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ge 2 of 34 Fraud and Deceptive Business Practices Act. 3. This action stems from an enforcement action the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey Epstein ("Epstein"), under the Virgin Islands' Criminally Influenced and C
n the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey Epstein ("Epstein"), under the Virgin Islands' Criminally Influenced and Corrupt Organizations Act ("CICO Act"), see Government of the U.S. Virgin Islands v. Indyke e
exual activity, and/or attempted to do the same. EFTA00161929 Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 61 of 77 GVI v. Estate of Jeffrey Epstein GV1's Second Amended Complaint Page 60 of 76 338. The Epstein Enterprise kept, maintained, and/or permitted his property at Little St. James to be used
was that, although the Bank properly classified Mr. Epstein as high-risk, the Bank failed to scrutinize the a
ction the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and var
ction the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and vari
t (July 22, 2010), https://www.thedailybeast.com/jeffrey-epstein-pedophile-billionaire-and-his-sex-den. 10 EFTA0
Thomas and Little St. James. 37. Defendant Southern Trust Company, Inc. was originally incorporated in the Virgin Islands on November 18, 2011 as Financial Informatics, Inc., but changed its name to Southern Trust Company in September 2012. Southern Trust Company is a tenant at American Yacht Harbor in Red Hook, St. Tho
AND ST. JOHN GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, PLAINTIFF, V. DARREN K. INDYKE, in his capacity as the EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN and ADMINISTRATOR OF THE 1953 TRUST; RICHARD D. KAHN, in his capacity as the EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN, and ADMINISTRATOR OF T
the Virgin Islands and he maintained a residence on Little St. James, which he acquired in 1998 and in 2016 he also purchased Great St. James. 6. Epstein registered as a sex offender in the Virgin Islands in 2010. He was a Tier 1 offender under Virgin Islands law based upon his Florida conviction of p
"any person or entity arising from or related to Mr. Epstein's conduct." (Motion, at 5). It acts to conceal t
forced labor in violation of 14 V.1.C. § 134. EFTA00073230 Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 27 of 55 GVI v. Estate of Jeffrey Epstein GV1's First Amended Complaint Page 26 of 55 130. The Epstein Enterprise knowingly provided or obtained the labor services of individuals by means of fo
n his capacity as the EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN and ADMINISTRATOR OF THE 1953 TRUST; R
n his capacity as the EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN and ADMINISTRATOR OF THE 1953 TRUST; RI
Thomas and Little St. James. 37. Defendant Southern Trust Company, Inc. was originally incorporated in the Virgin Islands on November 18, 2011 as Financial Informatics, Inc., but changed its name to Southern EFTA00073212 Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 9 of 55 GVI v. Estate of Jeffrey Epstei
Trust Co., Inc. ("the Beneficiary") received four years, ten months of tax incentive benefits. Southern Trust Company, Inc. is solely owned by Mr. Jeffery E. Epstein. Mr. Epstein also owned former VIEDC Beneficiary Financial Trust Company, Inc. whose tax incentive Certificate commenced on April 1, 2009 with a te
eneficiary") received four years, ten months of tax incentive benefits. Southern Trust Company, Inc. is solely owned by Mr. Jeffery E. Epstein. Mr. Epstein also owned former VIEDC Beneficiary Financial Trust Company, Inc. whose tax incentive Certificate commenced on April 1, 2009 with a termination dat
ny. • For the period 2013 to 2016, the Beneficiary provided documentation showing annual employee contributions for full-time employees except Mr. Jeffrey Epstein. • For the year 2017, the Beneficiary provided documentation showing annual employee contributions for full-time employees except Mr. Jeffrey Epst
uthern Trust Company, Inc. is solely owned by Mr. Jeffrey E. Epstein. OTHER FINDINGS: Southern Trust Compan
uthern Trust Company, Inc. is solely owned by Mr. Jeffrey E. Epstein. OTHER FINDINGS: Southern Trust Company
, Inc. is solely owned by Mr. Jeffery E. Epstein. Mr. Epstein also owned former VIEDC Beneficiary Financial Tr
Program Law, all applicable local and federal laws, and program regulations to include the reporting requirements. HISTORY: On November 18, 2011, Financial Informatics, Inc. filed Articles of Incorporation with the Office of the Lieutenant Governor. On December 8, 201 I they were issued a Certificate of Incorporation au
fficking conspiracy and led Jane Doe I, as well as other Class Members, to believe that they would be rewarded if they cooperated and acquiesced to Epstein's coercive demands. 380. JP Morgan's affirmative conduct was committed knowingly, and in reckless disregard of the facts, that Epstein would use ca
e 2 at m 3 Fraud and Deceptive Business Practices Act. 3. This action stems from an enforcement action the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey Epstein ("Epstein"), under the Virgin Islands' Criminally Influenced and C
was that, although the Bank properly classified Mr. Epstein as high-risk, the Bank failed to scrutinize the a
ction the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and var
ction the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and vari
t (July 22, 2010), https://www.thedailybeast.com/jeffrey-epstein-pedophile-billionaire-and-his-sex-den. 10 EFTA0
Thomas and Little St. James. 37. Defendant Southern Trust Company, Inc. was originally incorporated in the Virgin Islands on November 18, 2011 as Financial Informatics, Inc., but changed its name to Southern Trust Company in September 2012. Southern Trust Company is a tenant at American Yacht Harbor in Red Hook, St. Tho
l sexual activity of girls and young women in knowing or reckless disregard of the laws of the U.S. Virgin Islands. EFTA00086836 GVI v. Estate of Jeffrey E. Epstein GVI' s Complaint Page 36 of 48 201. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary c
nd Cays, some of which are privately owned. Among these privately owned islands are Little St. James and Great St. James. 5. Jeffrey E. Epstein ("Epstein") was a resident of the Virgin Islands and he maintained a residence on Little St. James, which he acquired in 1998 and in 2016 he also purchased G
"any person or entity arising from or related to Mr. Epstein's conduct." (Motion, at 5). It acts to conceal t
TATES VIRGIN ISLANDS, PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST.
