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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-
. often from Eastern Europe" to the United States on Epstein's private jets.; II. JP Morgan Knew Epstein Was a Felon, Registered Sex Offender, and Alleged Child Trafficker 41. JP Morgan did business with Jeffrey Epstein from as early as 1998 to 2013. In that time. JP Morgan serviced approximately fifty-fi
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-
. often from Eastern Europe" to the United States on Epstein's private jets.' II. JP Morgan Knew Epstein Was a Felon, Registered Sex Offender, and Alleged Child Trafficker 41. JP Morgan did business with Jeffrey Epstein from as early as 1998 to 2013. In that time, JP Morgan serviced approximately fifty-fi
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-
. often from Eastern Europe" to the United States on Epstein's private jets? II. JP Morgan Knew Epstein Was a Felon, Registered Sex Offender, and Alleged Child Trafficker 41. JP Morgan did business with Jeffrey Epstein from as early as 1998 to 2013. In that time, JP Morgan serviced approximately fifty-fi
Entities connected to both Darren Indyke and Alleged Child

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