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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
Trust; of companies holding Epstein's real property (as laid out below); and of ; FT Real Estate Inc.; Gratitude America, Inc.; J. Epstein Virgin Islands Foundation, Inc.; Jeepers, Inc.; Mort, Inc.; Nautilus, Inc.; and Zorro Development Corporation: among others. 81. Along with their officer and director roles, Defe
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
Trust; of companies holding Epstein's real property (as laid out below); and of ; FT Real Estate Inc.; Gratitude America, Inc.; J. Epstein Virgin Islands Foundation, Inc.; Jeepers, Inc.; Mort, Inc.; Nautilus, Inc.; and Zorro Development Corporation; among others. 81. Along with their officer and director roles, Defe
the Board of Trustees created by Ms. de Jongh's and Ms. Brenna's resignations; NOW, THEREFORE, BE IT RESOLVED, that effective as of March 1, 2012, Jeffrey E. Epstein and Erika Kellerhals be, and each of them hereby is, appointed as a Trustee of the Corporation, each to serve as such until such time as such perso
y 29, 2012 To: The Board of Trustees of The J. Epstein Virgin Islands Foundation, Inc (a/k/a Enhanced E
uary 29, 2012 To: The Board of Trustees of The J. Epstein Virgin Islands Foundation, Inc (a/k/a Enhanced E
IT RESOLVED, that effective as of March 1, 2012, Jeffrey E. Epstein and Erika Kellerhals be, and each of th
IT RESOLVED, that effective as of March 1, 2012, Jeffrey E. Epstein and Erika Kellerhals be, and each of the
J. EPSTEIN VIRIGIN ISLANDS FOUNDATION, INC. (a/k/a ENHANCED EDUCATION) The undersigned, being the sole remaining Trustee of The J. Epstein Virgin Islands Foundation, Inc., a United States Virgin Islands corporation, a/k/a Enhanced Education (the "Corporation"), in lieu of holding a meeting, does hereby adopt the foll
the Board of Trustees created by Ms. de Jongh's and Ms. Brenna's resignations; NOW, THEREFORE, BE IT RESOLVED, that effective as of March 1, 2012, Jeffrey E. Epstein and Erika Kellerhals be, and each of them hereby is, appointed as a Trustee of the Corporation, each to serve as such until such time as such perso
the Corporation pursuant to the immediately preceding resolution, be, and each of them hereby is, removed from office. Dated as of: March 1, 2012 Jeffrey E. E 1 )IIIALIZAA_ Darren K Indyke Erika Kellerhals 2 EFTA00311092 FURTHER RESOLVED, that all persons serving as officers of the Corporation that we
J. Epstein Virgin Islands Foundation, Inc. (a/k/a Enhanced
J. Epstein Virgin Islands Foundation, Inc. (a/k/a Enhanced
29, 2012. 3. Consent of Sole Trustee Electing Jeffrey Epstein and Erika Kellerhals as Directors, effec
J. EPSTEIN VIRIGIN ISLANDS FOUNDATION, INC. (a/k/a ENHANCED EDUCATION) The undersigned, being the sole remaining Trustee of The J. Epstein Virgin Islands Foundation, Inc., a United States Virgin Islands corporation, a/k/a Enhanced Education (the "Corporation"), in lieu of holding a meeting, does hereby adopt the foll
Islands 00802 April 10, 2012 Ms. Tam Bowers Customer Service Representative Platinum Dear Ms. Bowers: The Corporation authorizes you to add Mr. Jeffrey Epstein, President, as an additional signatory on the following account. Name: J. Epstein Vir in Islands Foundation, Inc. tia Enhanced Education Number:
J. Epstein Virgin Islands Foundation, Inc. 6100 Red Hook Qu
J. Epstein Virgin Islands Foundation, Inc. 6100 Red Hook Qu
owers: The Corporation authorizes you to add Mr. Jeffrey Epstein, President, as an additional signatory o
The Corporation authorizes you to add Mr. Jeffrey Epstein, President, as an additional signatory on the following account. Name: J. Epstein Vir in Islands Foundation, Inc. tia Enhanced Education Number: Your assistance in this matter is greatly appreciated. Sincerely, Darren K. Indyke Vice President EFTA00311079
120 Broadway, 3rd Floor New York, NY 10271 RE: Jeffrey Epstein VI Foundation Registration with the NY Attorney
dway, 3rd Floor New York, NY 10271 RE: Jeffrey Epstein VI Foundation Registration with the NY Attorney
d your letter dated March 2, 2015 requesting that J. Epstein Virgin Islands Foundation, Inc. (the "Foundation
120 Broadway, 3rd Floor New York, NY 10271 RE: Jeffrey Epstein VI Foundation Registration with the NY A
y General's Charities Rorean Dear Assistant Attorney General Goldman: I received your letter dated March 2, 2015 requesting that J. Epstein Virgin Islands Foundation, Inc. (the "Foundation") file a Form CHAR 410 and Schedule E thereto in order for the Charities Bureau to confirm the Foundation's exemption from registr
90, day of September, 2017, by and between the J. Epstein Virgin Islands Foundation, Inc., a/k/a Enhanced
he 90, day of September, 2017, by and between the J. Epstein Virgin Islands Foundation, Inc., a/k/a Enhanced
AGREEMENT AGREEMENT, made as of the 90, day of September, 2017, by and between the J. Epstein Virgin Islands Foundation, Inc., a/k/a Enhanced Education, a USVI non-profit corporation (the "Enhanced Education"), and Yoed Nir, residing at (the "Ni?'). WITNESSETH: WHEREAS,
Entities connected to both Jeffrey Epstein and Islands Foundation, Inc.

Richard Kahn
PERSONDarren Indyke
PERSONLarry Visoski
PERSON
United States
LOCATION
JPMorgan Chase
ORGANIZATION
Condoleezza Rice
PERSON
Glenn Dubin
PERSON
Jes Staley
PERSON
Prince Charles
PERSONSouthern District
LOCATIONJane Doe
PERSONErika Kellerhals
PERSON
New York
LOCATIONSouthern Trust Company
ORGANIZATIONHBRK Associates
ORGANIZATION
U.S. Virgin Islands
LOCATION
John Brennan
PERSON
Palm Beach
LOCATION
Financial Trust Company
ORGANIZATION
Deutsche Bank
ORGANIZATION