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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
tiOCIEIMME Figtige/36ailVZ'3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 35 of 76 with Epstein. Indyke was a signatory on Southern Trust's primary bank account to which funds were wired, primarily from a single source, as described below. Kahn, as Southern Trust's treasurer, oversaw it
any, knowing such claims to be false, fictitious, or fraudulent; knowingly and willfully falsified, concealed or covered up material facts regarding the Southern Trust Company; made false or fraudulent statements or representations about the purpose, activities, income, and employment of Southern Trust Company; and made an
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
Epstein's bestowal of financial and other benefits, including sexual services and forced labor from victims. Id. at 157-195. 25. In October 2012, the Southern Trust Company—one of the companies Epstein owned—applied for economic benefits from the Virgin Islands Economic Development Commission ("EDC") so the company cou
F THE 1953 TRUST; ESTATE OF JEFFREY E. EPSTEIN; 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 SE
iled 01/10/23 Page 36 of 77 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 35 of 76 with Epstein. Indyke was a signatory on Southern Trust's primary bank account to which funds were wired, primarily from a single source, as described below. Kahn, as Southern Trust's treasurer, oversaw it
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
any, knowing such claims to be false, fictitious, or fraudulent; knowingly and willfully falsified, concealed or covered up material facts regarding the Southern Trust Company; made false or fraudulent statements or representations about the purpose, activities, income, and employment of Southern Trust Company; and made an
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
operty's estimated cost basis. The underlying real property and rights will be appraised, and an updated value will be provided upon completion. 19 Southern Trust Company, Inc. has an estimated value of $233,611,964.00. This entity will be appraised, and an updated value will be provided upon completion. 20 FT Real Estate,
Entities connected to both Laurel and Southern Trust Company

Jeffrey Epstein
PERSONDarren Indyke
PERSONHyperion Air
ORGANIZATION
Richard Kahn
PERSON
U.S. Virgin Islands
LOCATION
Martha Stewart
PERSON
Financial Trust Company
ORGANIZATIONHBRK Associates
ORGANIZATION
Deutsche Bank
ORGANIZATION
United States
LOCATION
John Brennan
PERSON
Prince Andrew
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSONNeptune
ORGANIZATION
Marc Rich
PERSON
Bill Clinton
PERSONAce Greenberg
PERSON
St Thomas
LOCATION
George W. Bush
PERSON