Epstein Secrets

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

ed and Corrupt Organizations Act ("CICO") enforcement action against the Estate of Jeffrey E. Epstein and several Epstein-controlled entities before the Superior Court of the U.S. Virgin Islands. See Exhibit A hereto (USVI's operative First Amended Complaint, filed February 11, 2020). Access to other judicial docu

fied as described below. I. BACKGROUND On November 12, 2019, Plaintiff filed a Complaint against Ms. Maxwell and Defendants Darren K. Indyke and Richard D. Kahn in their official capacities as appointed executors of the Estate of Jeffrey E. Epstein (the "Estate") (Indyke and Kahn together, the "Co-Executors"

ren K. Indyke and Richard D. Kahn in their official capacities as appointed executors of the Estate of Jeffrey E. Epstein (the "Estate") (Indyke and Kahn together, the "Co-Executors"). The Complaint alleges claims of battery, false imprisonment and intentional infliction of emotional distress under N

Filed 02/10/21 Page 2 of 6 Epstein's and Ms. Maxwell's alleged sexual abuse of Plaintiff. Defendants did not file counterclaims. On June 2, 2020, the Superior Court of the United States Virgin Islands granted the Co- Executors' motion to establish the Epstein Victims' Compensation Program, a voluntary independen

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

er situated...to the then acting Trustees of The 1953 Trust." 67. On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn are the two Trustees of The 1953 Trust. See Certificate of Trust, In the 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

3 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 31. On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn arc the two Trustees of The 1953 Trust. 32. On September 6, 2019, Magistr

e Manager unless a greater number of Managers shall be fixed from time to time by action of the Members. The initial Manager of the Company shall be Richard Kahn. A Manager shall hold office until his, her or its death, removal, or resignation. 5.2 Management Authority. (a) Except as otherwise authorized i

initial Manager of the Company shall be Richard Kahn. A Manager shall hold office until his, her or it

regarding conflict of laws. The Company and each of the Members agree to submit to personal jurisdiction and to waive any objection as to venue in the Superior Court or the United States District Court located in 15 EFTA00809818 St. Thomas in the United States Virgin Islands. Service of process on the Company

e Manager unless a greater number of Managers shall be fixed from time to time by action of the Members. The initial Manager of the Company shall be Richard Kahn. A Manager shall hold office until his, her or its death, removal, or resignation. 5.2 Management Authority. (a) Except as otherwise authorized i

initial Manager of the Company shall be Richard Kahn. A Manager shall hold office until his, her or it

regarding conflict of laws. The Company and each of the Members agree to submit to personal jurisdiction and to waive any objection as to venue in the Superior Court or the United States District Court located in 15 EFTA00809799 St. Thomas in the United States Virgin Islands. Service of process on the Company

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

iminal Activity Lien Notice pursuant to Chapter 30, Title 14 § 610, in the matter ESTATE OF JEFFREY E. EPSTEIN, PROBATE NO. ST-19-PB-80, pending in the Superior Court of the Virgin Islands, Division of St. Thomas and St. John. A civil proceeding. Case No. ST-2020-CV-14. having been instituted by the Government of