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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
es to Defraud the Government and Fund its Criminal Activities 104. In October 2012, the Southern Trust Company applied for economic benefits from the Economic Development Commission ("EDC"). The EDC is a subsidiary of the Virgin Islands Economic Development Authority ("EDAM a semi-autonomous governmental instrumentality created
nt L STATE OF NEW YORK ) ACKNOWLEDGMENT COUNTY OF NEW YORK The foregoing ifISMIMetli was acknowledged before me this 20th day of March, 2013, by Jeffrey E. Epstein, who is personally known to me. HARRY I. BELLER Notary Public. S's ,I of nevi York No. 01131.1485.1924 Qualified in Rockland County /u , Commissi
Jeffrey E. Epstein is the initial investor in FSG. Identifying Information: Address: Date of Birth: 01/20/1953 Business History of Applicant Mr. Epstein's was educated at The Cooper Union for the Advancement of Science and Art. He began his business career in 1976 at Bear Stearns & Company. He subseq
ce heron is insufficient to answer any question fully.) IF ANSFP'ER IS "NO" OR `NONE", SO STATE. 1. Affiant's Full Name (Initials Not Acceptable) Jeffrey Edward Epstein 2. a. Have you ever had your name changed? No. If yes, give the reason for the change. b. Other names used at any time. 3. Affiant's Social
TA00128862 QUESTION 12 Directors And Officers Jeffrey E. Epstein, President Darren K Indyke, Secretary
TA00128862 QUESTION 12 Directors And Officers Jeffrey E. Epstein, President Darren K Indyke, Secretary R
Birth: 01/20/1953 Business History of Applicant Mr. Epstein's was educated at The Cooper Union for the Advanc
the Virgin Islands in 1999 when he opened Financial Trust Company, Inc. ("FTC"). FTC was a successful Virgin Islands business and a beneficiary of the Economic Development Commission ("EDC"). Mr. Epstein is also the sole shareholder of Southern Trust Company, Inc. ("SIC") which has been recommended for benefits from the EDC and
ledged before me this 20th day of March, 2013, by Jeffrey E. Epstein, who is personally known to me. Notary
ledged before me this 20th day of March, 2013, by Jeffrey E. Epstein, who is personally known to me. Notary
y of the Economic Development Commission CEDC"). Mr. Epstein is also the sole shareholder of Southern Trust Co
ce heron is insufficient to answer any question fully.) IF AIVSIVER IS 'WO" OR "NONE'', SO STATE. 1. Affiant's Full Name (Initials Not Acceptable) Jeffrey Edward Epstein 2. a. Have you ever had your name changed? No. If yes, give the reason for the change. b. Other names used at any time. 3. Affiant's Social
ffiant STATE OF NEW YORK ) ACKNOWLEDGMENT COUNTY OF NEW YORK The foregoing instrument was acknowledged before me this 20th day of March, 2013, by Jeffrey E. Epstein, who is personally known to me. Notary Public My Commission Expires: EFTA00294458
cial Trust Company, Inc. ("FTC"). FTC was a successful Virgin Islands business and a beneficiary of the Economic Development Commission CEDC"). Mr. Epstein is also the sole shareholder of Southern Trust Company, Inc. ("STC) which has been recommended for benefits from the EDC and is awaiting the signatu
ands EFTA00294453 in 1999 when he opened Financial Trust Company, Inc. ("FTC"). FTC was a successful Virgin Islands business and a beneficiary of the Economic Development Commission CEDC"). Mr. Epstein is also the sole shareholder of Southern Trust Company, Inc. ("STC) which has been recommended for benefits from the EDC and is
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
Criminal Activities 1. Defendant Southern Trust Company, Inc. 157. In October 2012, the Southern Trust Company applied for economic benefits from the Economic Development Commission ("EDC"). The EDC is a subsidiary of the Virgin Islands Economic Development Authority ("EDA"), a semi-autonomous governmental instrumentality creat
e, 18 Feb 2020 15:47:56 +0000 These are the paragraphs from the complaint that are the most specific allegations of complicity of the trustees: 17. Epstein maintained a deliberately complex web of Virgin Islands corporations, limited liability companies, foundations, and other entities, not all of which
ogram was to be designed to "establish an independent and voluntary claims resolution program for purposes of resolving sexual abuse claims against Jeffrey E. Epstein." (Motion, at 1). 91. The program proposed by the Estate, whose executors are trustees of The 1953 Trust and officers in at least two Epstein entit
urposes of resolving sexual abuse claims against Jeffrey E. Epstein." (Motion, at 1). 91. The program propo
urposes of resolving sexual abuse claims against Jeffrey E. Epstein." (Motion, at 1). 91. The program propos
"any person or entity arising from or related to Mr. Epstein's conduct." (Motion, at 5). It acts to conceal t
dyke and Kahn are Treasurer and Secretary of Sun Trust Company] 104. In October 2012, the Southern Trust Company applied for economic benefits from the Economic Development Commission ("EDC"). The EDC is a subsidiary of the Virgin Islands Economic Development Authority ("EDA"), a semi-autonomous governmental instrumentality creat
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 →"any person or entity arising from or related to Mr. Epstein's conduct." (Motion, at 5). It acts to conceal t
Page: EFTA00018796 →Entities connected to both Jeffrey Epstein and the Economic Development Commission

Richard Kahn
PERSONDarren Indyke
PERSONLarry Visoski
PERSON
Prince Andrew
PERSON
JPMorgan Chase
ORGANIZATION
Jes Staley
PERSONAndrew Farkas
PERSONJane Doe
PERSONMaria Farmer
PERSONErika Kellerhals
PERSONSouthern Trust Company
ORGANIZATION
Samantha Power
PERSON
U.S. Virgin Islands
LOCATION
Financial Trust Company
ORGANIZATIONHyperion Air
ORGANIZATION
Saint James
LOCATION
Vienna
LOCATION
St. Croix
LOCATION
Monaco
LOCATIONFirst Bank
ORGANIZATION