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LAINE MAXWELL, Plaintiff, vs. ESTATE OF JEFFREY E. EPSTEIN, DARREN K. INDYKE, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY F.. EPSTEIN, RICHARD D. KAHN, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY E. EPSTEIN, and NES, LLC. a New York Limited Liability Company, Defendants. COMPLAINT ; -;
interest in these events and proceedings. 28. By letter dated November 22, 2019, Maxwell submitted a claim to the Estate, addressed to Indyke and Kahn, requesting that the Estate honor its obligation to provide indemnification as requested in this action. 29. The Estate has not honored or even fo
s for NES. LLC. and never received a response. P. Maxwell was also employed by several of Epstein's other entities, including. but not limited to, the C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC, JEGE Inc.. and LSJ, LLC. 53. Upon information and belief, the corporate organizational documents or these othe
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
addition, Epstein and/or his representatives appeared to be misusing JP Morgan accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
shed by the Daily Mail, which identified the mystery man as Epstein's longtime accountant and a co-executor of his $634 million estate: 47- year-old Richard Kahn. The bag he was carrying, a source with close ties to Kahn said, contained Epstein's funeral clothes. Little is known about Kahn outside his work f
's longtime accountant and a co-executor of his $634 million estate: 47- year-old Richard Kahn. The bag he was carrying, a source with close ties to Kahn said, contained Epstein's funeral clothes. Little is known about Kahn outside his work for Epstein. Or about his co- executor, 55-year-old Darren In
ent for this article, has been an executive with Epstein's shadowy nonprofits since at least 2007. That year, Kahn replaced Maxwell as treasurer of the C.O.U.Q. Foundation and held the role until the charity dissolved five years later. C.O.U.Q. contributed $46 million in stock and other assets to Wexner's YLK Charita
SLAINE MAXWELL, Plaintiff, vs. ESTATE OF JEFFREY E. EPSTEIN. DARREN K. INDYKE, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY E. EPSTEIN, RICHARD D. KAHN, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY E. EPSTEIN, and NES. LLC, a New York Limited Liability Company, Defendants. ..... , : Mt
interest in these events and proceedings. 28. By letter dated November 22, 2019. Maxwell submitted a claim to the Estate, addressed to lndyke and Kahn, requesting that the Estate honor its obligation to provide indemnification as requested in this action. 29. The Estate has not honored or even fo
for NES. LLC. and never received a response. 52. Maxwell was also employed by several of Epstein's other entities, including. but not limited to, the C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC. JEGE Inc., and LSJ. LLC. 53. Upon inronnation and belief. the corporate organizational documents or these othe
shed by the Daily Mail, which identified the mystery man as Epstein's longtime accountant and a co-executor of his $634 million estate: 47- year-old Richard Kahn. The bag he was carrying, a source with close ties to Kahn said, contained Epstein's funeral clothes. Little is known about Kahn outside his work f
's longtime accountant and a co-executor of his $634 million estate: 47- year-old Richard Kahn. The bag he was carrying, a source with close ties to Kahn said, contained Epstein's funeral clothes. Little is known about Kahn outside his work for Epstein. Or about his co- executor, 55-year-old Darren In
ent for this article, has been an executive with Epstein's shadowy nonprofits since at least 2007. That year, Kahn replaced Maxwell as treasurer of the C.O.U.Q. Foundation and held the role until the charity dissolved five years later. C.O.U.Q. contributed $46 million in stock and other assets to Wexner's YLK Charita
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
CGLacs e. 22-1kod.-CIfia91143BRDOnntuantataa PDS EIC1O12/23 Page 11B aff ain accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
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
EFTA00161851 Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 17 of 34 accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
Entities connected to both Richard Kahn and the C.O.U.Q. Foundation

Jeffrey Epstein
PERSON
Marc Rich
PERSONDarren Indyke
PERSON
Lesley Groff
PERSON
Bella Klein
PERSONLarry Visoski
PERSONHBRK Associates
ORGANIZATION
Condoleezza Rice
PERSONLeon Black
PERSONJanusz Banasiak
PERSON
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSON
United States
LOCATION
U.S. Virgin Islands
LOCATION
Jes Staley
PERSONSouthern Trust Company
ORGANIZATION
Prince Charles
PERSON
Financial Trust Company
ORGANIZATION
Stephen Hawking
PERSON
Deutsche Bank
ORGANIZATION