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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
n reports the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 12. According to the Petition, the assets in the Virgin Islands thus far includes: a. $56.5 million in cash; b. $127 million in fixed income and equity investments; c. $195 mil
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
n reports the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 10. According to the Petition, the assets in the Virgin Islands thus far includes: a. $56.5 million in cash; EFTA00086803 GVI v. Estate of Jeffrey E. Epstein GVI's Complaint
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
n reports the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 10. According to the Petition, the assets in the Virgin Islands thus far includes: a. $56.5 million in cash; EFTA00104217 GVI v. Estate of Jeffrey E. Epstein GVI's Complaint
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
n reports the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 10. According to the Petition, the assets in the Virgin Islands thus far includes: a. $56.5 million in cash; EFTA00104292 Case 1:19-cv-08673-KPF-DCF Document 45-1 Filed 01/15/
ess by giving notice to all of the Parties set forth in this subsection. Laurel, Inc.: 6100 Red Hook Quarter, B3 St. Thomas, VI 00802 Attention: Darren K. Indyke, Vice President Mortara: Mrs. Virginia Mortara P.O. Box 145 Harrington Park, N.J. 07640 7. Opportunity to Cure. Prior to the institution of an
r, B3 St. Thomas, VI 00802 Attention: Darren K. Indyke, Vice President Mortara: Mrs. Virginia Mortara
ook Quarter, B3 St. Thomas, VI 00802 Attention: Darren K. Indyke, Vice President Mortara: Mrs. Virginia
ook Quarter, B3 St. Thomas, VI 00802 Attention: Darren K. Indyke, Vice President Mortara: Mrs. Virginia M
ts Petition for Formal Administrative Hearing ("Petition") with the FDEP challenging issuance of the Notice of Determination of Exemption. c) The Petition has not been referred to DOAH. The case is currently being held in abeyance by the FDEP. 2. Settlement Actions Entry into this Agreement shall no
undersigned, the Estate of Jeffrey E. Epstein, by Darren K. Indyke and Richard D. Kahn, as Co-Executors the
undersigned, the Estate of Jeffrey E. Epstein, by Darren K. Indyke and Richard D. Kahn, as Co-Executors ther
e evidence of the approval thereof by the Sole Member); and be it further RESOLVED, that all prior actions taken for and on behalf of the Company by Darren K. Indyke, as an authorized representative of the Company, the Manager (Lawrence Visoski) of the Company, and any employees, agents and/or legal counsel of th
necessary and/or appropriate to effectuate the purchase and sale of the Aircraft as contemplated by the preceding resolutions (the execution by Mr. Indyke of the Purchase Agreement with any such changes, additions and/or other revisions thereto to be 1 CONFIDENTIAL Subject to Protective Order IATS
LA H. GEORGE Clerk of the Court 241CLItS EDOTCIA THOMAS-HODGE • Court Clerk Supervisor 9 up___Qui ORDER FOR PROBATE Upon consideration of the Petition filed herein, and it appearing to the satisfaction of the Court that JEFFREY E. EPSTEIN died, testate, in Manhattan, New York, on August 10, 2019,
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-
reported the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 13. According to the Petition, the assets in the Virgin Islands thus far included: a. $56.5 million in cash; b. $127 million in fixed income and equity investments; c. $195 mil
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-
reported the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 13. According to the Petition, the assets in the Virgin Islands thus far included: a. $56.5 million in cash; b. $127 million in fixed income and equity investments; c. $195 mil
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
n reports the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 10. According to the Petition, the assets in the Virgin Islands thus far includes: a. $56.5 million in cash; EFTA00074773 GVI v. Estate of Jeffrey E. Epstein GVI's Complaint
ned to. Epstein had corporation attorney, Darren Indyke, register the businesses and register himself as
s assigned to. Epstein had corporation attorney, Darren Indyke, register the businesses and register hims
computer check revealed 457 Madison Ave is a business address in which Epstein has his corporations assigned to. Epstein had corporation attorney, Darren Indyke, register the businesses and register himself as an agent. I also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group, Ghi
imity among the defendants. In accordance with 28 U.S.C. § 1446(b) the undersigned are authorized to represent that all of the defendants join this Petition and consent to removal. Conclusion Because this is a civil action between citizens of different states, excluding any fraudulently joined parties,
Entities connected to both Darren Indyke and Petition

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Richard Kahn
PERSON
Marc Rich
PERSONLarry Visoski
PERSON
JPMorgan Chase
ORGANIZATIONLeon Black
PERSONSouthern Trust Company
ORGANIZATION
NEW YORK NY
LOCATION
Martha Stewart
PERSON
Woody Allen
PERSON
Prince Andrew
PERSONHyperion Air
ORGANIZATION
Alan Dershowitz
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSONDaphne Wallace
PERSON
Deutsche Bank
ORGANIZATION
George Mitchell
PERSON
U.S. Virgin Islands
LOCATION