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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
y and to the average resident of the Virgin Islands. But because of Epstein's enormous wealth, these fines had little effect in curbing or stopping the Epstein Enterprise's unlawful conduct or conforming its activities to the law. EFTA00104228 GVI v. Estate of Jeffrey E. Epstein GVI's Complaint Page 14 of 48 66.
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
y and to the average resident of the Virgin Islands. But because of Epstein's enormous wealth, these fines had little effect in curbing or stopping the Epstein Enterprise's unlawful conduct or conforming its activities to the law. EFTA00104303 Case 1:19-cv-08673-KPF-DCF Document 45-1 Filed 01/15/20 Page 14 of 49 GVI
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
y and to the average resident of the Virgin Islands. But because of Epstein's enormous wealth, these fines had little effect in curbing or stopping the Epstein Enterprise's unlawful conduct or conforming its activities to the law. 69. As a result of illegal construction activity of the Epstein Enterprise, 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
y and to the average resident of the Virgin Islands. But because of Epstein's enormous wealth, these fines had little effect in curbing or stopping the Epstein Enterprise's unlawful conduct or conforming its activities to the law. EFTA00086814 GVI v. Estate of Jeffrey E. Epstein GVI's Complaint Page 14 of 48 66.
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
y and to the average resident of the Virgin Islands. But because of Epstein's enormous wealth, these fines had little effect in curbing or stopping the Epstein Enterprise's unlawful conduct or conforming its activities to the law. EFTA00074784 GVI v. Estate of Jeffrey E. Epstein GVI's Complaint Page 14 of 48 66.
t concealed, assisted and furthered the wrongful acts by use of civil conspiracy. 387. As a direct and proximate result of Defendants' conspiracy, the Virgin Island has been injured. 388. Each co-conspirator is jointly and severally liable for the acts alleged herein. EFTA00162352 Oatied.122 100204ISSR Ceso
tional injury, in violation Virgin Islands criminal laws prohibiting Child Abuse and Neglect in Title 14 V.I.C. § 500 et. seq. 275. As a result of the Epstein Enterprise's actions numerous young girls suffered serious physical, mental and emotional injury. 276. Defendants through a pattern of criminal activity acquir
Entities connected to both U.S. Virgin Islands and the Epstein Enterprise's

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
Financial Trust Company
ORGANIZATION
New York
LOCATIONSouthern Trust Company
ORGANIZATION
St. Croix
LOCATIONLarry Visoski
PERSON
Apple
ORGANIZATIONSouthern District
LOCATIONV.I.C.
ORGANIZATIONNautilus, Inc.
ORGANIZATION
St. John
LOCATION
Saint James
LOCATIONHyperion Air
ORGANIZATIONL.S.J.
ORGANIZATION
Great St. James
ORGANIZATIONGREAT ST
ORGANIZATION
Vienna
LOCATIONLaurel, Inc.
ORGANIZATION