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stein. The co-conspirators who benefitted 107 EFTA00162227 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 108 of 130 financially include Ghislaine Maxwell, Lesley Grog Sarah Kellen, Adriana Ross, and Nadia Marcinkova. 412. Acting through its officers and employees (including Staley), JP Morgan itself
co-conspirator, Ghislaine Maxwell, for conspiracy to entice minor victims to travel to be abused by Epstein. The federal criminal investigation of Maxwell included investigation of possible 122 EFTA00162242 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 123 of 130 violations of the TVPA. 4
led 01/13/23 Page 108 of 130 financially include Ghislaine Maxwell, Lesley Grog Sarah Kellen, Adriana Ross,
ndicted Epstein (and unnamed "associates") for violating the TVPA. Later, on about June 29, 2020, the same Office indicted Epstein's co-conspirator, Ghislaine Maxwell, for conspiracy to entice minor victims to travel to be abused by Epstein. The federal criminal investigation of Maxwell included investigation of p
Indyke and Kahn filed a Petition for Probate and Letters Testamentary which included Epstein's last will and testament with the Probate Division of the Superior Court of the Virgin Islands. 12. The Petition reported the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 13
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN CIVIL CASE NO.: ‘51t 3DS . )56 GHISLAINE MAXWELL, Plaintiff, vs. ESTATE OF JEFFREY E. EPSTEIN. DARREN K. INDYKE, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY E. EPSTEIN, RICHAR
ESTATE OF JEFFREY E. EPSTEIN, and NES, LLC. a New York Limited Liability Company. Defendants. 18f103 ):101213dflS COMPLAINT Plaintiff GHISLAINE MAXWELL (-Maxwell.), through her undersigned attorneys. by ‘‘a) of her Complaint against Defendants is STA OF JEI FREY I.. LPSTLIN (the "Estate"). DARREN
suit, proceeding, or investigation relating to Epstein, his affiliated businesses, and his alleged victims. PARTIES AND JURISDICTION 2. Plaintiff Ghislaine Maxwell is an adult citizen of the United States. 3. Jeffrey E. Epstein was a resident of the Virgin Islands. The Estate of Jeffrey E. Epstein was created
New York. 24. On August 15. 2019. Indyke and Kahn filed a petition for probate of Epstein's last will and tostninent with thu Probate Division of the Superior Court of the Virgin Islands. Division of St. Thomas and St. John. 25. Maxwell has incurred and will continue to incur significant legal ices. personal security costs, and ot
ly on Epstein, he would only cause them more and more harm. 44. As demonstrated by the above, Epstein treated the girls he abused in the same way Ghislaine Maxwell, his co-conspirator, viewed them: like "they[] [were] nothing, these girls," like "[t]hey [we]re trash." Epstein's Abuse of Doe Was Directly and In
ed the girls he abused in the same way Ghislaine Maxwell, his co-conspirator, viewed them: like "they[] [w
tein treated the girls he abused in the same way Ghislaine Maxwell, his co-conspirator, viewed them: like "t
ner concluded Epstein died by suicide. 64. On August 15, 2019, Epstein's last will and testament (the "Will") was filed in the Probate Division of the Superior Court of the Virgin Islands. 65. The Will indicated that it was executed by Epstein on August 8, 2019 at the Metropolitan Correctional Center, and that it was witnessed by Ma
F NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defendants. Case No. COMPLAINT FOR DAMAGES DEMAND FOR JURY TRIAL Plaintiff Jane Doe ("Doe" or "Plaintiff") alleges as follows:
le and convicted sex offender Jeffrey Epstein ("Epstein"). It all started in when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a summer camp in Michigan. Jane Doe was their first known victim and was subsequently abused by Epstein and Maxwell for years as a girl, suff
executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defendants. Case No. C
ner concluded Epstein died by suicide. 28. On August 15, 2019, Epstein's last will and testament (the "Will") was filed in the Probate Division of the Superior Court of the Virgin Islands. 29. The Will indicated that it was executed by Epstein on August 8, 2019 at the Metropolitan Correctional Center. The Will was accompanied by aff
ally, on that date, the U.S. Court of Appeals for the Second Circuit unsealed approximately 2,000 pages of documents in civil litigation involving Ghislaine Maxwell, who was later convicted in December 2021 of conspiring with Epstein to sexually abuse minors over the course of a decade. The documents contain
