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VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN CIVIL CASE NO.: 012P'41-156. GHISLAINE MAXWELL, Plaintiff, vs. ESTATE OF JEFFREY E. EPSTEIN, DARREN K. INDYKE, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY F.. EPSTEIN, RICHARD D. KAHN, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY E.
of the Virgin Islands. The Estate of Jeffrey E. Epstein was created following Epstein's death and is domiciled in the Virgin Islands. 4. Defendant Darrell K. Indyke is an Executor of the Estate. S. Defendant Richard D. Kahn is an Executor of the Estate. 6. Defendant NES, LLC. is a limited liability company or
nd expenses for a number of other employees in other various lawsuits relating to Epstein, his affiliated businesses, and his alleged victims. 21. Indyke, in his capacity as an Executor of the Estate, also made assurances to Maxwell that Maxwell's legal fees and obligations would be reimbursed by Epst
, Plaintiff, vs. ESTATE OF JEFFREY E. EPSTEIN, DARREN K. INDYKE, in his capacity as EXECUTOR OF THE E
s for NES. LLC. and never received a response. P. Maxwell was also employed by several of Epstein's other entities, including. but not limited to, the C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC, JEGE Inc.. and LSJ, LLC. 53. Upon information and belief, the corporate organizational documents or these othe
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-
addition, Epstein and/or his representatives appeared to be misusing JP Morgan accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
E VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN CIVIL CASE NO.: 6P3D-41-156 GHISLAINE MAXWELL, Plaintiff, vs. ESTATE OF JEFFREY E. EPSTEIN. DARREN K. INDYKE, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY E. EPSTEIN, RICHARD D. KAHN, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY E.
of the Virgin Islands. The Estate of Jeffrey E. Epstein was created following Epstein's death and is domiciled in the Virgin Islands. 4. Defendant Darren K. Indyke is an Executor of the Estate. 5. Defendant Richard D. Kahn is an Executor of the Estate. 6. Defendant NES, LLC. is a limited liability company or
nd expenses for a number of other employees in other various lawsuits relating to Epstein, his affiliated businesses, and his alleged victims. 21. Indyke, in his capacity as an Executor of the Estate, also made assurances to Maxwell that Maxwell's legal fees and obligations would be reimbursed by Epst
, Plaintiff, vs. ESTATE OF JEFFREY E. EPSTEIN. DARREN K. INDYKE, in his capacity as EXECUTOR OF THE E
for NES. LLC. and never received a response. 52. Maxwell was also employed by several of Epstein's other entities, including. but not limited to, the C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC. JEGE Inc., and LSJ. LLC. 53. Upon inronnation and belief. the corporate organizational documents or these othe
s human beings. In this capacity, he is a benefactor but quite often also a mentor. Examples abound. One particularly poignant one was recounted by Darren K. Indyke, general counsel to Jeffrey: Two years ago, a building workman approached Jeffrey with news that the workman's wife needed a kidney transplant and
cational pursuits of his employees (and their family members) as a way of assisting them to better themselves and achieve their full potential. Mr. Indyke has written that over the last six years, Jeffrey has funded literally hundreds of thousands of dollars in tuition assistance to many individuals (
d. One particularly poignant one was recounted by Darren K. Indyke, general counsel to Jeffrey: Two years
d. One particularly poignant one was recounted by Darren K. Indyke, general counsel to Jeffrey: Two years a
oteworthy aspect of Jeffrey's giving: to the extent that it is possible, Jeffrey wants his 2 The Jeffrey Epstein Virgin Islands Foundation, Inc. and the C.O.U.Q. Foundation. 8 Public Records Request No. 19-372 gifts to be anonymous. Where this is not possible, he nonetheless does not seek the spotlight and makes it
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-
CGLacs e. 22-1kod.-CIfia91143BRDOnntuantataa PDS EIC1O12/23 Page 11B aff ain accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
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-
EFTA00161851 Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 17 of 34 accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
to Kahn said, contained Epstein's funeral clothes. Little is known about Kahn outside his work for Epstein. Or about his co- executor, 55-year-old Darren Indyke, who served as Epstein's personal attorney for more than two decades and was apparently so close to Epstein that the money manager paid for fertili
stein's personal attorney for more than two decades and was apparently so close to Epstein that the money manager paid for fertility treatments for Indyke and his wife. Neither man has a public social media account, and both shun press interviews. But both could soon be questioned as part of a lawsuit
r Epstein. Or about his co- executor, 55-year-old Darren Indyke, who served as Epstein's personal attorney
ent for this article, has been an executive with Epstein's shadowy nonprofits since at least 2007. That year, Kahn replaced Maxwell as treasurer of the C.O.U.Q. Foundation and held the role until the charity dissolved five years later. C.O.U.Q. contributed $46 million in stock and other assets to Wexner's YLK Charita
to Kahn said, contained Epstein's funeral clothes. Little is known about Kahn outside his work for Epstein. Or about his co- executor, 55-year-old Darren Indyke, who served as Epstein's personal attorney for more than two decades and was apparently so close to Epstein that the money manager paid for fertili
stein's personal attorney for more than two decades and was apparently so close to Epstein that the money manager paid for fertility treatments for Indyke and his wife. Neither man has a public social media account, and both shun press interviews. But both could soon be questioned as part of a lawsuit
r Epstein. Or about his co- executor, 55-year-old Darren Indyke, who served as Epstein's personal attorney
ent for this article, has been an executive with Epstein's shadowy nonprofits since at least 2007. That year, Kahn replaced Maxwell as treasurer of the C.O.U.Q. Foundation and held the role until the charity dissolved five years later. C.O.U.Q. contributed $46 million in stock and other assets to Wexner's YLK Charita
Entities connected to both Darren Indyke and the C.O.U.Q. Foundation

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Richard Kahn
PERSON
Marc Rich
PERSONLarry Visoski
PERSON
Bella Klein
PERSON
JPMorgan Chase
ORGANIZATIONLeon Black
PERSONSouthern Trust Company
ORGANIZATIONHyperion Air
ORGANIZATION
Ghislaine Maxwell
PERSONJanusz Banasiak
PERSON
Deutsche Bank
ORGANIZATION
U.S. Virgin Islands
LOCATION
United States
LOCATION
Financial Trust Company
ORGANIZATIONJack Goldberger
PERSON
Condoleezza Rice
PERSON
Bradley Edwards
PERSON
Jes Staley
PERSON