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tein was required to register annually with the Virgin Islands Department of Justice ("VIDOJ") and give advance notice of his travel to and from the Virgin Islands. Epstein was also subject to random address verification by VIDOJ. 7. Epstein was found dead on August 10, 2019 while in custody in New York for se
trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the U.S. Virgin Islands. III. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Eps
rs of The Estate, Darren K. Indyke and 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. 9. The Petition reports the value of the real and personal property in The Estate located in the Virgin
tein was required to register annually with the Virgin Islands Department of Justice ("VIDOJ") and give advance notice of his travel to and from the Virgin Islands. Epstein was also subject to random address verification by VIDOJ. 7. Epstein was found dead on August 10, 2019 while in custody in New York for se
trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the U.S. Virgin Islands. 111. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Eps
, Darren K. Indyke and Richard D. 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. 9. The Petition reports the value of the real and personal property in The Estate located in the Virgin
tein was required to register annually with the Virgin Islands Department of Justice ("VIDOJ") and give advance notice of his travel to and from the Virgin Islands. Epstein was also subject to random address verification by VIDOJ. 7. Epstein was found dead on August 10, 2019 while in custody in New York for se
d divesting in favor of the Government of the Virgin Islands all of Defendants' interests in any real and personal property within the territory of the U.S. Virgin Islands used to facilitate the criminal enterprise carried out by the Epstein Enterprise, including but not limited to Little St. James Island and Greater
in GVI's First Amended Complaint Page 3 of 55 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. 11. The Petition reports the value of the real and personal property in The Estate located in the Virgin
tein was required to register annually with the Virgin Islands Department of Justice ("VIDOJ") and give advance notice of his travel to and from the Virgin Islands. Epstein was also subject to random address verification by VIDOJ. 7. Epstein was found dead on August 10, 2019 while in custody in New York for se
trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the U.S. Virgin Islands. 111. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Eps
, Darren K. Indyke and Richard D. 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. 9. The Petition reports the value of the real and personal property in The Estate located in the Virgin
t concealed, assisted and furthered the wrongful acts by use of civil conspiracy. 272. As a direct and proximate result of Defendants' conspiracy, the Virgin Island has been injured. 273. Each co-conspirator is jointly and severally liable for the acts alleged herein. EFTA00074816 GVI v. Estate of Jeffrey E
trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the U.S. Virgin Islands. III. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Eps
e Estate") was created. 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.
filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey Epstein ("Epstein"), under the Virgin Islands' Criminally Influenced and Corrupt Organizations Act ("CICO Act"), see Government of the U.S. Virgin Islands v. Indyke et at, Case No. ST-20- CV-14 (
ial benefits that JP Morgan received for participating in and facilitating Epstein's sex-trafficking venture was the deposit of funds that Epstein—a Virgin Islands resident—and Epstein-controlled entities located in the Virgin Islands made to JP Morgan. JP Morgan profited from the use of these deposits. Epstein
st 15, 2019, Defendants 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 Virgi
filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey Epstein ("Epstein"), under the Virgin Islands' Criminally Influenced and Corrupt Organizations Act ("CICO Act"), see Government of the U.S. Virgin Islands v. Indyke et at, Case No. ST-20- CV-14 (
ial benefits that JP Morgan received for participating in and facilitating Epstein's sex-trafficking venture was the deposit of funds that Epstein—a Virgin Islands resident—and Epstein-controlled entities located in the Virgin Islands made to JP Morgan. JP Morgan profited from the use of these deposits. Epstein
st 15, 2019, Defendants 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 Virgi
Entities connected to both U.S. Virgin Islands and the Probate Division of

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Richard Kahn
PERSON
Financial Trust Company
ORGANIZATION
New York
LOCATION
Les Wexner
PERSONSouthern Trust Company
ORGANIZATION
Palm Beach
LOCATIONJane Doe
PERSON
St. Croix
LOCATION
JPMorgan Chase
ORGANIZATIONLarry Visoski
PERSON
Jes Staley
PERSON
Prince Charles
PERSON
Deutsche Bank
ORGANIZATIONVirgin Islands Department of Justice
ORGANIZATION
Apple
ORGANIZATIONSouthern District
LOCATION