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219 GVI v. Estate of Jeffrey E. Epstein GVI's Complaint Page 5 of 48 Jeffrey Epstein as the sole member of L.S.J., LLC, which it acquired Little Saint James via a warranty deed dated April 27, 1998. 23. As described below, Epstein engaged in a pattern and practice of trafficking and sexually abusing y
tates Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 3 V.I.C. § 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of
f 49 GVI v. Estate of Jeffrey E. Epstein GVI's Complaint Page 5 of 48 Jeffrey Epstein as the sole member of L.S.J., LLC, which it acquired Little Saint James via a warranty deed dated April 27, 1998. 23. As described below, Epstein engaged in a pattern and practice of trafficking and sexually abusing y
tates Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 3 V.I.C. § 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of
ALL COUNTS 7. Juan-Pablo Molyneux is a world-renowned interior designer. . 8. Jeffrey Epstein, via his company L.S.J., LLC, is the owner of Little Saint James, a 70-acre island within the U.S. Virgin Islands. 9. In 2005, the parties entered into an agreement whereby the Plaintiffs would provide design ser
and Defendant can thereafter admit, or deny the specifics of same. Personal jurisdiction alleged through some subsection of the long-arm statute, 5 V.I.C. § 4903, over this non-resident Defendant was not affirmatively plead in the First Amended Complaint-it is argued in opposition to the Motion to Dism
00) and other good and valuable consideration." The quitclaim deed lists Jeffrey Epstein as the sole member of L.S.J., LLC, which it acquired Little Saint James via a warranty deed dated April 27, 1998. 25. As described below, Epstein engaged in a pattern and practice of trafficking and sexually abusing y
tates Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 3 V.I.C. § 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of
805 GV1 v. Estate of Jeffrey E. Epstein GVI's Complaint Page 5 of 48 Jeffrey Epstein as the sole member of L.S.J., LLC, which it acquired Little Saint James via a warranty deed dated April 27, 1998. 23. As described below, Epstein engaged in a pattern and practice of trafficking and sexually abusing y
tates Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 3 V.I.C. § 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of
00) and other good and valuable consideration." The quitclaim deed lists Jeffrey Epstein as the sole member of L.S.J., LLC, which it acquired Little Saint James via a warranty deed dated April 27, 1998. 26. As described below, Epstein engaged in a pattern and practice of trafficking and sexually abusing y
ations of Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges
00) and other good and valuable consideration." The quitclaim deed lists Jeffrey Epstein as the sole member of L.S.J., LLC, which it acquired Little Saint James via a warranty deed dated April 27, 1998. 26. As described below, Epstein engaged in a pattern and practice of trafficking and sexually abusing y
ations of Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges
Entities connected to both Saint James and V.I.C.

Jeffrey Epstein
PERSON
Richard Kahn
PERSON
Condoleezza Rice
PERSON
Marc Rich
PERSON
U.S. Virgin Islands
LOCATIONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
New York
LOCATION
George W. Bush
PERSON
United States
LOCATIONLarry Visoski
PERSON
Sarah Kellen
PERSONDaphne Wallace
PERSON
St Thomas
LOCATION
Palm Beach
LOCATION
Sarah Ferguson
PERSON
Prince Andrew
PERSONthe Southern District
LOCATIONLeon Black
PERSONL.S.J.
ORGANIZATION