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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-
o triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David 1. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 849-4962 [email protected] CAROL THOMAS-JACOBS (NYS Bar #2941300) Admit
ired, primarily from a single source, as described below. Kahn, as Southern Trust's treasurer, oversaw its accounting, invoicing, and tax reporting. Indyke also authorized a majority of the wire transfers from Southern Trust's bank account in order to fund the various entities and personal bank account
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
NE Child Abuse and Neglect—All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual
NE Child Abuse and Neglect—All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual C
GREED. 10 EFTA00162372 O2taaa22222ettleD29214SERRCiThitarmanit+261I2 Plagttelnothfl .113 /s/ Linda Singer LINDA SINGER Admitted Pro Hac Vice Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 232-5504 [email protected] Dated: January 9, 2023 SO ORDERED. Dated: New
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-
o triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David I. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 849-4962 [email protected] CAROL THOMAS-JACOBS (NYS Bar #2941300) Admit
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
ss to Judicial Records and Discovery Documents. Dated: September 1, 2020 Respectfully submitted, /s/ William H. Narwold William H. Narwold, Esq. Motley Rice LLC One Corporate Center 20 Church Street, 17th Floor Hartford, CT 06103 13 EFTA00073272 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 P
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
ss to Judicial Records and Discovery Documents. Dated: September 1, 2020 Respectfully submitted, /s/ William H. Narwold William H. Narwold, Esq. Motley Rice LLC One Corporate Center 20 Church Street, 17th Floor Hartford, CT 06103 13 EFTA00077323 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 P
year term as the Commissioner to Casino Control.] During the investigation into the EPSTEIN estate it was discovered that Richard Kahn (KAHN) and Darren Indyke (INDYKE) were participants in the human trafficking operation. INDYKE was in charge of coordinating female to female marriages to gain immigration
ctims were housed on EPSTEIN properties and moved from Palm Beach, Florida, New York and Little St. James Island. A second amended complaint added INDYKE and KAHN as co-conspirators. The estate settled for 105 million dollars in civil court. The estate denied all wrong doing. MOTLEY RICE maintained a
e it was discovered that Richard Kahn (KAHN) and Darren Indyke (INDYKE) were participants in the human t
ertaining to Criminally Influenced and Corrupt Organizations Act (C/CO). MOTLEY RICE CICO BRYAN told GEORGE "He's dead go for it". GEORGE contacted Motley Rice (MOTLEY RICE) to assist with CICO and recovering funds from EPSTEIN's estate received due to criminal activity. MOTLEY RICE investigated with foren
rise, with the active participation of Defendants Indyke and Kahn, used Southern Trust Company to employ,
10 EFTA00161956 Gbase11222€6140002143$33R MeauneettlE62 F(rli£dcDQ11DP.VZ3 Flaajgethottill /s/ Linda Singer LINDA SINGER Admitted Pro Hac Vice Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 232-5504 [email protected] Dated: January 9, 2023 SO ORDERED. Dated: New
Entities connected to both Darren Indyke and Motley Rice

Jeffrey Epstein
PERSON
Richard Kahn
PERSONLarry Visoski
PERSON
JPMorgan Chase
ORGANIZATIONSouthern Trust Company
ORGANIZATIONHyperion Air
ORGANIZATION
Julie K. Brown
PERSON
Alan Dershowitz
PERSON
Ghislaine Maxwell
PERSON
Deutsche Bank
ORGANIZATION
U.S. Virgin Islands
LOCATION
United States
LOCATION
Financial Trust Company
ORGANIZATION
Condoleezza Rice
PERSON
Jes Staley
PERSONHBRK Associates
ORGANIZATION
New York
LOCATIONGratitude America
ORGANIZATION
Donald Trump
PERSON
Les Wexner
PERSON