OffilellMovi-DIEIRT1HIR fikozurreent3(611. FRI kitiOCIEIMME 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 its accounting, invoicing, and tax reporting. Indyke also authorized a majority of the wire transfers from Southern Trust's bank account in order to fund the various entities and personal bank accounts of Epstein, and had full inquiry capabilities over the account. 170. Bank records show that virtually all of Southern Trust Company's income came from a single source (including related entities). 171. In all, the single source paid $158 million to Defendant Southern Trust Company from 2013 to 2017, which constitutes 85% of the total revenues reported by Southern Trust Company. These funds appear to have not been used to pay for informatics or datamining services. 172. These payments to Southern Trust were the main source of funds for Epstein's Enterprise. Indeed, no other entity in Epstein's Enterprise generated revenues. Funds received from the single source were funneled, at the direction of Kahn and Indyke, to Epstein's personal accounts, and other Epstein entities to fund his criminal activities. 173. For the period between January 1, 2013 and December 31, 2017, Southern Trust Company received tax exemptions totaling $73.6 million. 174. As of December 31, 2017, Southern Trust Company, Inc. elected to file its income tax as an S-corporation, which elects to pass corporate income, losses, deductions and credits through to its sole shareholder—Jeffrey Epstein—for tax purposes. For this time period, Epstein's income tax exemption was $71.3 million. EFTA00162321

GamelnazatillIMITIBIR Elltouunreant3(611. FRIEutiCEILIME23 Figage 1.9_/ at= GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 36 of 76 175. Including gross receipt taxes, the Government currently estimates that, as a result of the EDC incentive, Epstein was able to avoid paying $80,576,236 in taxes. 176. Based upon these facts, it is clear that Southern Trust Company did not perform the "informatics" business represented to the EDC and could not have generated the business income attributable to that business. Instead, upon information and belief, Southern Trust Company existed to secure tax benefits for Epstein, to employ individuals associated with the Epstein Enterprise, 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. As of December 31, 2018, Epstein was listed as President Director and Defendants and Co-Executors Indyke and Kahn were listed, respectively, as Vice President/ Secretary/Director and Treasurer/Director of each of Cypress, Inc.; Maple, Inc.; and Laurel, Inc. 179. Defendant Cypress, Inc. acquired ownership of the property 49 Zone Ranch Road in Stanley, New Mexico in or about December 2011, shortly after Cypress was formed. 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, 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 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 37 of 76 182. Epstein appears to have maintained divided ownership of these properties, transferred ownership of them to the Virgin Islands, and then concealed this fact even from Virgin Islands authorities in an attempt to shield the properties from any judgment in the states where they are located. 183. The financial statements submitted by each of these three Defendant corporations to the Office of Lieutenant Governor of the Virgin Islands were false and misleading due to their failure to include the above properties owned by each company or the related expenses incurred by each company, such as property taxes. 184. For instance, Cypress's Balance Sheet as of December 31, 2018 did not reflect any assets other than cash of $18,824. Further, Cypress reported only $301 in expenses for the year ended December 31, 2018, despite it paying 185. Similarly, in 2017, Cypress reported as its only asset cash in the amount of $29,736 and expenses of $150, despite it paying 186. Similarly, for the tax years 2011 through 2016, Cypress did not include the value of the New Mexico property in the total assets it reported and did not include any expenses related to the New Mexico property in the total expenses it reported to the Government. 187. Likewise, Maple's balance sheet as of December 31, 2018 did not reflect any assets other than cash of $21,265. Further, Maple reported only $300 in expenses for the year ended December 31, 2018, despite it paying EFTA00162323

