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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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.1.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 255. SORCPA requires that offenders required to register provide information relating to intended travel in foreign commerce. 256. On at least two occasions,
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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
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
register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 356. SORCPA requires that offenders required to register provide information relating to intended travel in foreign commerce. 357. On at least two occasions,
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
register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 356. SORCPA requires that offenders required to register provide information relating to intended travel in foreign commerce. 357. On at least two occasions,
Entities connected to both U.S. Virgin Islands and SORCPA

Jeffrey Epstein
PERSONDarren Indyke
PERSON
United States
LOCATION
Richard Kahn
PERSON
Financial Trust Company
ORGANIZATION
New York
LOCATIONSouthern Trust Company
ORGANIZATION
St. Croix
LOCATIONLarry Visoski
PERSON
Jes Staley
PERSONVirgin Islands Department of Justice
ORGANIZATION
Apple
ORGANIZATIONSouthern District
LOCATIONV.I.C.
ORGANIZATIONNautilus, Inc.
ORGANIZATION
Condoleezza Rice
PERSON
St. John
LOCATION
Saint James
LOCATIONHyperion Air
ORGANIZATION
Red Hook
LOCATION