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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 and sexual servit
pstein Estate Executors Darren Indyke and Richard Kahn served, respectively, as Secretary and Treasurer
ties' motions for summary judgment and all unified deposition transcripts and exhibits thereto for use in its pending law enforcement action against the Epstein Estate. BACKGOUND Under Virgin Islands law, the CICO authorizes the USVI through its Attorney General to prosecute a civil action against any persons eng
NYS) Subject: [EXTERNAL] Estate of Jeffrey Epstein Dear I am following up on our conversation from earlier this week. As I mentioned, we represent Richard Kahn, one of the two co-executors of the estate of Jeffrey Epstein, and are hoping to gain access to one of the computers that was seized from Epstein's
r this week. As I mentioned, we represent Richard Kahn, one of the two co-executors of the estate of Je
ner, Daniel H. < >; McDonnell, Hilary >; Lau, Sean (x2742) < > Subject: [EXTERNAL] RE: Estate of Jeffrey Epstein In reviewing videos on behalf of the Epstein Estate in response to subpoenas issued in litigation against JPMorgan and Deutsche Bank in the SDNY, one of the document reviewers came across a video that
,gov> Subject: (EXTERNAL] Estate ofJeffrey Epstein Dear I am following up on our conversation from earlier this week. As I mentioned, we represent Richard Kahn, one of the two co-executors of the estate of Jeffrey Epstein, and are hoping to gain access to one of the computers that was seized from Epstein's
r this week. As I mentioned, we represent Richard Kahn, one of the two co-executors of the estate of Je
l 18, 2023 4:33 PM To: ( USANYS) <[email protected]> Cc: ca; Subject: (EXTERNAL) RE: Estate of Jeffrey Epstein In reviewing videos on behalf of the Epstein Estate in response to subpoenas issued in litigation against JPMorgan and Deutsche Bank in the SDNY, one of the document reviewers came across a video that
shed by the Daily Mail, which identified the mystery man as Epstein's longtime accountant and a co-executor of his $634 million estate: 47- year-old Richard Kahn. The bag he was carrying, a source with close ties to Kahn said, contained Epstein's funeral clothes. Little is known about Kahn outside his work f
's longtime accountant and a co-executor of his $634 million estate: 47- year-old Richard Kahn. The bag he was carrying, a source with close ties 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 In
e the federal judge overseeing the case and indicated Indyke would be deposed "in both his personal capacity and as a co- EFTA00163123 executor of the Epstein Estate," and would "offer extremely relevant testimony" relating to her claims. "Indeed, we have reason to believe he has firsthand knowledge of Jeffrey
shed by the Daily Mail, which identified the mystery man as Epstein's longtime accountant and a co-executor of his $634 million estate: 47- year-old Richard Kahn. The bag he was carrying, a source with close ties to Kahn said, contained Epstein's funeral clothes. Little is known about Kahn outside his work f
's longtime accountant and a co-executor of his $634 million estate: 47- year-old Richard Kahn. The bag he was carrying, a source with close ties 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 In
e the federal judge overseeing the case and indicated Indyke would be deposed "in both his personal capacity and as a co- EFTA01654941 executor of the Epstein Estate," and would "offer extremely relevant testimony" relating to her claims. "Indeed, we have reason to believe he has firsthand knowledge of Jeffrey
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
of Epstein's Enterprise, including the receiving and sending money to other entities they held. 117. Since they were appointed as Co-Executors of the Epstein Estate in 2019, Defendants Indyke and Kahn have approved the release of Estate funds to pay for the legal fees and costs of persons who—like the Co-Execut
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
of Epstein's Enterprise, including the receiving and sending money to other entities they held. 117. Since they were appointed as Co-Executors of the Epstein Estate in 2019, Defendants Indyke and Kahn have approved the release of Estate funds to pay for the legal fees and costs of persons who—like the Co-Execut
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
e order." V.I. R. CIV. P. Rule 24(b)(2). Specifically, the Government is a rightful participant in any program designed to distribute the assets of the Epstein Estate because of its interest in the assets and disposition of the 2 In full, Rule 24 (a)(2) reads: -On a timely motion, the court must permit anyone to i
Entities connected to both Richard Kahn and the Epstein Estate

Jeffrey Epstein
PERSON
Marc Rich
PERSONDarren Indyke
PERSON
Lesley Groff
PERSON
Bella Klein
PERSONLarry Visoski
PERSONHBRK Associates
ORGANIZATION
Condoleezza Rice
PERSONLeon Black
PERSON
Prince Andrew
PERSONJanusz Banasiak
PERSON
Alan Dershowitz
PERSON
Woody Allen
PERSON
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
United States
LOCATION
U.S. Virgin Islands
LOCATION
Jes Staley
PERSON
Julie K. Brown
PERSON