Clame11222coat-JESPR GDicaurrient3C631 FRISICCULIQUEB FRige /SIRE WM GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 38 of 76 188. Similarly, in 2017, Maple reported as its only asset cash in the amount of $18,281 and expenses of $150, despite it paying 189. Similarly, for the tax years 2011 through 2016, Maple did not include the value of the New York property in the total assets it reported and did not include any expenses related to the New York property in the total expenses it reported to the Government. 190. Likewise, Laurel's balance sheet as of December 31, 2018 did not reflect any assets other than cash in the amount of $20,155. Further, Laurel reported only $300 in expenses for the year ended December 31, 2018, despite it paying 191. Similarly, in 2017, Laurel reported as its only asset cash in the amount of $37,129 and expenses of $150, despite it paying 192. Similarly, for the tax years 2011 through 2016, Laurel did not include the value of the Palm Beach property in the total assets it reported 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 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 APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT . . ." EFTA00162324

ftaffelnalow-1114:1134r1HIR ftElmtunterft3ffill. FRISKUILB/233 FILlaffe7f0cdffr3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 39 of 76 195. In fact, Indyke and Kahn knew or should have known that their attestations were false. Upon information and belief, particularly given the absence of any other justification for these transactions and the fraudulent nature of their reporting, these transactions were made for the sole purpose of sheltering these assets from collection. STATUTES OF LIMITATIONS ARE TOLLED AND DEFENDANTS ARE ESTOPPED FROM ASSERTING STATUTES OF LIMITATIONS AS DEFENSES 1. Equitable Estoppel and Fraudulent Concealment 196. Defendants are equitably estopped from relying upon a statute of limitations defense for conduct that occurred prior to the limitation period because they undertook active efforts to deceive the Government and to purposefully conceal their unlawful conduct and fraudulently assure public authorities that their conduct was in compliance with the laws, all with the goal of avoiding punishment. 197. Defendants were deliberate in taking steps to conceal their criminal sex trafficking and abuse conduct and their fraudulent conduct in obtaining unearned tax benefits from the Government. Defendants' acts of concealment include, but are not limited to, the following. 198. Defendants used Epstein's secluded island of Little St. James and his later purchase of the nearby island of Great St. James to shield their trafficking and sexual abuse of young women and female children from detection by law enforcement authorities and to prevent their victims from escaping. 199. Defendants used Epstein's private aircraft to transport young women and female children to the Virgin Islands and to Little St. James while limiting public observation of this trafficking activity. EFTA00162325

One 11Z120ualISITD3IR ElErnwrreent3ffill. FRiliatUDYL135233 7fiaif3733 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 40 of 76 200. Defendants used Epstein's businesses and ostensibly charitable foundations in the Virgin Islands to make payments to the victims who were trafficked and sexually abused while concealing these payments from detection by law enforcement authorities. 201. Defendants also prevented Epstein Enterprise entity employees from cooperating with law enforcement by requiring them to sign confidentiality and non-disclosure agreements. 202. Defendants also actively obstructed law enforcement by denying investigators access to Little St. James beyond its boat dock. 203. 204. 205. 206. Defendants also concealed their fraud on the Government in obtaining unearned tax benefits by providing false testimony and submitting false and inaccurate reporting to the Economic Development Commission to prevent detection of Defendant Southern Trust Company's non-compliance with requirements concerning the nature of its business and the residency of the persons it employed. 207. The discovery of the nature, scope, and magnitude of Defendants' unlawful conduct and could not have been acquired earlier through the exercise of reasonable diligence. EFTA00162326

(C 11222 coadeR 0ltmwment3E631 FRIERtiCICULTIE23 Fitage 7672 af f J7273 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 41 of 76 2. Continuing Violations 208. The continuous criminal conduct by the Defendants has caused repeated and continuous injury. 209. Defendants criminal trafficking and sexual abuse of young women and female children in the Virgin Islands occurred continuously from Epstein's purchase of Little St. James in 1998 through his arrest and death in prison in 2019. 210. Flight logs and other sources establish that between 2001 and 2019, Defendants transported young women and female children to the Virgin Islands, where they were then transported by private helicopter or boat to Little St. James. 211. Air traffic controllers and airport personnel have reported seeing, as recently as 2018, Epstein leaving his private jet with young girls who appeared to be between the ages of 11 and 18 years. 212. One victim was brought by Defendants more than 50 times between 2000 and 2002, when she was around 18 to 20 years old, to Little St. James, where she was required to have sexual relations with Epstein or his guests multiple times per day and where she saw large numbers of other young women and female children subject to the same treatment. 213. Another victim was brought by Defendants dozens of times between 2004 and 2017 to Little St. James, where she too observed a succession of young women and female children who likewise were transported to the island and were required to have sexual relations with Epstein and his guests. 214. Defendants' fraud on the Government in obtaining unearned tax benefits through Defendant Southern Trust Company likewise was continuous inasmuch as Southern Trust's failure to perform the informatics services that it represented to the Economic Development EFTA00162327

