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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
29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to many other Epstein victims in order to maintain their immigration status and the
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
29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to marry other Epstein victims in order to maintain their immigration status and th
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
29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to many other Epstein victims in order to maintain their immigration status and the
P.C., in the place of Arent Fox Kinter Plotkin & Kahn, PLLC . ( signed by Judge Sidney H. Stein ) (p1)
Complaint due for 2/2/98 for Jeffrey E. Epstein ( signed by Judge Denny Chin ). (emil) (Entered: 01/14/1998) 01/20/1998 31 Affidavit of service of Second Amended Complaint as to Ellyn Bank by personal service on 1/10/98; Answer to Second Amended Complaint due on 1/30/98 for Ellyn Bank (ae) (Entered: 01/22/1998) 01/20
Entities connected to both Richard Kahn and Second Amended Complaint

Jeffrey Epstein
PERSON
Marc Rich
PERSONDarren Indyke
PERSONLarry Visoski
PERSONHBRK Associates
ORGANIZATION
Condoleezza Rice
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
United States
LOCATION
U.S. Virgin Islands
LOCATION
Jes Staley
PERSONSouthern Trust Company
ORGANIZATION
Prince Charles
PERSONMaria Farmer
PERSON
Financial Trust Company
ORGANIZATION