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liam H. Narwold William H. Narwold, Esq. Motley Rice LLC One Corporate Center 20 Church Street, 17th
n Defendants and Epstein Estate Executors Darren Indyke and Richard Kahn served, respectively, as Secretary and Treasurer—knowingly participated in the Epstein Enterprise and facilitated the trafficking and sexual servitude of underage girls and young women by providing the secluded properties at, from, or to which E
liam H. Narwold William H. Narwold, Esq. Motley Rice LLC One Corporate Center 20 Church Street, 17th
ch CICO action Defendants and Epstein Estate Executors Darren Indyke and erved, respectively, as Secretary and Treasurer—knowingly participated in the Epstein Enterprise and facilitated the trafficking and sexual servitude of underage girls and young women by providing the secluded properties at, from, or to which E
nger LINDA SINGER Admitted Pro Hac Vice Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC
and death in prison in 2019. 215. The continued criminal conduct by Defendants has caused repeated and continuous injury. The criminal conduct of the Epstein Enterprise was not completed nor were all damages incurred until the wrongdoing ceased. COUNT ONE Human Trafficking — Trafficking an Individual Violation of
Entities connected to both Condoleezza Rice and the Epstein Enterprise

Jeffrey Epstein
PERSON
Richard Kahn
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
Donald Trump
PERSON
Alan Dershowitz
PERSON
U.S. Virgin Islands
LOCATION
Deutsche Bank
ORGANIZATIONBridgeport
LOCATION
Nassau
LOCATION
Hartford
LOCATIONV.I.C.
ORGANIZATIONMotley Rice
PERSONSecond Circuit
ORGANIZATION
Albright
PERSONNew York Court
ORGANIZATIONthe Superior Court
ORGANIZATIONthe Epstein Estate
ORGANIZATION
Nautilus
ORGANIZATION