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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
l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
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
15, 2019, the Executors of The Estate, Darren K. Indyke and Richard D. Kahn, filed a Petition for Probate
ise described below. The Trust's administrators, Darren K. Indyke and Richard D. Kahn, filed a Certificate
ise described below. The Trust's administrators, Darren K. Indyke and Richard D. Kahn, filed a Certificate o
l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
15, 2019, the Executors of The Estate, Darren K. Indyke and filed a Petition for Probate and Letters Tes
ise described below. The Trust's administrators, Darren K. Indyke and filed a Certificate of Trust in the
ise described below. The Trust's administrators, Darren K. Indyke and filed a Certificate of Trust in the
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 filed a Petition for Probate and Letters Testamentary which included Epstein's last will and testament with the Probate Division of the Superio
l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
15, 2019, the Executors of The Estate, Darren K. Indyke and Richard D. Kahn, filed a Petition for Probate
ise described below. The Trust's administrators, Darren K. Indyke and filed a Certificate of Trust in the
ise described below. The Trust's administrators, Darren K. Indyke and filed a Certificate of Trust in the
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
l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
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-
l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
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-
l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
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
l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
f 55 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, PLAINTIFF, 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
Page: EFTA00018779 →F THE UNITED STATES VIRGIN ISLANDS, PLAINTIFF, DARREN K. INDYKE, in his capacity as the EXECUTOR FOR THE
Page: EFTA00018779 →on by VIDOJ. 7. Epstein was found dead on August 10, 2019 while in custody in New York for sex crimes. 8. Defendant Darren K. Indyke ("Defendant Indyke") is co-executor of the Estate of Jeffrey E. Epstein and Administrator of The 1953 Trust. 9. Defendant Richard D. Kahn ("Defendant Kahn") is co-ex
Page: EFTA00018780 →l and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and asse
Page: EFTA00018792 →Entities connected to both Darren Indyke and the Coastal Zone

Jeffrey Epstein
PERSON
Richard Kahn
PERSONLarry Visoski
PERSON
JPMorgan Chase
ORGANIZATIONSouthern Trust Company
ORGANIZATION
Woody Allen
PERSONHyperion Air
ORGANIZATION
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Deutsche Bank
ORGANIZATION
U.S. Virgin Islands
LOCATION
United States
LOCATIONErika Kellerhals
PERSON
Financial Trust Company
ORGANIZATION
Condoleezza Rice
PERSON
Jes Staley
PERSONHBRK Associates
ORGANIZATION
New York
LOCATIONGratitude America
ORGANIZATIONMaria Farmer
PERSON