Epstein Secrets

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, PLAINTIFF, V. DARREN K. INDYKE, in his capacity as the EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN and ADMINISTRATOR OF THE 1953 TRUST; RICHARD D. KAHN, in his capacity as th

eached $391.3 million. From 2011 until at least 2018, Jeffrey Epstein was the President/Director of Southern Trust Company, and Defendants Kahn and Indyke were Treasurer/Director and Secretary/Director, respectively. Epstein was the sole owner of Southern Trust Company. 38. John and Jane Does represe

E UNITED STATES VIRGIN ISLANDS, PLAINTIFF, V. DARREN K. INDYKE, in his capacity as the EXECUTOR FOR THE

E UNITED STATES VIRGIN ISLANDS, PLAINTIFF, V. DARREN K. INDYKE, in his capacity as the EXECUTOR FOR THE

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 Islands at $577,672,654.00 dollars. 12.

IRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN CIVIL CASE NO.: ‘51t 3DS . )56 GHISLAINE MAXWELL, Plaintiff, vs. ESTATE OF JEFFREY E. EPSTEIN. DARREN K. INDYKE, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY E. EPSTEIN, RICHARD D. KAHN, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY E.

MAXWELL (-Maxwell.), through her undersigned attorneys. by ‘‘a) of her Complaint against Defendants is STA OF JEI FREY I.. LPSTLIN (the "Estate"). DARREN K. INDYKE. in his capacity as Executor of the LSTATI. Of- JEFFREY E. EPSTEIN ("Indykel. RICHARD D. KAHN, in his capacity as Executor or the ESTATE OF JEFFREY

nd expenses for a number of other employees in other various lawsuits relating to Epstein, his affiliated businesses, and his alleged victims. 21. Indyke, in his capacity as an Executor of the Estate, also made assurances to Maxwell that Maxwell's legal fees and obligations would be reimbursed by Epst

, Plaintiff, vs. ESTATE OF JEFFREY E. EPSTEIN. DARREN K. INDYKE, in his capacity as EXECUTOR OF THE E

New York. 24. On August 15. 2019. Indyke and Kahn filed a petition for probate of Epstein's last will and tostninent with thu Probate Division of the Superior Court of the Virgin Islands. Division of St. Thomas and St. John. 25. Maxwell has incurred and will continue to incur significant legal ices. personal security costs, and ot

Case 1:19-cv-08673 Document 1 Filed 09/18/19 Page 1 of 16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY E. EPSTEIN, Defendants. Case No. JURY TRIAL DEMANDED COMPLAI

avits from Darren K. Indyke and Richard D. Kahn attesting to their "Oath of Willingness to Serve as Executor and Appointment of Local Counsel." Mr. Indyke and Mr. Kahn also filed a Petition for Probate and for Letters Testamentary in the Superior Court of the Virgin Islands. 12 EFTA00103507 Case 1:

DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities

DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities

ner concluded Epstein died by suicide. 64. On August 15, 2019, Epstein's last will and testament (the "Will") was filed in the Probate Division of the Superior Court of the Virgin Islands. 65. The Will indicated that it was executed by Epstein on August 8, 2019 at the Metropolitan Correctional Center, and that it was witnessed by Ma

ill indicated that it was executed by Epstein on August 8, 2019 at the Metropolitan Correctional Center. The Will was accompanied by affidavits from Darren K. Indyke and Richard D. Kahn attesting to their "Oath of Willingness to Serve as Executor and Appointment of Local Counsel." Mr. Indyke and Mr. Kahn also fil

avits from Darren K. Indyke and Richard D. Kahn attesting to their "Oath of Willingness to Serve as Executor and Appointment of Local Counsel." Mr. Indyke and Mr. Kahn also filed a Petition for Probate and for Letters Testamentary in the Superior Court of the Virgin Islands. 30. The Will's first arti

DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities

DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities

ner concluded Epstein died by suicide. 28. On August 15, 2019, Epstein's last will and testament (the "Will") was filed in the Probate Division of the Superior Court of the Virgin Islands. 29. The Will indicated that it was executed by Epstein on August 8, 2019 at the Metropolitan Correctional Center. The Will was accompanied by aff

companies, that existed merely to transfer money to other accounts, or to shelter Epstein's assets from judgment. Id. ¶ 116. 31. Epstein's lawyer, Darren K. Indyke, and accountant, Richard Kahn, now the Co- Executors of Epstein's Estate, authorized or directed many of the transactions in JP Morgan accounts 8 E

