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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
ngage in a course of conduct aimed at concealing the criminal activities of the Epstein Enterprise. On November 24, 2019, Epstein's Estate filed an Expedited Motion for Establishment of a Voluntary Claims Resolution Program in the Superior Court of the Virgin Islands. ("Motion"). According to the Motion, the proposed program was to h
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
ngage in a course of conduct aimed at concealing the criminal activities of the Epstein Enterprise. On November 24, 2019, Epstein's Estate filed an Expedited Motion for Establishment of a Voluntary Claims Resolution Program in the Superior Court of the Virgin Islands. ("Motion"). According to the Motion, the proposed program was to b
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
ngage in a course of conduct aimed at concealing the criminal activities of the Epstein Enterprise. On November 24, 2019, Epstein's Estate filed an Expedited Motion for Establishment of a Voluntary Claims Resolution Program in the Superior Court of the Virgin Islands. ("Motion"). According to the Motion, the proposed program was to b
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
ngage in a course of conduct aimed at concealing the criminal activities of the Epstein Enterprise. On November 24, 2019, Epstein's Estate filed an Expedited Motion for Establishment of a Voluntary Claims Resolution Program in the Superior Court of the Virgin Islands. ("Motion"). According to the Motion, the proposed program was to b
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-
ngage in a course of conduct aimed at concealing the criminal activities of the Epstein Enterprise. On November 24, 2019, Epstein's Estate filed an Expedited Motion for Establishment of a Voluntary Claims Resolution Program in the Superior Court of the Virgin Islands. ("Motion"). According to the Motion, the proposed program was to b
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-
ngage in a course of conduct aimed at concealing the criminal activities of the Epstein Enterprise. On November 24, 2019, Epstein's Estate filed an Expedited Motion for Establishment of a Voluntary Claims Resolution Program in the Superior Court of the Virgin Islands. ("Motion"). According to the Motion, the proposed program was to b
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
rtainly not the Estate, can ensure that its interests are protected. Further, as discussed in the Government's Motion in Opposition to the Estate's Expedited Motion for Establishment of a Voluntary Claims Resolution, a significant conflict of interest exists on the part of the Executors. See Ex. 1, at 10. The Executors of Epstein's E
st Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of E
spiratorial acts are ongoing. E. The Epstein Enterprise Used Corporate Entities to Defraud the Government and Fund its Criminal Activities [note: Indyke and Kahn are Treasurer and Secretary of Sun Trust Company] 104. In October 2012, the Southern Trust Company applied for economic benefits from the
around the's filing accusing the executors of complicity? Last month, George brought charges against Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of Epstein's alleged fraud. George also put claims on Epstein's two islands. Thanks. Epstein's lawyers in dis
ngage in a course of conduct aimed at concealing the criminal activities of the Epstein Enterprise. On November 24, 2019, Epstein's Estate filed an Expedited Motion for Establishment of a Voluntary Claims Resolution Program in the Superior Court of the Virgin Islands. ("Motion"). According to the Motion, the proposed program was to b
Entities connected to both Darren Indyke and Expedited Motion for Establishment of a

Jeffrey Epstein
PERSON
Richard Kahn
PERSONLarry Visoski
PERSON
JPMorgan Chase
ORGANIZATIONSouthern Trust Company
ORGANIZATIONHyperion Air
ORGANIZATION
Ghislaine Maxwell
PERSON
Deutsche Bank
ORGANIZATION
U.S. Virgin Islands
LOCATION
United States
LOCATION
Financial Trust Company
ORGANIZATION
Condoleezza Rice
PERSON
Jes Staley
PERSONHBRK Associates
ORGANIZATION
New York
LOCATIONGratitude America
ORGANIZATION
Les Wexner
PERSON
Prince Charles
PERSON
Glenn Dubin
PERSONVirgin Islands Department of Justice
ORGANIZATION