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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
. 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 Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14
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
man Trafficking Act, 14 V.I.C. §131 et seq, and violates CICO, enacted to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14 V
s Consumer 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
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
was that, although the Bank properly classified Mr. Epstein as high-risk, the Bank failed to scrutinize the a
. 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 Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14
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
. 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 Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14
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.
man Trafficking Act, 14 V.I.C. §131 et seq, and violates CICO, enacted to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14 V
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
man Trafficking Act, 14 V.I.C. §131 er seq, and violates CICO, enacted to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14 V
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.
man Trafficking Act, 14 V.I.C. §131 et seq, and violates CICO, enacted to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14 V
CIVIL NO. /2010 BREACH OF CONTRACT v. ) ) JEFFREY EPSTEIN, ) JURY TRIAL DEMANDED ) Defendant.
AS AND ST. JOHN ) J.P. MOLYNEUX STUDIO, LTD. and ) JUAN PABLO MOLYNEUX, ) ) Plaintiffs, ) ) CIVIL NO. /2010 BREACH OF CONTRACT v. ) ) JEFFREY EPSTEIN, ) JURY TRIAL DEMANDED ) Defendant. ) COMPLAINT Plaintiffs, J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux, complaining of the defendant,
000 in the performance of their obligations under the contract. 8. From the start of plaintiffs' performance of the terms of the contract, defendant Epstein acted in bad faith and unfairly to unreasonably and successfully frustrate and obstruct plaintiffs' performance, making it impossible for plaintiff
ntiffs' performance of the terms of the contract, defendant Epstein acted in bad faith and unfairly to unreasonably
domiciled in the State of New York. 3. Upon information and belief, defendant Jeffrey Epstein, at all times hereinafter mentioned was domiciled in the Territory of the Virgin Islands. 4. This court has original jurisdiction of this action because the amount in controversy exceeds $75,000, exclusive of costs and interests, and th
, U.S. Virgin Islands (the "Marina"). EFTA00798408 Case: 3:18-cv-00069 Document #: 1 Filed: 09/04/18 Page 2 of 4 COMPLAINT Crown Bay Marino,. v. Epstein Page 2 5. Upon information and belief, Defendant Jeffrey Epstein & Michelle's Transportation Company, LLC is a limited liability company authorize
Islands CROWN BAY MARINA, M. Plointiff(s) V. JEFFREY EPSTEIN & MICHELLE'S TRANSPORTATION COMPANY, LLC, AND BI
Islands CROWN BAY MARINA, M. Plointiff(s) V. JEFFREY EPSTEIN & MICHELLE'S TRANSPORTATION COMPANY, LLC
able attorney's fees and expenses incurred by Crown Bay Marina in defending against any such suit. I agree that this agreement is being entered into the Territory of the Virgin Islands, and the laws of the Virgin Islands shall govern its terms and conditions. I agree that if any term or conditions is found to be invalid under the l
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 Territory of the Virgin Islands

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
PERSONMaria Farmer
PERSON
Alfredo Rodriguez
PERSON
New York
LOCATIONSouthern Trust Company
ORGANIZATION
Samantha Power
PERSONHBRK Associates
ORGANIZATION
U.S. Virgin Islands
LOCATION
Palm Beach
LOCATION