GamtellMew-MglallER Caorwment3E631 FRIERMILIIIIE23 FRagEe74Baff17S3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 42 of 76 Commission and its false reporting of the residency and job descriptions of its employees were continuous from the start of the tax benefits in 2013 through Epstein's arrest 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 the Criminally Influenced and Corrupt Organizations Act ("CICO"), 14 V.I.C. § 600 et seq. and 14 V.I.0 § 133 216. The Government restates and realleges paragraphs 1 to 215 of this Complaint as if fully set forth herein. 217. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 218. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly recruiting, transporting, transferring, harboring, receiving, providing, obtaining, isolating, maintaining, or enticing female children and young women in the furtherance and performance of forced labor, sexual servitude and commercial sexual activity in violation of Virgin Islands laws codified in 14 V.I.C. §§ 133-138. 219. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 220. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. EFTA00162328

ClamelIML2carkiilffiffilJESPR Camwritent3ffill FRIERti0CILIME23 FigtgEe74)1cdUTZ3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 43 of 76 221. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.14 V.I.C. §600 et seq. COUNT TWO Human Trafficking — Trafficking an Individual Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 et seq. and 14 V.I.0 § 133 222. The Government restates and realleges paragraphs 1 to 221 of this Complaint as if fully set forth herein. 223. At all times material herein, each Defendant joined in a conspiracy to violate laws prohibiting human trafficking. 224. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by recruiting, transporting, transferring, harboring, receiving, providing, obtaining, isolating, maintaining or enticing female children and young women in the furtherance and performance of forced labor, sexual servitude and commercial sexual activity in violation of Virgin Islands laws codified in 14 V.I.C. § 133 -138. 225. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. 226. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). EFTA00162329

ClatmellM2mAiffiglaJESPR Camwrreent3E631 FRIEEW0CILI13123 FRatifeethccf GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 44 of 76 227. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT THREE Human Trafficking — Forced Labor Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 et seq. and 14 V.I.0 § 134 228. The Government restates and realleges paragraphs 1 to 227 of this Complaint as if fully set forth herein. 229. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 230. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly using coercion to compel underage girls and young women to provide labor or services by forced labor in violation of 14 V.I.C. § 134. 231. The Epstein Enterprise knowingly provided or obtained the labor services of individuals by means of force, threats of force, physical restraint, and/or threats of physical restraint; by means of serious harm or threats of serious harm; by means of abuse or threatened abuse of law or legal processes; and by means of the Epstein Enterprise with the intent to cause individuals to believe that, if individuals did not perform such labor or services, individuals would suffer serious harm or physical restraint. 232. Defendants through a pattern of criminal activity directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. EFTA00162330

datEarellMierall134rD3IR Dielument3E631 FRilliti0CIEUXE23 Figalre8tEcdf17Z3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 45 of 76 233. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 234. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 235. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT FOUR Human Trafficking — Forced Labor Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 et seq. and 14 V.I.0 § 134 236. The Government restates and realleges paragraphs 1 to 235 of this Complaint as if fully set forth herein. 237. At all times material herein, each Defendant joined in a conspiracy to violate laws prohibiting human trafficking. 238. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by knowingly using coercion to compel underage girls and young women to provide labor or services by forced labor in violation of 14 V.I.C. § 134. 239. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. EFTA00162331

