3
Shared Docs
3
Same-Page
5 / 3
Mentions
RT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP THE GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' MEMORANDUM OF LAW IN SUPPORT OF EX PARTE MOTION TO INTERVENE AND FOR CONFIDENTIAL ACCESS TO JUDICIAL RECORDS AND DISCOVERY DOCUMENTS The Governme
V.I.C. §§ 605, 607. The USVI alleges in its CICO action that decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking enterprise in the Virgin Islands, wherein he used his vast wealth and property holdings and a deliberately opaque web of corporations and companies to transport young women and girl
n Defendants and Epstein Estate Executors Darren Indyke and Richard Kahn served, respectively, as Secretary and Treasurer—knowingly participated in the Epstein Enterprise and facilitated the trafficking and sexual servitude of underage girls and young women by providing the secluded properties at, from, or to which E
ED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP THE GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' MEMORANDUM OF LAW IN SUPPORT OF EX PARTE MOTION TO INTERVENE AND FOR CONFIDENTIAL ACCESS TO JUDICIAL RECORDS AND DISCOVERY DOCUMENTS The Governme
V.I.C. §§ 605, 607. The USVI alleges in its CICO action that decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking enterprise in the Virgin Islands, wherein he used his vast wealth and property holdings and a deliberately opaque web of corporations and companies to transport young women and girl
ch CICO action Defendants and Epstein Estate Executors Darren Indyke and erved, respectively, as Secretary and Treasurer—knowingly participated in the Epstein Enterprise and facilitated the trafficking and sexual servitude of underage girls and young women by providing the secluded properties at, from, or to which E
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
and death in prison in 2019. 215. The continued criminal conduct by Defendants has caused repeated and continuous injury. The criminal conduct of the Epstein Enterprise was not completed nor were all damages incurred until the wrongdoing ceased. COUNT ONE Human Trafficking — Trafficking an Individual Violation of
Entities connected to both U.S. Virgin Islands and the Epstein Enterprise

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
Richard Kahn
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Julie K. Brown
PERSON
Deutsche Bank
ORGANIZATIONV.I.C.
ORGANIZATION
Condoleezza Rice
PERSONSecond Circuit
ORGANIZATION
Hartford
LOCATION
Nassau
LOCATIONthe Epstein Estate
ORGANIZATIONMotley Rice
PERSONthe Superior Court
ORGANIZATION
Nautilus
ORGANIZATIONBridgeport
LOCATIONMartindell
PERSON
Press-Enterprise Co.
ORGANIZATION