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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
thern Trust Company. 38. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 39. The Attorney General brings this action to seek all remedies a
ll IMAM TO INVESTIGATION AND TWAT AM FALSE OR CRIIIONUT AI N1 OANY CIEMION MAY AI 0•01010$ 102 WHIM OR SMSI 4TtVOC TION Of REGISILMOIL SIGNATURE FtIchard Kahn At. DA. MEW REST tome AND LAST NAME SIGNATURE Joey Epstein DALE POSED REST NAME AND LAST NAME • if DIE LAST REPORT DOES NOT COVER NE PERIOD I
RAC, 10 INVIIMGADON AMC THAI ANY MIK OR DONONESI ANSWER TO ANT (WISDOM MAY III WO* DENIAL OR SMISIQUINI Of REGISMADOK • MEASURE SIGNAM ASMArr1 Kahn MOW HIM NAME AND IASI NAME PRINTED FoosT NMI AND LAST NAME EFTA00073410 THE UNITED STATES IRRGIN ISLANDS OFFICE OF THE LIEUTENANT GOVERNOR DIV
Is for the hood Ended lone )06 2013 1000 Ham corse• mock I 01 pa ...Ment/ThittlItTI.FITIt s 0 rn ' 3 <0 • rrl Arri (Attach checks payable to The Government of the Virgin Islands sad mall documents Is the Offlee of the Lieutopat goseracticti tMsloa of Corporation sad Trademarks, I I, St. Thomas, VI 00802-64$7.) 0 „--‘sident
cessor elected , St. Thomas, USVI 00802 Richard Kahn,Treasurer/Director Serves unhl successor elected
ND T. WM FULL KNOWLEISO All STARAMM MADE IN MT APPUCAION AN ILIAC! TO iNVISTIGATION GROUNDS ERR PIRAL OR SlifSIQUENT RE Of REGISTRATION SiGNAPJ Richard Kahn r.,14 0/v PRIMED REST NAME MO LAST NAME PRETroforf SIGNATURE Jeffrey Epstein TA/St OR OISMTHEST A3RTWER TO ANY ouesnoN MAY IN PRINTED ARSE NAME AP
6 S c. Total Pellet), And Interest. Co " 6) TOTAL DUE AND FORWARDED HEREWITH (Sum of (4) (b) and (5) (c) ti 1r4rn (Attach cheeks payable to The Government of the Virgin Islands and mall documents to the Office of the Lieu tenadcrovernor, DWIsion of Corporation and Trademarks, St. Thomas, VI 001101-6487.) President EFTA00
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
d Little St. James. 35. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 36. The Attorney General brings this action to seek all remedies a
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.,
d Little St. James. 35. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 36. The Attorney General brings this action to seek all remedies a
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
d Little St. James. 35. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 36. The Attorney General brings this action to seek all remedies a
TIRE ADORESS TERM EXPIRATION Jeffrey E Epstein, President/Dr/IC/Of 6100 Red Hook Quarter, B3. St. Thomas, USVI 00802 servos Intl Successa elected Richard Kahn,TreasuredDirector 130 East 75th Street, Apt 7E. New York, NY 10021 SSW Una successor eleCTOI Mtn" iner LvaF" sistesesetarY"'“" 2 Kean Court, Living
USVI 00802 servos Intl Successa elected Richard Kahn,TreasuredDirector 130 East 75th Street, Apt 7E. N
And Interest. i $ . -- 0 01 n5 - e - 6) TOTAL WE AND FORWARDED HEREWITH (Sam of (4) (b) and (5) (c) ---1 rtri (Attach cants canto payable to The Government of the Virgin Islands and mall documents to the Office of the lieutetaattportnior. Division of Corporatist sad Trademarks, 5049 Kongens Gado, St. Thomas, VI 00802-6487.)
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
ing regulations is to give law enforcement real-time information so that it can act to detect violations of the law and protect public safety. 89. The Government of the Virgin Islands did not know, and could not have known, that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind eye t
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
ing regulations is to give law enforcement real-time information so that it can act to detect violations of the law and protect public safety. 89. The Government of the Virgin Islands did not know, and could not have known, that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind eye t
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
ing regulations is to give law enforcement real-time information so that it can act to detect violations of the law and protect public safety. 89. The Government of the Virgin Islands did not know, and could not have known, that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind eye t
Entities connected to both Richard Kahn and The Government of the Virgin Islands

Jeffrey Epstein
PERSONDarren Indyke
PERSONLarry Visoski
PERSONHBRK Associates
ORGANIZATION
Condoleezza Rice
PERSON
George W. Bush
PERSON
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSON
United States
LOCATION
U.S. Virgin Islands
LOCATION
St Thomas
LOCATION
Jes Staley
PERSONSouthern Trust Company
ORGANIZATION
Prince Charles
PERSON
Financial Trust Company
ORGANIZATION
Sarah Ferguson
PERSON
Deutsche Bank
ORGANIZATION
New York
LOCATION
Glenn Dubin
PERSON
St. Croix
LOCATION