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s expenses incurred during each of these years by omitting the annual amounts of property taxes it paid for the New York property. 414. Defendant Laurel misrepresented the value of its assets held during each of these years by omitting the value of the 358 Brillo Way, Palm Beach, Florida property tha
t Laurel, Inc. acquired ownership of the property 358 Brillo Way in Palm Beach, Florida in or about December 2011, shortly after Cyrpess was formed. Laurel acquired ownership of the property from Epstein personally. EFTA00162322 daelnazati-lThh1BER fiamiumetttafill FFilleildraB1233 Flgaffe fatal/2/3
180. Defendant Maple, Inc. acquired ownership of the property 9 East 71st Street in New York, New York on or about December 23, 2011, shortly after Maple was formed. Maple acquired ownership of the property from Nine East 71st Street Corporation, which was owned by Epstein. 181. Defendant Laurel, I
d and did not include any expenses related to the Palm Beach property in the total expenses it reported to the Government. 193. Neither Cypress's, Maple's, nor Laurel's financial statements ever reflected the reality of the above assets held or the above expenses incurred by each entity. 194. The Ann
lected the reality of the above assets held or the above expenses incurred by each entity. 194. The Annual Reports submitted on behalf of Cypress, Maple, and Laurel all were signed by Epstein and Defendant and Co-Executor Kahn with the representation that "ALL STATEMENTS CONTAINED IN THIS APPLICATIO
t Laurel, Inc. acquired ownership of the property 358 Brillo Way in Palm Beach, Florida in or about December 2011, shortly after Cyrpess was formed. Laurel acquired ownership of the property from Epstein personally. EFTA00161906 Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 38 of 77 GVI v
lected the reality of the above assets held or the above expenses incurred by each entity. 194. The Annual Reports submitted on behalf of Cypress, Maple, and Laurel all were signed by Epstein and Defendant and Co-Executor Kahn with the representation that "ALL STATEMENTS CONTAINED IN THIS APPLICATIO
180. Defendant Maple, Inc. acquired ownership of the property 9 East 71st Street in New York, New York on or about December 23, 2011, shortly after Maple was formed. Maple acquired ownership of the property from Nine East 71st Street Corporation, which was owned by Epstein. 181. Defendant Laurel, I
d and did not include any expenses related to the Palm Beach property in the total expenses it reported to the Government. 193. Neither Cypress's, Maple's, nor Laurel's financial statements ever reflected the reality of the above assets held or the above expenses incurred by each entity. 194. The Ann
s expenses incurred during each of these years by omitting the annual amounts of property taxes it paid for the New York property. 414. Defendant Laurel misrepresented the value of its assets held during each of these years by omitting the value of the 358 Brillo Way, Palm Beach, Florida property tha
predicate acts as defined by CICO, including but not limited to making fraudulent claims upon the Government. 411. Defendants Cypress, Maple, and Laurel misrepresented the values of their assets held and expenses incurred in their annual reporting to the Government of the United States Virgin Island
e criminal predicate acts as defined by CICO, including but not limited to making fraudulent claims upon the Government. 411. Defendants Cypress, Maple, and Laurel misrepresented the values of their assets held and expenses incurred in their annual reporting to the Government of the United States V
nsportation, LLC 100% 323,907 323,907 LSI LLC 100% 6,400 MOO Cypress, Inc 100% 17.539,837 17,760,284 Zorro Management LLC 100% 205,186 Laurel, Inc 100% 12,800,364 13,814,238 Neptune LLC 100% 114,280 Maple, Inc. 100'/0 56,331,414 56,257,2fKi NES LLC WO% 289,442 Plan D LLC 100%
rd Kahn as Joint Personal Representatives NY ttate of Jeffrey Epstein, Nine East 71st Street, Corporation. Financial Than Company, Inc., NIS,11.C, Maple, Inc-, 11RRK Associates, Inc., and JEGII, Inc., Coe No. 1:19-cv-07772 (S.D.N.Y.) v. Darren K. Indyke and Richard D. Kahn es Joint Personal Reptche
Entities connected to both Laurel and Marla Maples

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Joi Ito
PERSONDoug Band
PERSON
Joe Biden
PERSON
Samantha Power
PERSONCleary Gottlieb Steen & Hamilton LLP
ORGANIZATION
Richard Kahn
PERSONMaria Farmer
PERSON
Vicky Ward
PERSON
Prince Andrew
PERSON
Donald Trump
PERSONLeon Black
PERSON
Condoleezza Rice
PERSON
Stephen Hawking
PERSON
Marc Rich
PERSON
NEW YORK NY
LOCATIONGlendower
LOCATION