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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
ss to Judicial Records and Discovery Documents. Dated: September 1, 2020 Respectfully submitted, /s/ William H. Narwold William H. Narwold, Esq. Motley Rice LLC One Corporate Center 20 Church Street, 17th Floor Hartford, CT 06103 13 EFTA00073272 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 P
March 23, 2022 to a five year term as the Commissioner to Casino Control.] During the investigation into the EPSTEIN estate it was discovered that Richard Kahn (KAHN) and Darren Indyke (INDYKE) were participants in the human trafficking operation. INDYKE was in charge of coordinating female to female marri
to a five year term as the Commissioner to Casino Control.] During the investigation into the EPSTEIN estate it was discovered that Richard Kahn (KAHN) and Darren Indyke (INDYKE) were participants in the human trafficking operation. INDYKE was in charge of coordinating female to female marriages t
ertaining to Criminally Influenced and Corrupt Organizations Act (C/CO). MOTLEY RICE CICO BRYAN told GEORGE "He's dead go for it". GEORGE contacted Motley Rice (MOTLEY RICE) to assist with CICO and recovering funds from EPSTEIN's estate received due to criminal activity. MOTLEY RICE investigated with foren
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
o triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David 1. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 849-4962 [email protected] CAROL THOMAS-JACOBS (NYS Bar #2941300) Admit
tein. Indyke was a signatory on Southern Trust's primary bank account to which funds were wired, primarily from a single source, as described below. Kahn, as Southern Trust's treasurer, oversaw its accounting, invoicing, and tax reporting. Indyke also authorized a majority of the wire transfers from
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
GREED. 10 EFTA00162372 O2taaa22222ettleD29214SERRCiThitarmanit+261I2 Plagttelnothfl .113 /s/ Linda Singer LINDA SINGER Admitted Pro Hac Vice Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 232-5504 [email protected] Dated: January 9, 2023 SO ORDERED. Dated: New
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
o triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David I. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 849-4962 [email protected] CAROL THOMAS-JACOBS (NYS Bar #2941300) Admit
fund the criminal activities of the Epstein Enterprise. In addition, the Epstein Enterprise, with the active participation of Defendants Indyke and Kahn, used Southern Trust Company to employ, pay, and conceal the activities of participants in the criminal activities of the Enterprise. 393. The Ep
10 EFTA00161956 Gbase11222€6140002143$33R MeauneettlE62 F(rli£dcDQ11DP.VZ3 Flaajgethottill /s/ Linda Singer LINDA SINGER Admitted Pro Hac Vice Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 232-5504 [email protected] Dated: January 9, 2023 SO ORDERED. Dated: New
Entities connected to both Richard Kahn and Motley Rice

Jeffrey Epstein
PERSONDarren Indyke
PERSONLarry Visoski
PERSONHBRK Associates
ORGANIZATION
Condoleezza Rice
PERSON
Alan Dershowitz
PERSON
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
United States
LOCATION
U.S. Virgin Islands
LOCATION
Jes Staley
PERSON
Julie K. Brown
PERSONSouthern Trust Company
ORGANIZATION
Prince Charles
PERSON
New York City
LOCATION
Financial Trust Company
ORGANIZATION
Deutsche Bank
ORGANIZATION
New York
LOCATION
Paul Ryan
PERSON