Claine11222com-lilltagidEZPR aitmwment3E631 FRISICEIMII123 Rage8127aff17Z3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 46 of 76 240. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). 241. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT FIVE Human Trafficking — Sexual Servitude Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 et seq. and 14 V.I.0 § 135 242. The Government restates and realleges paragraphs 1 to 241 of this Complaint as if fully set forth herein. 243. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 244. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly maintaining or making available minors for the purpose of engaging the minors in commercial sexual activities or using coercion or deception to force young women to engage in commercial sexual activity in violation of 14 V.I.C. § 135. 245. On the pretext of providing modeling opportunities, careers and contracts, Defendants facilitated the transporting or recruiting of young women and girls or lured and recruited young women and underage girls to travel to the Virgin Islands where they engaged in sexual acts with Epstein and others. In some instances, young women and underage girls were EFTA00162332

Clasie11222coataBIR 0ltunurreent3ffill FRIEROCIUME23 FRage8133ccIUTS3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 47 of 76 given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and others. 246. Defendants through a pattern of criminal activity directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 247. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 248. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 249. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT SIX Human Trafficking — Sexual Servitude Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 et seq. and 14 V.I.0 § 135 250. The Government restates and realleges paragraphs 1 to 249 of this Complaint as if fully set forth herein. 251. At all times material herein, each Defendant joined in a conspiracy to violate laws prohibiting human trafficking. 252. Each Defendant engaged in acts that revealed its intent to join the criminal conspiracy by knowingly maintaining or making available minors for the purpose of engaging the minors in commercial sexual activities or using coercion or deception to force young women to engage in commercial sexual activity in violation of 14 V.I.C. § 135. EFTA00162333

Oatemilalow-11MISITD3IR Mmunweitt3E6-31 MastiffLt41312233 Ramp 8:11)ccf GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 48 of 76 253. On the pretext of providing modeling opportunities, careers and contracts, Defendants facilitated the transporting or recruiting of young women and girls or lured and recruited young women and underage girls to travel to the Virgin Islands where they engaged in sexual acts with Epstein and others. In some instances, young women and underage girls were given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and others. 254. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. 255. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §6040. 256. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT SEVEN Human Trafficking — Patronizing Minors and Victims of Sexual Servitude Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 et seq. and 14 V.I.0 §§ 136-37 257. The Government restates and realleges paragraphs I to 256 of this Complaint as if fully set forth herein. 258. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. EFTA00162334

flanife11222coal-JESPR Camwrrentt3ffia FRIEntiOCULLIM3 Flzhge8:10cdfJ7273 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 49 of 76 259. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly giving, agreeing to give, or offering to give items of value to young women and minors so that the young women and minors would engage in commercial sexual activity with Epstein, other Defendants, and other individuals in violation of 14 V.I.C. §§ 136-137. 260. In some instances, young women and underage girls were given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and others. 261. Defendants through a pattern of criminal activity directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 262. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 263. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 264. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 14 V.I.C. §600 et seq. COUNT EIGHT Human Trafficking— Patronizing Minors and Victims of Sexual Servitude Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Ad, 14 § 600 et seq. and 14 V.I.0 §§ 136-37 265. The Government restates and realleges paragraphs 1 to 264 of this Complaint as if fully set forth herein EFTA00162335

One IlMow-DMEIDATD3IR Dacaturreartl3ffia FRikt10CIEIB;023 Rage 8331 Fa GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 50 of 76 266. At all times material herein, each Defendant joined in a conspiracy to violate laws prohibiting human trafficking. 267. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by knowingly giving, agreeing to give, or offering to give items of value to young women and minors so that the young women and minors would engage in commercial sexual activity with Epstein, other Defendants, and other individuals in violation of 14 V.I.C. §§ 136-137. 268. In some instances, young women and underage girls were given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and others. 269. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. 270. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 271. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 14 V.I.C. §600 et seq. EFTA00162336

