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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
and death in prison in 2019. 215. The continued criminal conduct by Defendants has caused repeated and continuous injury. The criminal conduct of the Epstein Enterprise was not completed nor were all damages incurred until the wrongdoing ceased. COUNT ONE Human Trafficking — Trafficking an Individual Violation 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
n 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 and sexual servitude of underage girls and young women by providing the secluded properties at, from, or to which E
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
ch 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 servitude of underage girls and young women by providing the secluded properties at, from, or to which E
iability and accountability." (Id., at 18.) The New York Times reports that this lawsuit "seeks to head off an effort by Mr. Epstein's executor, Mr. Indyke, to turn Mr. Epstein's vast wealth into a victim's compensatory fund."' Particularly in light of these recent developments, plaintiffs deserve to k
pecifically addresses the Program, describing it as a continuation of the Estate's "course of conduct aimed at concealing the criminal activities of the Epstein Enterprise ... and shield[ing] its participants from liability and accountability." (Id., at 18.) The New York Times reports that this lawsuit "seeks to head
Entities connected to both Darren Indyke and the Epstein Enterprise

Jeffrey Epstein
PERSON
Richard Kahn
PERSON
Julie K. Brown
PERSON
Alan Dershowitz
PERSON
Ghislaine Maxwell
PERSON
Deutsche Bank
ORGANIZATION
U.S. Virgin Islands
LOCATION
Condoleezza Rice
PERSON
Donald Trump
PERSON
Nassau
LOCATIONV.I.C.
ORGANIZATION
Hartford
LOCATIONSecond Circuit
ORGANIZATIONthe Epstein Estate
ORGANIZATION
Albright
PERSONMartindell
PERSONthe Superior Court
ORGANIZATIONMotley Rice
PERSON
Nautilus
ORGANIZATIONBridgeport
LOCATION