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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
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
d to, making fraudulent claims upon the Government. 291. The Epstein Enterprise misrepresented the purpose, activities, employment, and income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epstei
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
d to, making fraudulent claims upon the Government. 392. The Epstein Enterprise misrepresented the purpose, activities, employment, and income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epste
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. EFTA00161936 Case 1:22-cv-10904-JSR Doc
d to, making fraudulent claims upon the Government. 392. The Epstein Enterprise misrepresented the purpose, activities, employment, and income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epste
Entities connected to both U.S. Virgin Islands and the Southern Trust Company, Inc.

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
New York
LOCATIONSouthern Trust Company
ORGANIZATION
Jes Staley
PERSON
the United States District Court
ORGANIZATION
Apple
ORGANIZATIONSouthern District
LOCATIONV.I.C.
ORGANIZATION
Condoleezza Rice
PERSON
Hillary Clinton
PERSON
Washington D.C.
LOCATIONLaurel, Inc.
ORGANIZATION
Vienna
LOCATION
Marla Maples
PERSON
Monaco
LOCATIONLinda Pinto
PERSON
El Brillo Way
LOCATIONCarol Thomas-Jacobs
PERSON