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

thern Trust Company. 38. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 39. The Attorney General brings this action to seek all remedies a

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

d Little St. James. 35. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 36. The Attorney General brings this action to seek all remedies a

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

d Little St. James. 35. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 36. The Attorney General brings this action to seek all remedies a

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

d Little St. James. 35. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 36. The Attorney General brings this action to seek all remedies a

companies, that existed merely to transfer money to other accounts, or to shelter Epstein's assets from judgment. Id. 1 116. 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 held

t"), see Government of the U.S. Virgin Islands v. Indyke et at, Case No. ST-20- CV-14 (Super. Ct. V.I. Jan

from judgment. Id. 1 116. 31. Epstein's lawyer, Darren K. Indyke, and accountant, Richard Kahn, now the Co

from judgment. Id. 1 116. 31. Epstein's lawyer, Darren K. Indyke, and accountant, Richard Kahn, now the Co-

ing regulations is to give law enforcement real-time information so that it can act to detect violations of the law and protect public safety. 89. The Government of the Virgin Islands did not know, and could not have known, that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind eye t

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-

ing regulations is to give law enforcement real-time information so that it can act to detect violations of the law and protect public safety. 89. The Government of the Virgin Islands did not know, and could not have known, that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind eye t

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-

ing regulations is to give law enforcement real-time information so that it can act to detect violations of the law and protect public safety. 89. The Government of the Virgin Islands did not know, and could not have known, that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind eye t

Jeffrey E. Epste haitAttA.. a 1/2 9 k_ Darren Indyke, Secretary TERRITORY OF THE UNITED STATES VIRGIN

e purpose of giving their consent Mere° and approval thereof. Cwporare Seal \CC' usoic- ` Laurel, Inc. Jeffrey E. Epste haitAttA.. a 1/2 9 k_ Darren Indyke, Secretary TERRITORY OF THE UNITED STATES VIRGIN ISLANDS )ss: DISTRICT' OF ST. THOMAS & ST. JOHN On this the / day of _4 , 2012, before me /3e

/Director St. Thomas, USVI 00802 saves until successor elected Richard Kahn, Treasurer/Director New York, NY 10021 serves until successor elected Darren K incryte.vkePraskwo/SecteurylThrector Livingston, NJ 07039 Serves until successor enkted I DECLARE. LINKER MASSY Of HENRY, UNDER THE LAWS Of ME UMW

Is for the hood Ended lone )06 2013 1000 Ham corse• mock I 01 pa ...Ment/ThittlItTI.FITIt s 0 rn ' 3 <0 • rrl Arri (Attach checks payable to The Government of the Virgin Islands sad mall documents Is the Offlee of the Lieutopat goseracticti tMsloa of Corporation sad Trademarks, I I, St. Thomas, VI 00802-64$7.) 0 „--‘sident

reto and approval thereof. !w ponds Seal Darren Indyke, Secretary TERRITORY OF THE UNITED STATES VIRGIN

vv..... 2012, the undersigned have executed this Resolution for the purpose of giving their consent ifiereto and approval thereof. !w ponds Seal Darren Indyke, Secretary TERRITORY OF THE UNITED STATES VIRGIN ISLANDS )ss: DISTRICT OF ST. THOMAS & ST. JOHN On this the day of av 0-s-- 2012, before me

F ST. THOMAS & ST. JOHN On this the day of av 0-s-- 2012, before me A r Se/Ar the undersigned, personally appeared Jeffrey E Epstein and Darren In who acknowledged themselves to be the President and Secretary of Maple, Inc., a US. Virgin Islands Corporation, and as being authorized so to d

6 S c. Total Pellet), And Interest. Co " 6) TOTAL DUE AND FORWARDED HEREWITH (Sum of (4) (b) and (5) (c) ti 1r4rn (Attach cheeks payable to The Government of the Virgin Islands and mall documents to the Office of the Lieu tenadcrovernor, DWIsion of Corporation and Trademarks, St. Thomas, VI 001101-6487.) President EFTA00

uted this Resolution for the purpose of giving their consent Ofiereto and approval thereof. Celan* Seal Maple, Inc. Jeffrey E. EpsLitm, President Darren Indyke, Secretary - TERRITORY OF THE UNITED STATES VIRGIN ISLANDS )ss: DISTRICT OF ST. THOMAS & ST. JOHN On this the / day of s0 , 2012, before me

aple, Inc. Jeffrey E. EpsLitm, President Darren Indyke, Secretary - TERRITORY OF THE UNITED STATES VIR

Seal Maple, Inc. Jeffrey E. EpsLitm, President Darren Indyke, Secretary - TERRITORY OF THE UNITED STA

And Interest. i $ . -- 0 01 n5 - e - 6) TOTAL WE AND FORWARDED HEREWITH (Sam of (4) (b) and (5) (c) ---1 rtri (Attach cants canto payable to The Government of the Virgin Islands and mall documents to the Office of the lieutetaattportnior. Division of Corporatist sad Trademarks, 5049 Kongens Gado, St. Thomas, VI 00802-6487.)