury trial on all issues so triable. Dated: April 3, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Isl Linda Singer Linda Singer (pro hac vice) Mimi Liu (pro hac vice) David I. Ackerman Paige Boggs (pro hac vice)
V.I.C. §§ 604(e) and 605(a) 110. The Government restates and realleges paragraphs 1 to 109 of this Complaint as if funny set forth herein. III. The Virgin Islands Legislature enacted the CICO Act with the purpose to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islan
h other relief as the Court deems appropriate. JURY DEMAND The Government demands a jury trial on all issues so triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David 1. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washingto
V.I.C. §§ 604(e) and 605(a) 110. The Government restates and realleges paragraphs 1 to 109 of this Complaint as if funny set forth herein. III. The Virgin Islands Legislature enacted the CICO Act with the purpose to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islan
h other relief as the Court deems appropriate. JURY DEMAND The Government demands a jury trial on all issues so triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David I. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washingto
Entities connected to both The Virgin Islands Legislature and CAROL THOMAS-JACOBS

Glenn Dubin
PERSON
Condoleezza Rice
PERSON
Financial Trust Company
ORGANIZATIONEnhanced Education
ORGANIZATIONVirgin Islands Department of Justice
ORGANIZATIONHBRK Associates
ORGANIZATION
Hyperion
ORGANIZATIONHyperion Air
ORGANIZATIONJEGE, Inc.
ORGANIZATION
Financial Crimes Enforcement Network
ORGANIZATIONOffice of the Comptroller of the Currency
ORGANIZATIONConchita Samoff
PERSONThe Government of the Virgin Islands
ORGANIZATIONthe U.S. Department of
ORGANIZATION
Palm Beach
LOCATION
United States
LOCATIONSecond Amended Complaint
ORGANIZATIONFFIEC
ORGANIZATIONSouthern Trust Company
ORGANIZATIONCoatue Enterprises
ORGANIZATION