ClamellMew-MEIC91,1EZPR Caurtruneent3E631 FRitiftin/1135123 872cdf I/2/3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 51 of 76 COUNT NINE Child Abuse and Neglect—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 §§ 505, 506 and 507 272. The Government restates and realleges paragraphs 1 to 271 of this Complaint as if as if fully set forth herein. 273. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 274. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly or recklessly causing a child to suffer physical, mental or emotional injury, or knowingly or recklessly causing a child to be placed in a situation where it is reasonably foreseeable that such child may suffer physical, mental or emotional injury, in violation Virgin Islands criminal laws prohibiting Child Abuse and Neglect in Title 14 V.I.C. § 500 et. seq. 275. As a result of the Epstein Enterprise's actions numerous young girls suffered serious physical, mental and emotional injury. 276. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 277. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 278. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. EFTA00162337

dateifell222coatJESPR Camwrientt3E631 FRil$t10IMI1123 Fitagfe£(630[1072/3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 52 of 76 COUNT TEN Child Abuse and Neglect Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act —All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual Capacities, 14 V.I.C. § 600 et seq. and 14 V.I.0 §§ 505, 506 and 507 279. The Government restates and realleges paragraphs I to 278 of this Complaint as if as if fully set forth herein. 280. At all times material herein, each Defendant joined in a conspiracy to violate laws prohibiting child abuse and neglect. 281. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy as they knowingly or recklessly caused a child to suffer physical, mental or emotional injury, or knowingly or recklessly caused a child to be placed in a situation where it is reasonably foreseeable that such child may suffer physical, mental or emotional injury, in violation Virgin Islands criminal laws prohibiting Child Abuse and Neglect in Tide 14 V.I.C. § 500 et seq. 282. As a result of Defendants' actions, numerous young girls suffered serious physical, mental and emotional injury. 283. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. 284. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). EFTA00162338

CkmellMmAAMHMAJEOR MmummmtaBil PkWffliMMEM WOmeaglegh3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 53 of 76 285. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT ELEVEN Aggravated Rape—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 § 1700a 286. The Government restates and realleges paragraphs 1 to 285 of this Complaint as if fully set forth herein. 287. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 288. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, conduct that constituted or facilitated the rape of minors by force, intimidation, or the perpetrator's position of authority over the victim. 289. Epstein and others, using force or intimidation, engaged in sexual intercourse with underage girls without their consent in violation of 14 V.I.C. § 1700a. 290. As a result of the Epstein Enterprise's actions, numerous underage girls suffered serious physical, mental and emotional injury. 291. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 292. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. EFTA00162339

ClaffiellMew-MglaThiPR 0ltinwnient3E631 FRISICICIMIE23 Fitage915a1072/3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 54 of 76 293. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT TWELVE Aggravated Rape Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, —All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual Capacities, 14 V.I.C. § 600 et seq. and 14 V.I.0 § 1700a 294. The Government restates and realleges paragraphs I to 293 of this Complaint as if fully set forth herein. 295. At all times material herein, each Defendant joined in a conspiracy to violate laws prohibiting aggravated rape. 296. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by engaging in conduct that constituted or facilitated the rape of minors by force, intimidation, or the perpetrator's position of authority over the victim. 297. Epstein and others, using force or intimidation, engaged in sexual intercourse with underage girls without their consent in violation of 14 V.I.C. § 1700a. 298. As a result of Defendants' actions, numerous underage girls suffered serious physical, mental and emotional injury 299. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. EFTA00162340

aaaffen222coataHm Catimuntent3E631 FRilifitiCCUM13123 FitageS6ccif GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 55 of 76 300. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). 301. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein 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 V.I.C. § 600 et seq. and 14 V.I.0 § 1700a 302. The Government restates and realleges paragraphs 1 to 301 of this Complaint as if fully set forth herein. 303. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 304. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, conduct that constituted or facilitated the rape of girls under 18 years of age. 305. Epstein and others who engaged in rape were over 18 years old at the time of the incidents. 306. As a result of the Epstein Enterprise's actions, numerous minors suffered serious physical, mental and emotional injury. 307. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. EFTA00162341

