Epstein Secrets

F Document 118 Filed 02/10/21 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, 19 Civ. 10475 (LGS) -against- DARREN K. INDYKE, in his capacity as executor : of the Estate of Jeffrey Edward Epstein, et al., Defendants. LORNA G. SCHOFIELD, District Judge: X OPINION AND O

ndants Darren K. Indyke and Richard D. Kahn in their official capacities as appointed executors of the Estate of Jeffrey E. Epstein (the "Estate") (Indyke and Kahn together, the "Co-Executors"). The Complaint alleges claims of battery, false imprisonment and intentional infliction of emotional distres

RK X Plaintiff, 19 Civ. 10475 (LGS) -against- DARREN K. INDYKE, in his capacity as executor : of the Es

RK X Plaintiff, 19 Civ. 10475 (LGS) -against- DARREN K. INDYKE, in his capacity as executor : of the Est

Filed 02/10/21 Page 2 of 6 Epstein's and Ms. Maxwell's alleged sexual abuse of Plaintiff. Defendants did not file counterclaims. On June 2, 2020, the Superior Court of the United States Virgin Islands granted the Co- Executors' motion to establish the Epstein Victims' Compensation Program, a voluntary independen

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

er situated...to the then acting Trustees of The 1953 Trust." 67. On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn are the two Trustees of The 1953 Trust. See Certificate of Trust, In the 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

3 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 31. On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn arc the two Trustees of The 1953 Trust. 32. On September 6, 2019, Magistr

9212 Ya-neeeed PA NZI.ING July 13th 2010 Mr. Darren K. Indyke VIA EMAIL (dkiesaftaol.com) Subject: Lit

ts for 01 40 10 35 10 GHRISTMN MRTHO0 thrihaefameells.panelmg row PLAINTIFFS' EXHIBIT 2 EFTA00309212 Ya-neeeed PA NZI.ING July 13th 2010 Mr. Darren K. Indyke VIA EMAIL (dkiesaftaol.com) Subject: Little Saint James Office Woodwork - Color staining modification. Dear Mr. Indyke In answer to your email Mon

uly 13th 2010 Mr. Darren K. Indyke VIA EMAIL (dkiesaftaol.com) Subject: Little Saint James Office Woodwork - Color staining modification. Dear Mr. Indyke In answer to your email Monday, July 12, 2010, we confirm that during our last on site intervention of March 2010 we executed all the expected work

9212 Ya-neeeed PA NZI.ING July 13th 2010 Mr. Darren K. Indyke VIA EMAIL (dkiesaftaol.com) Subject: Litt

aintiffs FAC and the exhibits attached thereto. 2. Plaintiffs Have Filed Their Lawsuit in the Proper Venue: The St. Thomas and St. John Division of the Superior Court. Defendant also suggests that this case be dismissed because the venue is improper. "To survive a motion to dismiss for improper venue, the plainti

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

iminal Activity Lien Notice pursuant to Chapter 30, Title 14 § 610, in the matter ESTATE OF JEFFREY E. EPSTEIN, PROBATE NO. ST-19-PB-80, pending in the Superior Court of the Virgin Islands, Division of St. Thomas and St. John. A civil proceeding. Case No. ST-2020-CV-14. having been instituted by the Government of

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

ed and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended Complaint, filed February 11, 2020). Access to other judicial docu

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

ed and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended Complaint, filed February 11, 2020). Access to other judicial docu

ed Feb. 16, 2021 (ECF No. 120), at 2 in Farmer v. Indyke, 19 Civ. 10475 (S.D.N.Y.); Order, dated Mar. 19,

arial, [and] confidential" basis.2' For example, the EVCP operates "entirely free from any interference or control by the Epstein " Ex. G (order of the Superior Court of t1 lit• in Islands Division of St. ( Virgin dated June 2, 2020); see Ex. A ¶¶ 8, 13 Decl.). " Ex. C (6/25/20 Press Release). 16 Maxwell's Mo