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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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 255. SORCPA requires that offenders required to register provide information relating to intended travel in foreign commerce. 256. On at least two occasions,
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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
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.,
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.1.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
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
register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 356. SORCPA requires that offenders required to register provide information relating to intended travel in foreign commerce. 357. On at least two occasions,
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
register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 356. SORCPA requires that offenders required to register provide information relating to intended travel in foreign commerce. 357. On at least two occasions,
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
, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. 242. On at least two occasions, Epstein trav
Entities connected to both Richard Kahn and SORCPA

Jeffrey Epstein
PERSONDarren Indyke
PERSONLarry Visoski
PERSON
Condoleezza Rice
PERSON
United States
LOCATION
U.S. Virgin Islands
LOCATION
Jes Staley
PERSONSouthern Trust Company
ORGANIZATION
Financial Trust Company
ORGANIZATION
New York
LOCATION
St. Croix
LOCATION
Saint James
LOCATION
Apple
ORGANIZATIONHyperion Air
ORGANIZATION
St. John
LOCATION
Red Hook
LOCATIONSouthern District
LOCATION
Washington D.C.
LOCATIONNautilus, Inc.
ORGANIZATION
Monaco
LOCATION