dame11222auklilfaC91JESPR Camwireerlt3ffill FRIERti0CUMT,0233 Figagje9327ccI0TS3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 56 of 76 308. Defendants benefited, directly and indirectly. from the pattern of criminal activity conducted by the Epstein Enterprise. 309. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT FOURTEEN Rape in the Second Degree Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, —All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual Capacities, 14 V.I.C. § 600 et seq. and 14 V.I.0 § 1702 310. The Government restates and realleges paragraphs I to 309 of this Complaint as if fully set forth herein. 311. At all times material herein, each Defendant joined in a conspiracy to violate laws prohibiting rape in the second degree. 312. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by engaging in conduct that constituted or facilitated the rape of girls under 18 years of age. 313. Epstein and others who engaged in rape were over 18 years old at the time of the incidents. 314. As a result of Defendants' actions, numerous minors suffered serious physical, mental and emotional injury. 315. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, EFTA00162342

Claffirelnaaw-111111314BER Ilartaunreitt3E611 FfikeigLIMIZEB FREse933aff1233 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 57 of 76 forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. 316. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). 317. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT FIFTEEN Unlawful Sexual Contact in the First or 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 §§ 1708 and 1709 318. The Government restates and realleges paragraphs 1 to 317 of this Complaint as if as if fully set forth herein. 319. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 320. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, using or facilitating the use of force or coercion to accomplish sexual contact or engaging in sexual contact with a minor between 13 and 16 years of age. 321. Epstein and others who engaged in the sexual contact were over 18 years old at the time of the incidents. 322. As a result of the Epstein Enterprise's actions numerous young women and minors suffered serious physical, mental and emotional injury. EFTA00162343

0affirellM2mAk13381(91JESPR Gamiuntent3ffill. FlzhgeN3cdf17Z3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 58 of 76 323. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 324. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 325. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 14 V.I.C. §600 et seq. COUNT SIXTEEN Unlawful Sexual Contact in the First or Second Degree Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act —All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual Capacities, 14 V.I.C. § 600 et seq. and 14 V.I.0 §.§. 1708 and 1709 326. The Government restates and realleges paragraphs I to 325 of this Complaint as if as if fully set forth herein. 327. At all times material herein, each Defendant joined in a conspiracy to violate laws prohibiting unlawful sexual contact. 328. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by using or facilitating the use of force or coercion to accomplish sexual contact or engaging in sexual contact with a minor between 13 and 16 years of age. 329. Epstein and others who engaged in the sexual contact were over 18 years old at the time of the incidents. 330. As a result of Defendants' actions, numerous young women and minors suffered serious physical, mental and emotional injury. EFTA00162344

Gatmella2cau-DELIAMIR Ormatunient3E631 FRI liatiCCIEIME23 FRagEe933)aff17-2/3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 59 of 76 331. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. 332. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §6040. 333. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 14 V.I.C. §600 et seq. COUNT SEVENTEEN Prostitution and Keeping House of Prostitution Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 et seq. and 14 V.I.C. §§ 1622, 1624 334. The Government restates and realleges paragraphs 1 to 333 of this Complaint as if fully set forth herein. 335. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 336. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including the engaging in or facilitating the knowing and/or reckless abuse of minors through the acts alleged herein. 337. The Epstein Enterprise knowingly persuaded, induced, enticed, and/or coerced women and children to travel to the Virgin Islands to engage in prostitution and/or sexual activity, and/or attempted to do the same. EFTA00162345

