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ification form did not disclose travel to any other countries. It was later discovered by law enforcement authorities that Epstein also travelled to Vienna and Monaco during that trip. 80. Similarly, the Epstein Enterprise sought to prevent DPNR from conducting routine site visits to inspect unpermit
tates Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 3 V.I.C. § 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of
ification form did not disclose travel to any other countries. It was later discovered by law enforcement authorities that Epstein also travelled to Vienna and Monaco during that trip. 80. Similarly, the Epstein Enterprise sought to prevent DPNR from conducting routine site visits to inspect unpermit
tates Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 3 V.I.C. § 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of
te of Jeffrey Epstein GVI's First Amended Complaint Page 17 of 55 It was later found by law enforcement authorities that Epstein also travelled to Vienna and Monaco during that trip. 83. Similarly, the Epstein Enterprise sought to prevent DPNR from conducting routine site visits to inspect unpermit
tates Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 3 V.I.C. § 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of
ification form did not disclose travel to any other countries. It was later discovered by law enforcement authorities that Epstein also travelled to Vienna and Monaco during that trip. 80. Similarly, the Epstein Enterprise sought to prevent DPNR from conducting routine site visits to inspect unpermit
tates Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 3 V.I.C. § 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of
ification form did not disclose travel to any other countries. It was later discovered by law enforcement authorities that Epstein also travelled to Vienna and Monaco during that trip. 80. Similarly, the Epstein Enterprise sought to prevent DPNR from conducting routine site visits to inspect unperrni
Trust, and numerous Epstein business affiliates and associates for violation of the Criminally Influenced and Corrupt Organization Act ("CICO"). 14 V.I.C. § 600 et seq., and civil conspiracy, seeking forfeiture and divestment of assets in favor of the Government, civil penalties, damages, and other re
s notification form did not disclose travel to any other countries. It was later found by law enforcement authorities that Epstein also travelled to Vienna and Monaco during that trip. 135. Similarly, the Epstein Enterprise sought to prevent DPNR from conducting routine site visits to inspect unpermi
ations of Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges
ders required to register provide information relating to intended travel in foreign commerce. 357. On at least two occasions, Epstein traveled to Vienna and Monaco without disclosing that travel to the Virgin Islands sex offender registry. EFTA00162348 Glaffiella2a3m-MEDArlSIR firlimuneent3ffill F
ceased. COUNT ONE Human Trafficking — Trafficking an Individual Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"), 14 V.I.C. § 600 et seq. and 14 V.I.0 § 133 216. The Government restates and realleges paragraphs 1 to 215 of this Complaint as if fully set forth herein. 2
s notification form did not disclose travel to any other countries. It was later found by law enforcement authorities that Epstein also travelled to Vienna and Monaco during that trip. 135. Similarly, the Epstein Enterprise sought to prevent DPNR from conducting routine site visits to inspect unpermi
ations of Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges
Entities connected to both Vienna and V.I.C.

Jeffrey Epstein
PERSON
George W. Bush
PERSON
United States
LOCATION
Prince Andrew
PERSON
U.S. Virgin Islands
LOCATION
Prince Charles
PERSON
New York
LOCATION
Donald Trump
PERSON
Woody Allen
PERSON
Marc Rich
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSONDarren Indyke
PERSON
Stephen Hawking
PERSON
Julie K. Brown
PERSON
Michael Jackson
PERSON
Samantha Power
PERSON
Boris Nikolic
PERSON
Ghislaine Maxwell
PERSON