gs from a defamation lawsuit filed by Virginia Roberts Giuffre, a woman who alleged that Epstein had victimized her when she was a teenager, against Ghislaine Maxwell.31 As a result of the court’s order, that same day approximately 2,000 pages of documents were released into the public domain, which cont
also named in the released documents. There was significant media coverage of information contained within the unsealed court filings. 31 Maxwell was subsequently indicted and, in December 2021, convicted of conspiring with Epstein to sexually abuse minors. 51 III. Transfer of Epstein
he Office of the Inspector General (OIG) confirmed via court records that the August 8, 2019 will and other probate-related documents were filed in the Superior Court of the Virgin Islands on August 15, 2019. Among the court filings was an affidavit from another attorney who stated that she received the August 8, 2019 will from Epstei
ally, on that date, the U.S. Court of Appeals for the Second Circuit unsealed approximately 2,000 pages of documents in civil litigation involving Ghislaine Maxwell, who was later convicted in December 2021 of conspiring with Epstein to sexually abuse minors over the course of a decade. The documents contain s
res were also named in the released documents. There was significant media coverage of information contained within the unsealed court filings. 31 Maxwell was subsequently indicted and, in December 2021, convicted of conspiring with Epstein to sexually abuse minors. 50 EFTA01656764 III. Transfer o
pages of documents in civil litigation involving Ghislaine Maxwell, who was later convicted in December 202
he Office of the Inspector General (OIG) confirmed via court records that the August 8, 2019 will and other probate-related documents were filed in the Superior Court of the Virgin Islands on August 15, 2019. Among the court filings was an affidavit from another attorney who stated that she received the August 8, 2019 will from Epstein
ally, on that date, the U.S. Court of Appeals for the Second Circuit unsealed approximately 2,000 pages of documents in civil litigation involving Ghislaine Maxwell, who was later convicted in December 2021 of conspiring with Epstein to sexually abuse minors over the course of a decade. The documents contain s
e summary judgment filings from a defamation lawsuit filed b a woman who alleged that Epstein had victimized her when she was a teenager, against Ghislaine Maxwell.3' As a result of the court's order, that same day approximately 2,000 pages of documents were released into the public domain, which conta
res were also named in the released documents. There was significant media coverage of information contained within the unsealed court filings. 31 Maxwell was subsequently indicted and, in December 2021, convicted of conspiring with Epstein to sexually abuse minors. 50 EFTA00039081 III. Transfer o
he Office of the Inspector General (OIG) confirmed via court records that the August 8, 2019 will and other probate-related documents were filed in the Superior Court of the Virgin Islands on August 15, 2019. Among the court filings was an affidavit from another attorney who stated that she received the August 8, 2019 will from Epstein
r Horizon oil spill, Deputy Administrator of the GM Ignition Switch Compensation Program and Deputy
The Executors, Darren Indyke and Richard Kahn, filed a Petition for Probate and 1 EFTA00074744 Letters Testamentary with the Probate Division of the Superior Court of the Virgin Islands on August 15, 2019. Id. 8. The Petition for Probate included Mr. Epstein's Last Will and 'Testament.' Id. Two days before his death, Mr. Epstein a
r Horizon oil spill, Deputy Administrator of the GM Ignition Switch Compensation Program and Deputy
ates Virgin Islands under Chapter 30 of the Virgin Islands Code, namely, the Criminally Influenced and Corrupt Organizations Act (MO), is pending in the Superior Court of the Virgin Islands naming the ESTATE OF JEFFREY E. EPSTEIN; THE 1953 TRUST; PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC.; AND POLAR, INC. as de
Entities connected to both Ghislaine Maxwell and the Superior Court of the Virgin Islands

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
JPMorgan Chase
ORGANIZATIONSouthern District
LOCATION
United States
LOCATION
George W. Bush
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Donald Trump
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Eric Trump
PERSONDarren Indyke
PERSON
Virginia Giuffre
PERSON
New York
LOCATION
Les Wexner
PERSONFBI
ORGANIZATIONJane Doe
PERSON
Denver
LOCATIONLarry Visoski
PERSON