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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
EL, INC.; AND JOHN AND JANE DOES, DEFENDANTS. Case No.: ST-20-CV-14 ACTION FOR DAMAGES JURY TRIAL DEMANDED SECOND AMENDED COMPLAINT COMES NOW, the Government of the United States Virgin Islands ("Government") and files this Second Amended Complaint containing information that has become known through further investigation and third-party d
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
RUST COMPANY, INC.; JOHN AND JANE DOES DEFENDANTS, Case No.: ACTION FOR DAMAGES JURY TRIAL DEMANDED C- . : FIRST AMENDED COMPLAINT COMES NOW, the Government of the United States Virgin Islands ("Government") and files this First Amended Complaint against the above-named Defendants and in support thereof, would show unto the Court as follo
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
EL, INC.; AND JOHN AND JANE DOES, DEFENDANTS. Case No.: ST-20-CV-14 ACTION FOR DAMAGES JURY TRIAL DEMANDED SECOND AMENDED COMPLAINT COMES NOW, the Government of the United States Virgin Islands ("Government") and files this Second Amended Complaint containing information that has become known through further investigation and third-party d
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.
NC.; HYPERION AIR, LLC; POPLAR, INC., JOHN AND JANE DOES DEFENDANTS, Case No.: ACTION FOR DAMAGES JURY TRIAL DEMANDED 01 COMPLAINT COMES NOW, the Government of the United States Virgin Islands ("Government") and files this Complaint against the above-named Defendants and in support thereof, would show unto the Court as follows: JURISDICT
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
S, INC.; HYPERION AIR, LLC; POPLAR, INC., JOHN AND JANE DOES DEFENDANTS, Case No.: ACTION FOR DAMAGES JURY TRIAL DEMANDED COMPLAINT COMES NOW, the Government of the United States Virgin Islands ("Government") and files this Complaint against the above-named Defendants and in support thereof, would show unto the Court as follows: JURISDICT
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.
C.; HYPERION AIR, LLC; POPLAR, INC., JOHN AND JANE DOES DEFENDANTS, Case No.: ACTION FOR DAMAGES JURY TRIAL DEMANDRD rs COMPLAINT COMES NOW, the Government of the United States Virgin Islands ("Government") and files this Complaint against the above-named Defendants and in support thereof, would show unto the Court as follows: JURISDICT
), and the authority of the Court to administer proceedings before it, for approval of an agreed- upon protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videorecorded materials and photographs in the possession, custody, or control of the Epstein Estate (the "Epstein
o assume that [there was possible] interstate transmission of child pornography...that could have changed the entire complexion of the case against Epsteinf OPR Report, p. 176. Six computer hard drives were suspiciously missing from Epstein's Florida home just before a police raid--leaving dangling wire
- investigation-into-the-u-s-attorney-s-office-for-the-southern-district-of- florida-s-resolution-of-its-2006-2008-federal-criminal-investigation-of- jeffrey-epstein-and-its-interactions-with-victims-during-the- investigation/db9373e8-22f8-4712-b4a7-be844d162de0/, p. iv. As acknowledged in the OPR Report, law enforce
on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videor
on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videore
EOMATERIALS AND PHOTOGRAPHS FOR THE PRESENCE OF POTENTIAL CHILD SEX ABUSE MATERIALS AND FOR DISCLOSURE OF THOSE MATERIALS Plaintiffs Jane Doe 1 and the Government of the United States Virgin Islands ("Government"), by their respective counsel, move pursuant to Federal Rules of Civil Procedure 26(c), and the authority of the Court to administer
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
, INC.; HYPERION AIR, LLC; POPLAR, INC'., JOHN AND JANE DOES DEFENDANTS. Case No.: ACTION FOR DAMAGES JURY TRIAL DEMANDED COMPLAINT COMES NOW, the Government of the United States Virgin Islands ("Government") and files this Complaint against the above-named Defendants and in support thereof. would show unto the Court as follows: JURISDICT
), and the authority of the Court to administer proceedings before it, for approval of an agreed- upon protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videorecorded materials and photographs in the possession, custody, or control of the Epstein Estate (the "Epstein
s meant to include Responsive Media that may consist of movies or You Tube videos, for example, but does not extend to Responsive Media relating to Epstein activities or properties that may have been publicly disclosed at any time. 2 In this motion, the parties use the term "child sex abuse imagery" or
on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videor
on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videore
EOMATERIALS AND PHOTOGRAPHS FOR THE PRESENCE OF POTENTIAL CHILD SEX ABUSE MATERIALS AND FOR DISCLOSURE OF THOSE MATERIALS Plaintiffs Jane Doe 1 and the Government of the United States Virgin Islands ("Government"), by their respective counsel, move pursuant to Federal Rules of Civil Procedure 26(c), and the authority of the Court to administer
From: Cecile de Jongh To: "Jeffrey E." <[email protected]> Cc: Jeanne Brennan -te
From: Cecile de Jongh To: "Jeffrey E." <[email protected]> Cc: Jeanne Brennan -
outside the Territory of the Virgin Islands or in an election district other than that in which he is registered; or (ii) an officer or employee of the Government of the United States Virgin Islands or the Government of the United States assigned to official duties outside of the election district in which he is registered; or (iii) the spouse
Entities connected to both Jeffrey Epstein and the Government of the United States Virgin Islands

Richard Kahn
PERSONDarren Indyke
PERSONLarry Visoski
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATION
JPMorgan Chase
ORGANIZATION
Condoleezza Rice
PERSON
Glenn Dubin
PERSON
Jes Staley
PERSON
Prince Charles
PERSONSouthern District
LOCATIONJane Doe
PERSON
New York
LOCATIONSouthern Trust Company
ORGANIZATIONHBRK Associates
ORGANIZATION
U.S. Virgin Islands
LOCATIONFBI
ORGANIZATION