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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
ing regulations is to give law enforcement real-time information so that it can act to detect violations of the law and protect public safety. 89. The Government of the Virgin Islands did not know, and could not have known, that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind eye t
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
thern Trust Company. 38. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 39. The Attorney General brings this action to seek all remedies a
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
ing regulations is to give law enforcement real-time information so that it can act to detect violations of the law and protect public safety. 89. The Government of the Virgin Islands did not know, and could not have known, that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind eye t
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
ing regulations is to give law enforcement real-time information so that it can act to detect violations of the law and protect public safety. 89. The Government of the Virgin Islands did not know, and could not have known, that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind eye t
VIRGIN ISLANDS )ss: DISTRICT' OF ST. THOMAS & ST. JOHN On this the / day of _4 , 2012, before me /3ear the undersigned, personally appeared Jeffrey E. Epstein and Darren Indy who acknowledged themselves to be the President and Secretary of Laurel, Inc., a U.S. Virgin Islands Corporation, and as being auth
MADE IN TAO ArPuCATION Alf SiBACT 70 NWEITCABON AND NAT AM PASSE OR DISNON GPO's DIMAS ORSUµEOUEIII BEVOCMIOH 04 REGISTRADON. IS/a3 ) OM 17 NE Jeffrey Epstein PRINTED FIRST NAME AAD LAST NANE • EDE LAST REPORT OCRS HOE COWS NE PERIOD lAvAEC4ATELY PRECIDREG DEE REPOLI RESOD COVERED BY MS REPORT. A SuFPLEF
of. Cwporare Seal \CC' usoic- ` Laurel, Inc. Jeffrey E. Epste haitAttA.. a 1/2 9 k_ Darren Indyke, Se
S APPLICATION ARE NIRO TO TICIESTIGADON MO T ANY FALSE a CONONESI MIMI TO ANY MINION MAY II V OR SU AMMO et I DON OT REGISIRATION. balikkay SI E Jeffrey E4:eteln PRwTED MGT 1St AND LAST NAME RRZ cole3o(tit . IF THE LAP REPORT DOES NCI COVER THE PEP400 IMMECTARLY PREOECING THE REPORT PERKO COVERED by D
the undersigned, personally appeared Jeffrey E. Epstein and Darren Indy who acknowledged themselves to b
Is for the hood Ended lone )06 2013 1000 Ham corse• mock I 01 pa ...Ment/ThittlItTI.FITIt s 0 rn ' 3 <0 • rrl Arri (Attach checks payable to The Government of the Virgin Islands sad mall documents Is the Offlee of the Lieutopat goseracticti tMsloa of Corporation sad Trademarks, I I, St. Thomas, VI 00802-64$7.) 0 „--‘sident
L DIRECTORS AND OFFICERS Of THE CORPORATION AT THE CLOSE Of FISCAL YEAR ANDEXPIRATION DATES OF TERMS Of OffICE - NAME/HIE ADDRESS TERM EXPIRATION Jeffrey E Epstein, President/Director Serves until successor elected , St. Thomas, USVI 00802 Richard Kahn,Treasurer/Director Serves unhl successor elected , New
GATION GROUNDS ERR PIRAL OR SlifSIQUENT RE Of REGISTRATION SiGNAPJ Richard Kahn r.,14 0/v PRIMED REST NAME MO LAST NAME PRETroforf SIGNATURE Jeffrey Epstein TA/St OR OISMTHEST A3RTWER TO ANY ouesnoN MAY IN PRINTED ARSE NAME APO LAST NAME Rita 6o1 IMIE F DC LAST REPORT DOES HOT COVER THE PERIM IMATIOIATUY
- NAME/HIE ADDRESS TERM EXPIRATION Jeffrey E Epstein, President/Director Serves until successor elect
EST TOTAL PMD-IN CAPITAL STOCK AS REPORTED ON UNE JE ABOVE B. TAX DUE OA OR SI50.00 (WHICHEVER 5 GRE
Of OffICE - NAME/HIE ADDRESS TERM EXPIRATION Jeffrey E Epstein, President/Director Serves until success
6 S c. Total Pellet), And Interest. Co " 6) TOTAL DUE AND FORWARDED HEREWITH (Sum of (4) (b) and (5) (c) ti 1r4rn (Attach cheeks payable to The Government of the Virgin Islands and mall documents to the Office of the Lieu tenadcrovernor, DWIsion of Corporation and Trademarks, St. Thomas, VI 001101-6487.) President EFTA00
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.
d Little St. James. 35. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 36. The Attorney General brings this action to seek all remedies a
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
d Little St. James. 35. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 36. The Attorney General brings this action to seek all remedies a
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.
d Little St. James. 35. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 36. The Attorney General brings this action to seek all remedies a
ANDS )ss: DISTRICT OF ST. THOMAS & ST. JOHN On this the / day of s0 , 2012, before me r' rty fie/Ar the undersigned, personally appeared Jeffrey E. Epstein and Darren Indykiwho acknowledged themselves to be the President and Secretary of Maple, Inc., a US. virgin islands Corporation, and as being author
OF OFfICE - NAME/TIRE ADORESS TERM EXPIRATION Jeffrey E Epstein, President/Dr/IC/Of 6100 Red Hook Quarter
ICSI MAY II GRUNNS 1 0* »KNEPRA« nOti Of il*GISTIUUTOIL IMAILIMI MAI TOMAT/RE Richard Klim AR ~ED ARS, mimt AND LAST ~E SIGNAIJRE klitTOY Fystein te, to(Ita DATE PESA@ FIRST ~Æ IND LAST NieME • P MI LAST REPORT DOCS NOT COVER THE PERCO PMEOLAItlY PRECECTC tHE «PM ~OD COvEREO SY TH6 REPCM. A
- NAME/TIRE ADORESS TERM EXPIRATION Jeffrey E Epstein, President/Dr/IC/Of 6100 Red Hook Quarter, B3. St
and approval thereof. Celan* Seal Maple, Inc. Jeffrey E. EpsLitm, President Darren Indyke, Secretary -
And Interest. i $ . -- 0 01 n5 - e - 6) TOTAL WE AND FORWARDED HEREWITH (Sam of (4) (b) and (5) (c) ---1 rtri (Attach cants canto payable to The Government of the Virgin Islands and mall documents to the Office of the lieutetaattportnior. Division of Corporatist sad Trademarks, 5049 Kongens Gado, St. Thomas, VI 00802-6487.)
Entities connected to both Jeffrey Epstein and The Government of the Virgin Islands

Richard Kahn
PERSONDarren Indyke
PERSONLarry Visoski
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
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