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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
d to, making fraudulent claims upon the Government. 291. The Epstein Enterprise misrepresented the purpose, activities, employment, and income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epstei
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
d to, making fraudulent claims upon the Government. 392. The Epstein Enterprise misrepresented the purpose, activities, employment, and income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epste
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
d to, making fraudulent claims upon the Government. 392. The Epstein Enterprise misrepresented the purpose, activities, employment, and income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epste
Entities connected to both Jeffrey Epstein and the Southern Trust Company, Inc.

Richard Kahn
PERSONDarren Indyke
PERSON
Condoleezza Rice
PERSON
Jes Staley
PERSONSouthern District
LOCATION
New York
LOCATIONSouthern Trust Company
ORGANIZATION
U.S. Virgin Islands
LOCATIONLinda Pinto
PERSON
Hillary Clinton
PERSON
the United States District Court
ORGANIZATION
Vienna
LOCATION
Washington D.C.
LOCATION
Monaco
LOCATION
Apple
ORGANIZATION
Marla Maples
PERSON
El Brillo Way
LOCATIONV.I.C.
ORGANIZATIONLaurel, Inc.
ORGANIZATIONWilmerHale
ORGANIZATION