Epstein Secrets

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

nd costs; L. Award compensatory and punitive damages for Defendants' civil conspiracy; M. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; N. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 V.I.C.

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

nd costs; L. Award compensatory and punitive damages for Defendants' civil conspiracy; M. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; N. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 14 V.I.

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

nd costs; L. Award compensatory and punitive damages for Defendants' civil conspiracy; M. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; N. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 14 V.I.

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

nd costs; L. Award compensatory and punitive damages for Defendants' civil conspiracy; M. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; N. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 14 V.I.

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

nd costs; M. Award compensatory and punitive damages for Defendants' civil conspiracy; N. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; O. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 V.I.C.

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

nd costs; L. Award compensatory and punitive damages for Defendants' civil conspiracy; M. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; N. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 14 V.I.

rise, with the active participation of Defendants Indyke and Kahn, used Southern Trust Company to employ,

nd costs; M. Award compensatory and punitive damages for Defendants' civil conspiracy; N. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; O. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 V.I.C.