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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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 255. SORCPA requires that offenders required to register provide information relating to intended travel in foreign commerce. 256. On at least two occasions,
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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.1.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
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
register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 356. SORCPA requires that offenders required to register provide information relating to intended travel in foreign commerce. 357. On at least two occasions,
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-
register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 356. SORCPA requires that offenders required to register provide information relating to intended travel in foreign commerce. 357. On at least two occasions,
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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
Entities connected to both Darren Indyke and SORCPA

Jeffrey Epstein
PERSON
Richard Kahn
PERSONLarry Visoski
PERSONSouthern Trust Company
ORGANIZATIONHyperion Air
ORGANIZATION
U.S. Virgin Islands
LOCATION
United States
LOCATION
Financial Trust Company
ORGANIZATION
Condoleezza Rice
PERSON
Jes Staley
PERSON
New York
LOCATIONVirgin Islands Department of Justice
ORGANIZATIONSouthern District
LOCATION
Saint James
LOCATION
Apple
ORGANIZATION
Keystone
ORGANIZATION
St. John
LOCATIONNautilus, Inc.
ORGANIZATION
Washington D.C.
LOCATION
St. Croix
LOCATION