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ANDS, 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 the EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN, and ADMINISTRATOR OF THE 1953 TRUST; ESTATE OF JEFFREY E. EPSTEIN, THE 195
efendant Indyke") is co-executor of the Estate of Jeffrey E. Epstein and Administrator of The 1953 Trust. 9. Defendant Richard D. Kahn ("Defendant Kahn") is co-executor of The Estate of Jeffrey E. Epstein and Administrator of The 1953 Trust. 10. Defendant, the Estate of Jeffrey E. Epstein ("Estate
Complaint Page 3 of 55 Petition for Probate and Letters Testamentary which included Epstein's last will and testament with the Probate Division of the Superior Court of the Virgin Islands. 11. The Petition reports the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 12.
SLAINE 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. EPSTEIN, and NES, LLC. a New York Limited Liability Company. Defendants. 18f103 ):10121
uct, and that Epstein's promises would be honored. 23. Epstein %%as found dead on August 10.2019 in New York. 24. On August 15. 2019. Indyke and Kahn filed a petition for probate of Epstein's last will and tostninent with thu Probate Division of the Superior Court of the Virgin Islands. Division o
New York. 24. On August 15. 2019. Indyke and Kahn filed a petition for probate of Epstein's last will and tostninent with thu Probate Division of the Superior Court of the Virgin Islands. Division of St. Thomas and St. John. 25. Maxwell has incurred and will continue to incur significant legal ices. personal security costs, and ot
Document 1 Filed 09/18/19 Page 1 of 16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY E. EPSTEIN, Defendants. Case No. JURY TRIAL DEMANDED COMPLAINT EFTA00103496 Ca
en K. Indyke and Richard D. Kahn attesting to their "Oath of Willingness to Serve as Executor and Appointment of Local Counsel." Mr. Indyke and Mr. Kahn also filed a Petition for Probate and for Letters Testamentary in the Superior Court of the Virgin Islands. 12 EFTA00103507 Case 1:19-cv-08673 D
ner concluded Epstein died by suicide. 64. On August 15, 2019, Epstein's last will and testament (the "Will") was filed in the Probate Division of the Superior Court of the Virgin Islands. 65. The Will indicated that it was executed by Epstein on August 8, 2019 at the Metropolitan Correctional Center, and that it was witnessed by Ma
1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SOUTHERN DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defendants. Case No. COMPLAINT FOR DAMA
en K. Indyke and Richard D. Kahn attesting to their "Oath of Willingness to Serve as Executor and Appointment of Local Counsel." Mr. Indyke and Mr. Kahn also filed a Petition for Probate and for Letters Testamentary in the Superior Court of the Virgin Islands. 30. The Will's first article directs E
ner concluded Epstein died by suicide. 28. On August 15, 2019, Epstein's last will and testament (the "Will") was filed in the Probate Division of the Superior Court of the Virgin Islands. 29. The Will indicated that it was executed by Epstein on August 8, 2019 at the Metropolitan Correctional Center. The Will was accompanied by aff
INDYKE, in his individual capacity and in his capacity as the EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN and ADMINISTRATOR OF THE 1953 TRUST; RICHARD D. KAHN, in his individual capacity and in his capacity as the EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN, and ADMINISTRATOR OF THE 1953 TRUST; ESTATE
ielcIALTIM23 Paggeg of 123 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 3 of 76 9. Defendant Richard D. Kahn ("Defendant Kahn") is co-executor of The Estate of Jeffrey E. Epstein and Administrator of The 1953 Trust and was and/or is a participant in the activity of the "Ep
Indyke and Kahn filed a Petition for Probate and Letters Testamentary which included Epstein's last will and testament with the Probate Division of the Superior Court of the Virgin Islands. 12. The Petition reported the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 13
pstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT THIRTEEN Rape in the 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 14 V.I.0 § 1702 14
iled 01/10/23 Page 4 of 77 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 3 of 76 9. Defendant Richard D. Kahn ("Defendant Kahn") is co-executor of The Estate of Jeffrey E. Epstein and Administrator of The 1953 Trust and was and/or is a participant in the activity of the "Ep
Indyke and Kahn filed a Petition for Probate and Letters Testamentary which included Epstein's last will and testament with the Probate Division of the Superior Court of the Virgin Islands. 12. The Petition reported the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 13
e 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 Division of the Superior Co
ious 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 officers of a
The Executors, Darren Indyke and Richard Kahn, filed a Petition for Probate and 1 EFTA00074744 Letters Testamentary with the Probate Division of the Superior Court of the Virgin Islands on August 15, 2019. Id. 8. The Petition for Probate included Mr. Epstein's Last Will and 'Testament.' Id. Two days before his death, Mr. Epstein a
SHMENT OF A VOLUNTARY CLAIMS RESOLUTION PROGRAM COME NOW the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorable Court for an expedited order to establish an independent and voluntary claims resolution program (the "Program") for purpo
(the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorable Court for an expedited
ates Virgin Islands under Chapter 30 of the Virgin Islands Code, namely, the Criminally Influenced and Corrupt Organizations Act (MO), is pending in the Superior Court of the Virgin Islands naming the ESTATE OF JEFFREY E. EPSTEIN; THE 1953 TRUST; PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC.; AND POLAR, INC. as de
Entities connected to both Richard Kahn and the Superior Court of the Virgin Islands

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Lesley Groff
PERSONLarry Visoski
PERSONHBRK Associates
ORGANIZATION
Condoleezza Rice
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Eric Trump
PERSON
Woody Allen
PERSON
JPMorgan Chase
ORGANIZATION
John F. Kennedy
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
United States
LOCATION
Samantha Power
PERSON
U.S. Virgin Islands
LOCATION
St Thomas
LOCATION
Jes Staley
PERSON