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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
y. and by several of his affiliated businesses. including. but not limited to. the C.O.U.Q. Foundation. NES LLC. New York Strategy Group. JEGE: LLC. JEGE Inc.. and LSJ, LLC. 10. While under Epstein's employ. Maxwell was responsible for managing Epstein's properties. including properties located in New Y
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
rties located in Ne York. Paris, Florida. New \lexico. and the U.S. Virgin Islands. I I. During the course of their relationship. including while Maxwell was in Epstein's employ. Epstein promised Maxwell that he would support her financially. EFTA00094891 CIVIL CASE NO.: Page 3 of 10 12. Epstein
THOMAS AND ST. JOHN CIVIL CASE NO.: 012P'41-156. GHISLAINE MAXWELL, Plaintiff, vs. ESTATE OF JEFFREY E. E
was also employed by several of Epstein's other entities, including. but not limited to, the C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC, JEGE Inc.. and LSJ, LLC. 53. Upon information and belief, the corporate organizational documents or these other entities pro% riy!,.. of indcznHt Maxwe
I Beller Joseph P Dwyer Ghislaine Noelle Marion Maxwell Alan Morton Dershowitz Charles Garald Goldsmith
Darren K Indyke Harry I Beller Joseph P Dwyer Ghislaine Noelle Marion Maxwell Alan Morton Dershowitz Ch
Air LLC JEGE LLC Gratitude America Ltd Hyperion Air Inc I Correct COM LLC International Cahritable Interests J Epstein Foundation Jeepers Inc JEGE Inc LCP Company LLC LSJ LLC Maple Inc JEGE LLCMC2 Model Management Plan D LLC Southern Financial LLC Southern Trust Company Inc The Haze Trust Zor
Entities connected to both Ghislaine Maxwell and JEGE Inc

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSONDarren Indyke
PERSON
Les Wexner
PERSONLarry Visoski
PERSON
Prince Charles
PERSON
Samantha Power
PERSON
Alfredo Rodriguez
PERSON
U.S. Virgin Islands
LOCATION
Richard Kahn
PERSON
Martha Stewart
PERSON
Paul Morris
PERSON
Harvey Weinstein
PERSON
John Brennan
PERSON
Eric Holder
PERSON
Bear Stearns
ORGANIZATION