Epstein Secrets

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

nterprise, and to provide a source of income to support his criminal activities and properties in the Virgin Islands. 2. Defendants Cypress, Inc.; Maple, Inc.; and Laurel, Inc. 177. Epstein formed Cypress, Inc.; Maple, Inc.; and Laurel, Inc. as Virgin Islands corporations in or about November 2011. 178.

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

airs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT TWENTY-FIVE Fraudulent Claims Upon the Government—Cypress, Inc.; Maple, Inc.; Laurel, Inc. Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §.§. 600 et seq. and 14 V.I.C. § 843 408. The Gover

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%

press, 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% 17,876,274 17,000,000 JEGE LLC 100% (17,791) Hyperion Air LLC 100%

E UNITED STATES VIRGIN ISLANDS THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT, WITH Laurel ICSDec 2018009/09/20197:33 PM Ms. Erika KELLERHALS Esq Attorney in Fact President Jeffrey EPSTEIN 07/31/2019 Richard KAHN Treasurer 07/31/201

essed value of $13,618,230.00. The underlying real property and rights will be appraised, and an updated value will be provided upon completion. 16 Maple, Inc. holds cash on hand and tide to the real property located at 9 East 7I" Street, New York, New York and all appurtenant rights which for purposes of t

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

N; THE 1953 TRUST; PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, Inc.; SOUTHERN TRUST COMPANY, INC.; CYPRESS, INC.; MAPLE, INC.; LAUREL, INC.; AND JOHN AND JANE DOES, DEFENDANTS. Case No.: ST-20-CV-14 ACTION FOR DAMAGES JURY TRIAL DEMANDED SECOND AMENDED COMPLAINT COMES