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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
nd costs; L. Award compensatory and punitive damages for Defendants' civil conspiracy; M. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; N. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 V.I.C.
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.
nd costs; L. Award compensatory and punitive damages for Defendants' civil conspiracy; M. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; N. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 14 V.I.
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
nd costs; L. Award compensatory and punitive damages for Defendants' civil conspiracy; M. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; N. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 14 V.I.
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.
nd costs; L. Award compensatory and punitive damages for Defendants' civil conspiracy; M. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; N. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 14 V.I.
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
nd costs; L. Award compensatory and punitive damages for Defendants' civil conspiracy; M. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; N. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 14 V.I.
ut was related to the affairs of the Epstein Enterprise in violation of CICO 14 V.I.C. §600 et seq. COUNT NINETEEN Sex Offender Registry-Estate of Jeffrey E. Epstein Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 a seq. and 14 V.I.C. § 1721 et seq. 354. The Government res
IEIRT1HIR fikozurreent3(611. FRI kitiOCIEIMME Figtige/36ailVZ'3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 35 of 76 with Epstein. Indyke was a signatory on Southern Trust's primary bank account to which funds were wired, primarily from a single source, as described below. Kahn
COUNT NINETEEN Sex Offender Registry-Estate of Jeffrey E. Epstein Violation of the Criminally Influenced
COUNT NINETEEN Sex Offender Registry-Estate of Jeffrey E. Epstein Violation of the Criminally Influenced a
nd costs; M. Award compensatory and punitive damages for Defendants' civil conspiracy; N. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; O. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 V.I.C.
ax benefits that had been bestowed on any Defendant; J. Pursuant to 14 V.I.C. §§ 607(a)(6) and 607(k), order all assets and funds of the Estate of Jeffrey E. Epstein be placed into receivership; K. Pursuant to 14 V.I.C. § 607(e), award the Government the maximum civil penalty for each and every violation of law
wful scheme. 385. These unlawful acts could not have been carried to the length and extent accomplished without the common understanding shared by Epstein and the Epstein Enterprise Defendants. 386. Each of the Defendants had a duty to report, stop or terminate the wrongful conduct, but instead each
(k), order all assets and funds of the Estate of Jeffrey E. Epstein be placed into receivership; K. Pursua
(k), order all assets and funds of the Estate of Jeffrey E. Epstein be placed into receivership; K. Pursuan
nd costs; M. Award compensatory and punitive damages for Defendants' civil conspiracy; N. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; O. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 V.I.C.
Entities connected to both Jeffrey Epstein and the The 1953 Trust

Richard Kahn
PERSONDarren Indyke
PERSONLarry Visoski
PERSON
Condoleezza Rice
PERSON
Jes Staley
PERSONSouthern District
LOCATION
New York
LOCATIONSouthern Trust Company
ORGANIZATION
U.S. Virgin Islands
LOCATION
Financial Trust Company
ORGANIZATIONHyperion Air
ORGANIZATIONLinda Pinto
PERSON
Hillary Clinton
PERSON
Saint James
LOCATION
Vienna
LOCATION
the United States District Court
ORGANIZATION
Washington D.C.
LOCATION
St. Croix
LOCATION
Monaco
LOCATION
St. John
LOCATION