TATES VIRGIN ISLANDS, PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST.
provide services) and LSJ Emergency, LLC (registered December 2, 2015 to provide services). 85. Some of these companies held considerable assets: Financial Informatics, Inc. (incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of approximately $391 million in 2015; and Financial Trust
UPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, INC., JOHN AND JANE DOES DEFENDANTS, Case No.: ACT
nd Cays, some of which are privately owned. Among these privately owned islands are Little St. James and Great St. James. 5. Jeffrey E. Epstein ("Epstein") was a resident of the Virgin Islands and he maintained a residence on Little St. James, which he acquired in 1998 and in 2016 he also purchased G
TATES VIRGIN ISLANDS, PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST.
TATES VIRGIN ISLANDS, PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST.
"any person or entity arising from or related to Mr. Epstein's conduct." (Motion, at 5). It acts to conceal t
provide services) and LSJ Emergency, LLC (registered December 2, 2015 to provide services). 85. Some of these companies held considerable assets: Financial Informatics, Inc. (incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of approximately $391 million in 2015; and Financial Trust
UPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, INC., JOHN AND JANE DOES DEFENDANTS, Case No.: A
nd Cays, some of which are privately owned. Among these privately owned islands are Little St. James and Great St. James. 5. Jeffrey E. Epstein ("Epstein") was a resident of the Virgin Islands and he maintained a residence on Little St. James, which he acquired in 1998 and in 2016 he also purchased G
"any person or entity arising from or related to Mr. Epstein's conduct." (Motion, at 5). It acts to conceal t
TATES VIRGIN ISLANDS, PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST.
TATES VIRGIN ISLANDS, PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST.
provide services) and LSJ Emergency, LLC (registered December 2, 2015 to provide services). 85. Some of these companies held considerable assets: Financial Informatics, Inc. (incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of approximately $391 million in 2015; and Financial Trust
SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN ************************************* IN THE MATTER OF THE ESTATE OF ) JEFFREY E. EPSTEIN, ) ) Deceased. ) ) PROBATE NO. ST-I9-PB-80 MOTION TO INTERVENE COMES NOV the Government of the United States Virgin Islands (-the Government"
) and hereby files this Motion to Intervene in the Petition for Probate and for Letters Testamentary filed by the Executors of the Estate ofJeffrey Epstein ("the Estate") on August 15, 2019. Pursuant to the Virgin Islands Rules of Civil Procedure Rule 24, the Government has the statutory right and auth
************* IN THE MATTER OF THE ESTATE OF ) JEFFREY E. EPSTEIN, ) ) Deceased. ) ) PROBATE NO. ST-
************* IN THE MATTER OF THE ESTATE OF ) JEFFREY E. EPSTEIN, ) ) Deceased. ) ) PROBATE NO. ST-I
tion for Probate included Mr. Epstein's Last Will and 'Testament.' Id. Two days before his death, Mr. Epstein amended a previous trust, namely, The Jeffrey E. Epstein Trust and then created "The 1953 Trust" ("the Trust"). In addition to amending the Trust, Epstein also amended his Last Will and Testamcnt, so that all hi
provide services) and LSJ Emergency, LLC (registered December 2, 2015 to provide services). 85. Some of these companies held considerable assets: Financial Informatics, Inc. (incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of approximately $391 million in 2015; and Financial Trust
CUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN and ADMINISTRATOR OF THE 1953 TRUST; RICHARD D. KAHN, in his capacity as the EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN, and ADMINISTRATOR OF THE 1953 TRUST; ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPER
Page: EFTA00018779 →1953 TRUST; RICHARD D. KAHN, in his capacity as the EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN, and ADMINISTRATOR OF THE 1953 TRUST; ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, INC., SOUTHERN TRUST COMPANY, INC.; JOHN AND JANE DO
Page: EFTA00018779 →nd Cays, some of which are privately owned. Among these privately owned islands are Little St. James and Great St. James. 5. Jeffrey E. Epstein ("Epstein") was a resident of the Virgin Islands and he maintained a residence on Little St. James, which he acquired in 1998 and in 2016 he also purchased G
Page: EFTA00018780 →1-1 Filed 09/01/20 Page 3 of 55 GVI v. Estate of Jeffrey Epstein GVI's First Amended Complaint Page 2 of
Page: EFTA00018780 →Thomas and Little St. James. 37. Defendant Southern Trust Company, Inc. was originally incorporated in the Virgin Islands on November 18, 2011 as Financial Informatics, Inc., but changed its name to Southern EFTA00018785 --- PAGE BREAK --- Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 9 of 55 GVI v. Esta
Page: EFTA00018786 →Entities connected to both Jeffrey Epstein and Financial Informatics, Inc.

Richard Kahn
PERSONDarren Indyke
PERSONLarry Visoski
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
JPMorgan Chase
ORGANIZATION
Condoleezza Rice
PERSON
Glenn Dubin
PERSON
Jes Staley
PERSON
Prince Charles
PERSONSouthern District
LOCATIONJane Doe
PERSON
St Thomas
LOCATION
New York
LOCATIONSouthern Trust Company
ORGANIZATIONHBRK Associates
ORGANIZATION
U.S. Virgin Islands
LOCATION
Sarah Ferguson
PERSON
Palm Beach
LOCATION
Financial Trust Company
ORGANIZATION