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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-
of Epstein's Enterprise, including the receiving and sending money to other entities they held. 117. Since they were appointed as Co-Executors of the Epstein Estate in 2019, Defendants Indyke and Kahn have approved the release of Estate funds to pay for the legal fees and costs of persons who—like the Co-Execut
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-
of Epstein's Enterprise, including the receiving and sending money to other entities they held. 117. Since they were appointed as Co-Executors of the Epstein Estate in 2019, Defendants Indyke and Kahn have approved the release of Estate funds to pay for the legal fees and costs of persons who—like the Co-Execut
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
e order." V.I. R. CIV. P. Rule 24(b)(2). Specifically, the Government is a rightful participant in any program designed to distribute the assets of the Epstein Estate because of its interest in the assets and disposition of the 2 In full, Rule 24 (a)(2) reads: -On a timely motion, the court must permit anyone to i
l servitude. Id., 11 97. CICO action Defendants Great St. Jim, LLC and Nautilus, Inc.—for which CICO action 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 a
n Defendants and Epstein Estate Executors Darren Indyke and Richard Kahn served, respectively, as Secreta
O action Defendants and Epstein Estate Executors Darren Indyke and Richard Kahn served, respectively, as
ties' motions for summary judgment and all unified deposition transcripts and exhibits thereto for use in its pending law enforcement action against the Epstein Estate. BACKGOUND Under Virgin Islands law, the CICO authorizes the USVI through its Attorney General to prosecute a civil action against any persons eng
l servitude. Id., 11 97. CICO action Defendants Great St. Jim, LLC and Nautilus, Inc.—for which 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 se
n Defendants and Epstein Estate Executors Darren Indyke and erved, respectively, as Secretary and Treas
O action Defendants and Epstein Estate Executors Darren Indyke and erved, respectively, as Secretary and
ties' motions for summary judgment and all unified deposition transcripts and exhibits thereto for use in its pending law enforcement action against the Epstein Estate. BACKGOUND Under Virgin Islands law, the CICO authorizes the USVI through its Attorney General to prosecute a civil action against any persons eng
to Kahn said, contained Epstein's funeral clothes. Little is known about Kahn outside his work for Epstein. Or about his co- executor, 55-year-old Darren Indyke, who served as Epstein's personal attorney for more than two decades and was apparently so close to Epstein that the money manager paid for fertili
stein's personal attorney for more than two decades and was apparently so close to Epstein that the money manager paid for fertility treatments for Indyke and his wife. Neither man has a public social media account, and both shun press interviews. But both could soon be questioned as part of a lawsuit
r Epstein. Or about his co- executor, 55-year-old Darren Indyke, who served as Epstein's personal attorney
e the federal judge overseeing the case and indicated Indyke would be deposed "in both his personal capacity and as a co- EFTA00163123 executor of the Epstein Estate," and would "offer extremely relevant testimony" relating to her claims. "Indeed, we have reason to believe he has firsthand knowledge of Jeffrey
to Kahn said, contained Epstein's funeral clothes. Little is known about Kahn outside his work for Epstein. Or about his co- executor, 55-year-old Darren Indyke, who served as Epstein's personal attorney for more than two decades and was apparently so close to Epstein that the money manager paid for fertili
stein's personal attorney for more than two decades and was apparently so close to Epstein that the money manager paid for fertility treatments for Indyke and his wife. Neither man has a public social media account, and both shun press interviews. But both could soon be questioned as part of a lawsuit
r Epstein. Or about his co- executor, 55-year-old Darren Indyke, who served as Epstein's personal attorney
e the federal judge overseeing the case and indicated Indyke would be deposed "in both his personal capacity and as a co- EFTA01654941 executor of the Epstein Estate," and would "offer extremely relevant testimony" relating to her claims. "Indeed, we have reason to believe he has firsthand knowledge of Jeffrey
rogram and Renewed Request for Ruling, Fanner v. Indyke, No. 19-cv-10475-LGS-DCF, Dkt. 73-1. 1. Specific
about 2001, up to and including in or about 2004." (Id. if 23, 27). B. The Accusers and The Epstein Victim Compensation Fund Accusers 1 and 2 sued the Epstein Estate and simultaneously applied to the Epstein Victim Compensation Fund. Accuser-4 previously sued Epstein and and reached a settlement for those claim
sation Program and Renewed Request for Rulinay. Indyke, No. 19-cv-10475-LGS-DCF, Dkt. 73-1. 1. Specific
about 2001, up to and including in or about 2004." (Id. if 23, 27). B. The Accusers and The Epstein Victim Compensation Fund Accusers 1 and 2 sued the Epstein Estate and simultaneously applied to the Epstein Victim Compensation Fund. Accuser-4 previously sued Epstein and and reached a settlement for those claim
tigation against Epstein's Estate, see Fanner v. Indyke, et at (I:19-cv-10474); Fanner v. Indyke, et at (
voted years of her career to advocating on behalf of survivors of Jeffrey Epstein, including in cases against Prince Andrew, Ghislaine Maxwell, and the Epstein Estate. Ms. McCawley was recognized by Forbes Magazine for her "iron clad interrogation skills" during the deposition of Ghislaine Maxwell. Her work contri
Entities connected to both Darren Indyke and the Epstein Estate

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Richard Kahn
PERSON
Marc Rich
PERSONLarry Visoski
PERSON
Bella Klein
PERSON
JPMorgan Chase
ORGANIZATIONLeon Black
PERSONSouthern Trust Company
ORGANIZATION
Woody Allen
PERSON
Prince Andrew
PERSONHyperion Air
ORGANIZATION
Julie K. Brown
PERSON
Alan Dershowitz
PERSON
Ghislaine Maxwell
PERSONJanusz Banasiak
PERSON
Deutsche Bank
ORGANIZATION
U.S. Virgin Islands
LOCATIONMartin Weinberg
PERSON
United States
LOCATION