iThatellMove-MBIBITD3IR2 artmiuntentM 31 FRI ifdl0CIEIME23 RE/awe 931 at f GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 60 of 76 338. The Epstein Enterprise kept, maintained, and/or permitted his property at Little St. James to be used for the purpose of prostitution, lewdness or assignation with knowledge or reasonable cause to know the same. 339. The Epstein Enterprise received or offered or agreed to receive women and children at his property at Little St. James for the purposes of prostitution, lewdness or assignation, and/or permitted women and children to remain there for such purposes. 340. The Epstein Enterprise directed, took, transported, and or offered or agreed to take or transport women and children to Little St. James with the knowledge or reasonable cause to know that the purpose of such directing, taking or transporting was prostitution, lewdness or assignation. 341. The Epstein Enterprise knew or should reasonably have known that individuals that were the subjects of the actions described in this Count were minors. 342. As a result of Defendants' actions, numerous young women and minors suffered serious physical, mental and emotional injury. 343. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 344. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 345. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. EFTA00162346

Offee11222coalitilEIR Camwrreent3ffill Rage952af GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 61 of 76 COUNT EIGHTEEN Prostitution and Keeping House of Prostitution Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 et seq. and 14 V.I.C. §§ 1622, 1624. 346. The Government restated and realleges paragraph 1 to 345 of this Complaint as if fully set forth herein. 347. At all times material herein, each Defendant joined a conspiracy to laws against prostitution. 348. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by engaging in or facilitating the persuasion, inducement, enticement or coercion of women and children to travel to the Virgin Islands to engage in prostitution and/or sexual activity, and/or attempted to do the same; keeping, maintaining, and/or permitting Epstein's property at Little St. James, to be used for the purpose of prostitution, lewdness or assignation with knowledge or reasonable cause to know the same; receiving, offering, or agreeing to receive individuals at his property at Little St. James for the purposes of prostitution, lewdness or assignation, and/or permitted women and children to remain there for such purposes; and directing, taking, transporting, and/or offering or agreeing to take or transport women and children to Little St. James with the knowledge or reasonable cause to know that the purpose of such directing, taking or transporting was prostitution, lewdness or assignation, in violation of 14 V.I.C. §§ 1622 and 1624. 349. Defendants knew or should reasonably have known that individuals that were the subjects of the actions described in this Count were minors. 350. As a result of Defendants' actions numerous young women and minors suffered serious physical, mental and emotional injury. EFTA00162347

Claasiell222mailiCSIdEBIR Camturrentt3ffill. 1Rf1$ti0]MTi1PZii Figajfe9Bcdt17Z3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 62 of 76 351. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands 352. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). 353. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 14 V.I.C. §600 et seq. COUNT NINETEEN Sex Offender Registry-Estate of Jeffrey E. Epstein Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 a seq. and 14 V.I.C. § 1721 et seq. 354. The Government restates and realleges paragraphs 1 to 353 of this Complaint as if fully set forth herein. 355. Epstein was required to, and did, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. 356. SORCPA requires that offenders required to register provide information relating to intended travel in foreign commerce. 357. On at least two occasions, Epstein traveled to Vienna and Monaco without disclosing that travel to the Virgin Islands sex offender registry. EFTA00162348

Glaffiella2a3m-MEDArlSIR firlimuneent3ffill FRiketiCCIEUM233 Fitaige9:91cdf2Z3 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 63 of 76 358. Epstein's failure to disclose this travel before, during, or even after his travel was knowing. 359. Epstein's violation SORPCA was part of a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise. 14 V.LC. §604(j). COUNT TWENTY Fraudulent Conveyance Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 a seq. and 14 V.I.C. ft 832-833 360. The Government restates and realleges paragraphs 1 to 359 of this Complaint as if fully set forth herein. 361. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 362. Each Defendant engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to transferring assets to and between various entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder or delay claims against them. 363. Upon information and belief, in an effort to defeat the claims of creditors and avoid the oversight of the court probating his estate, Epstein, days before his death, transferred significant assets, including assets held by other Defendants, into The 1953 Trust. 364. At the time of these transfers, Epstein had numerous actions pending against him related to his trafficking and sexual assaults seeking financial judgments. 365. Through these transfers, Epstein and the Epstein Enterprise fraudulently removed property and effects beyond the jurisdiction of the probate court. EFTA00162349

