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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 by Epstein or related entitie
lawyer, Darren K. Indyke, and accountant, Richard Kahn, now the Co- Executors of Epstein's Estate, autho
ce to monitor and identify unusual activity."2 When a bank detects suspicious activity, it is required to report that information within 30 days to the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN"). The reporting requirement ensures that the government is able to monitor and act wh
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
ce to monitor and identify unusual activity."2 When a bank detects suspicious activity, it is required to report that information within 30 days to the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN"). The reporting requirement ensures that the government is able to monitor and act FF
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
ce to monitor and identify unusual activity."' When a bank detects suspicious activity, it is required to report that information within 30 days to the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN"). The reporting requirement ensures that the government is able to monitor and act FF
Entities connected to both Richard Kahn and the U.S. Department of

Jeffrey Epstein
PERSONDarren Indyke
PERSONLarry Visoski
PERSONHBRK Associates
ORGANIZATION
Condoleezza Rice
PERSON
Prince Andrew
PERSON
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSON
United States
LOCATION
U.S. Virgin Islands
LOCATION
Jes Staley
PERSONSouthern Trust Company
ORGANIZATION
Prince Charles
PERSON
Harry Reid
PERSON
Financial Trust Company
ORGANIZATIONMartin Weinberg
PERSON
Deutsche Bank
ORGANIZATION
New York
LOCATION
Glenn Dubin
PERSON
Reid Weingarten
PERSON