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the time of his death. As the legal representatives of the Estate of Jeffrey E. Epstein, Darren K. Indyke and Richard D. Kahn are deemed citizens of the U.S. Virgin Islands, and jurisdiction in this Court is therefore proper. 28 U.S.C. § 1332(c)(2). 12. At all times material to the events alleged herein, Plaintiff res
e of Trust with the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn are the two Trustees of The 1953 Trust. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 68. On September 6, 2019, Magistrate
and is domiciled in the Southern District of New York. JURISDICTION AND VENUE 22. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at the time of his death. Jeffrey Epstein maintained a residence in the Southern District of New York. As the legal representatives of the Estate o
K. Indyke and Richard D. Kahn filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 38. Epstein's will was entered into
and is domiciled in the Southern District of New York. JURISDICTION AND VENUE 22. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at the time of his death. Jeffrey Epstein maintained a residence in the Southern District of New York. As the legal representatives of the Estate o
K. Indykc and Richard D. Kahn filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 38. Epstein's will was entered into
and is domiciled in the Southern District of New York. JURISDICTION AND VENUE 22. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at the time of his death. Jeffrey Epstein maintained a residence in the Southern District of New York. As the legal representatives of the Estate o
K. Indyke and Richard D. Kahn filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 38. Epstein's will was entered into
ppointed executor of the Estate of Jeffrey E. Epstein. JURISDICTION AND VENUE 19. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at the time of his death. Jeffrey Epstein maintained a residence in the Southern District of New York. As the legal representatives of the Estate o
K. Indyke and Richard D. Kahn filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019). 34. Epstein's will was entered into
Entities connected to both U.S. Virgin Islands and See Certificate of Trust

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
Richard Kahn
PERSON
New York
LOCATION
Les Wexner
PERSON
Palm Beach
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSON
Martha Stewart
PERSON
Jes Staley
PERSON
David Boies
PERSON
Southern District of New York
ORGANIZATION
United Kingdom
LOCATIONSuperior Court
ORGANIZATIONSigrid McCawley
PERSON
New Mexico
LOCATIONN.Y. Post
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION
New York Post
ORGANIZATION