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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
the EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN, and ADMINISTRATOR OF THE 1953 TRUST; ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, INC., SOUTHERN TRUST COMPANY, INC.; JOHN AND JANE DOES DEFENDANTS, Case No.: ACTION FOR
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
s of The Estate, Darren K. Indyke and Richard D. Kahn, filed a Petition for Probate and Letters Testame
T. THOMAS AND ST. JOHN GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, INC., JOHN AND JANE DOES DEFENDANTS, Case No.: ACTION FOR DAMAGES JURY TRIAL DEMANDED 01
erty for personal use." Darren Indyke and Richard Kahn, Executors of the Estate, are the secretary and
1. Epstein was president and director of Nautilus, Inc., which corporate filings describe as "holding property for personal use." Darren Indyke and Richard Kahn, Executors of the Estate, are the secretary and treasurer of Nautilus, Inc., respectively. The Estate values Epstein's holdings of Nautilus, Inc.,
T. THOMAS AND ST. JOHN GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, INC., JOHN AND JANE DOES DEFENDANTS, Case No.: ACTION FOR DAMAGES JURY TRIAL DEMANDED CO
s of The Estate, Darren K. Indyke and Richard D. Kahn, filed a Petition for Probate and Letters Testame
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
T. THOMAS AND ST. JOHN GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, INC., JOHN AND JANE DOES DEFENDANTS, Case No.: ACTION FOR DAMAGES JURY TRIAL DEMANDRD
019; WHEREAS, ownership of 100% of the Membership Units of the Company has vested in the Estate of Jeffrey E. Epstein of which Darren K. Indyke and Richard D. Kahn are Co-Executors and which is the sole member of the Company; WHEREAS, Article V of the Articles of Organization provides that the Company shall be
e date first set forth above. ESTATE OF JEFFREY E. EPSTEIN By: Darren K. Indyke, Co-Executor ks24.1,42_ -and- 7 ) IV it 'n) , By: ( Richaidt. Kahn, Co-Executor CONFIDENTIAL SDNY_GM_000 13473 CONFIDENTIAL FirstBankPR000636 EFTA_BOUNl 16 EFTA01269320 Business Entity No. 585782 Government
odian of the corporate records and the proper officer to execute this certificate. I further certify that the records of this office disclose that GREAT ST. JIM, LLC Limited Liability Company was duly, registered to conduct business in the Territory on October 26, 2015 and has a legal existence as a L
From: jeffrey E. <[email protected]> Sent: Wednesday, December 21, 20164:45 AM To: Richard Kahn Subject: Re: JDG'S INVOICE NO. 16-011.1 FOR A-E SERVICES ON GREAT ST. JAMES did not approve he just billeed„ relax = why are you working On Tue,
Wednesday, December 21, 20164:45 AM To: Richard Kahn Subject: Re: JDG'S INVOICE NO. 16-011.1 FOR A-E
<[email protected]> Sent: Wednesday, December 21, 20164:45 AM To: Richard Kahn Subject: Re: JDG'S INVOICE NO. 16-011.1 FOR A-E SERVICES ON GREAT ST. JAMES did not approve he just billeed„ relax = why are you working On Tue, Dec 20, 2016 at 9:39 PM, Richard Kahn < wrote: matter. Not sure if y
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
he EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN, and ADMINISTRATOR OF THE 1953 TRUST; ESTATE OF JEFFREY E. EPSTEIN; THE 1953 TRUST; PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, Inc.; SOUTHERN TRUST COMPANY, INC.; CYPRESS, INC.; MAPLE, INC.; LAUREL, INC.; AND JOHN AND
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
he EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN, and ADMINISTRATOR OF THE 1953 TRUST; ESTATE OF JEFFREY E. EPSTEIN; THE 1953 TRUST; PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, Inc.; SOUTHERN TRUST COMPANY, INC.; CYPRESS, INC.; MAPLE, INC.; LAUREL, INC.; AND JOHN AND
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
T. THOMAS AND ST. JOHN GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS. PLAINTIFF, V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, INC'., JOHN AND JANE DOES DEFENDANTS. Case No.: ACTION FOR DAMAGES JURY TRIAL DEMANDED C
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
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 defendants. In conformity with Title 14 VIC. §610(e), from the time of the filing
Entities connected to both Richard Kahn and GREAT ST

Jeffrey Epstein
PERSONDarren Indyke
PERSONLarry Visoski
PERSONHBRK Associates
ORGANIZATION
Condoleezza Rice
PERSONLeon Black
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Woody Allen
PERSON
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSON
Wilbur Ross
PERSONErika Kellerhals
PERSON
FedEx
ORGANIZATION
United States
LOCATION
Samantha Power
PERSON
U.S. Virgin Islands
LOCATION
St Thomas
LOCATION
Jes Staley
PERSON
Julie K. Brown
PERSON