's financial assets and is also responsible to pay damages for the acts committed by Epstein and the Epstein Enterprise described below. Defendants Indyke and Kahn, filed a Certificate of Trust in the Superior Court of the Virgin Islands for The Trust on August 26, 2019. 18. Epstein maintained a deli

from judgment. Id. ¶ 116. 31. Epstein's lawyer, Darren K. Indyke, and accountant, Richard Kahn, now the Co

from judgment. Id. ¶ 116. 31. Epstein's lawyer, Darren K. Indyke, and accountant, Richard Kahn, now the Co-

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 Virgin Islands at $577,672,654.00 dollars. 13

Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT FIFTEEN Unlawful Sexual Contact in the First or Second Degree—All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual Capacities Violation of the Criminally Influenced and Corrupt Organization Act, 14 V.I.C. § 600 et seq. and

's financial assets and is also responsible to pay damages for the acts committed by Epstein and the Epstein Enterprise described below. Defendants Indyke and Kahn, filed a Certificate of Trust in the Superior Court of the Virgin Islands for The Trust on August 26, 2019. 18. Epstein maintained a deli

rom judgment. Id. II 116. 31. Epstein's lawyer, Darren K. Indyke, and accountant, Richard Kahn, now the Co

rom judgment. Id. II 116. 31. Epstein's lawyer, Darren K. Indyke, and accountant, Richard Kahn, now the Co-

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 Virgin Islands at $577,672,654.00 dollars. 13

effrey E. Epstein ("The Estate"), created upon Epstein's death, is domiciled in the Virgin Islands. On August 15, 2019, the Executors of The Estate, 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 Divisio

between the Executors and the Fund. The Executors of Epstein's Estate, and also the movants for the Expedited Motion to establish the Epstein Fund, Darren K. lndyke and Rickard D. Kahn. were and are involved in various Epstein business entities that arc alleged to share liability in Epstein's civil and cr

ved in various Epstein business entities that arc alleged to share liability in Epstein's civil and criminal violations in the Virgin Islands. Both Indyke and Kahn are the Trustees of the 1953 Trust, which holds almost all of Epstein's assets. See Compl. 72 l3. Furthermore, the Executors are also offic

stein ("the Estate") was created. The Executors, Darren Indyke and Richard Kahn, filed a Petition for Pro

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. Two days before his death, Mr. Epstein a

ED MOTION FOR ESTABLISHMENT OF A VOLUNTARY CLAIMS RESOLUTION PROGRAM COME NOW the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorable Court for an expedited order to establish an independent and voluntary claims resolution program (the

of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorable Cour

the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honora

the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorab

ates Virgin Islands under Chapter 30 of the Virgin Islands Code, namely, the Criminally Influenced and Corrupt Organizations Act (MO), is pending in the Superior Court of the Virgin Islands naming the ESTATE OF JEFFREY E. EPSTEIN; THE 1953 TRUST; PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC.; AND POLAR, INC. as de

dress is forwarded to all Parties: (a) For Epstein: Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USVI 00802 With a courtesy copy to: Darren K Indyke, Esq. 301 East 66th Street, 10B New York, New York 10065 (212) 517-2052 (b) For Fancelli: [PLEASE INSERT NOTICE ADDRESSES] 10 EFTA00655547

s, USVI 00802 With a courtesy copy to: Darren K Indyke, Esq. 301 East 66th Street, 10B New York, New Y

St. Thomas, USVI 00802 With a courtesy copy to: Darren K Indyke, Esq. 301 East 66th Street, 10B New York

es Virgin Islands (the "Disputes"); and WHEREAS, Epstein and FPI, as well as M. Molyneux Studio, Ltd., are parties to a lawsuit now pending before the Superior Court of the Virgin Islands, Division of St. Thomas and St. John, under Case No. ST-CV-443 (the "Lawsuit"); and WHEREAS, the parties hereto (the "Parties") desire to settle al

ddress is forwarded to all Parties: (a) For Epstein: Jeffrey Epstein 6100 Red Hook Quarter, B3 St Thomas, USVI 00802 With a courtesy copy to: Darren K Indyke, Esq. 301 East 66th Street, 10B New York, New York 10065 10 EFTA00584732 (212) 517-2052 (b) For Fancelli: [PLEASE INSERT NOTICE ADDRESSES]

s, USVI 00802 With a courtesy copy to: Darren K Indyke, Esq. 301 East 66th Street, 10B New York, New Y

St Thomas, USVI 00802 With a courtesy copy to: Darren K Indyke, Esq. 301 East 66th Street, 10B New York

Virgin Islands (the "Disputes"); and WHEREAS, Epstein and FPI, as well as J.P. Molyneux Studio, Ltd., are parties to a lawsuit now pending before the Superior Court of the Virgin Islands, Division of St. Thomas and St. John, under Case No. ST-CV-443 (the "Lawsuit"); and WHEREAS, the parties hereto (the "Parties") desire to settle al