alae81.122 102043SER CIDootmaati8Val. FlfileicIXDA/30123 Ft100400 of 723 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 64 of 76 366. Epstein and the Epstein Enterprise were parties to the fraudulent conveyance of the property, real or personal, and/or the interests or rights arising out of property, contracts, or conveyances of Epstein and the Epstein Enterprise. 367. Epstein and the Epstein Enterprise acted with the intent to defeat, hinder, or delay creditors and claimants, including the Government of the Virgin Islands, in collecting on their judgements, debts and demands 368. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 369. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 370. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT TWENTY-ONE Fraudulent Conveyance Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 a seq. and 14 V.I.C. §§ 832-833 371. The Government restates and realleges paragraphs 1 to 370 of this Complaint as if fully set forth herein. 372. At all times material herein, each Defendant joined in a conspiracy to commit fraudulent conveyances. 373. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy, including, but not limited to, transferring assets to and between various EFTA00162350

Oafiell.122ektla02041SER Cl0otimeatithial. FifdEk0006B/33a123 Plaggethth of 123 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 65 of 76 entities controlled by Epstein and the Epstein Enterprise to avoid. defeat. hinder or delay claims against them. 374. Upon information and belief, in an effort to defeat the claims of creditors and avoid the oversight of the court probating his estate, Epstein, days before his death, transferred significant assets, including assets held by other Defendants, into The 1953 Trust. 375. At the time of this transfer, Epstein had numerous actions pending against him related to his trafficking and sexual assaults seeking financial judgments. 376. Through this transfer, Epstein and the Epstein Enterprise fraudulently removed property and effects beyond the jurisdiction of the probate court. 377. Epstein and the Epstein Enterprise were parties to the fraudulent conveyance of the property, real or personal, and/or the interests or rights arising out of property, contracts, or conveyances of Epstein and the Epstein Enterprise. 378. Epstein and the Epstein Enterprise acted with the intent to defeat, hinder, or delay the Government of the Virgin Islands and other creditors and claimants to collect on their judgements, debts and demands. 379. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. 380. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). EFTA00162351

Casied.122 1002041SER Cl0onmentithial FifnEKON3/310723 Plagge3.02 of 123 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 66 of 76 381. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT TWENTY-TWO Civil Conspiracy 382. The Government restates and realleges paragraphs 1 to 381 of this Complaint as if fully set forth herein. 383. Defendants acted in concert and joined with others to perform the wrongful acts identified in Counts 1 to 13, among others, concealing the sexual abuse of minor females by unlawful means. 384. Each co-conspirator knew, or in the exercise of reasonable care should have known, about the conduct of the others and about the common unlawful scheme. 385. These unlawful acts could not have been carried to the length and extent accomplished without the common understanding shared by Epstein and the Epstein Enterprise Defendants. 386. Each of the Defendants had a duty to report, stop or terminate the wrongful conduct, but instead each Defendant concealed, assisted and furthered the wrongful acts by use of civil conspiracy. 387. As a direct and proximate result of Defendants' conspiracy, the Virgin Island has been injured. 388. Each co-conspirator is jointly and severally liable for the acts alleged herein. EFTA00162352

Oatied.122 100204ISSR Cesoormaati8thal FfideidAb11/310723 PEigge108 of /23 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 67 of 76 COUNT TWENTY-THREE Fraudulent Claims Upon the Government—Southern Trust Company, Inc. Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 et seq. and 14 V.I.C. § 843 389. The Government restates and realleges paragraphs 1 to 388 of this Complaint as if fully set forth herein. 390. At all times relevant and material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 391. Each Defendant engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, making fraudulent claims upon the Government. 392. The Epstein Enterprise misrepresented the purpose, activities, employment, and income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epstein Enterprise, with the active participation of Defendants Indyke and Kahn, used Southern Trust Company to employ, pay, and conceal the activities of participants in the criminal activities of the Enterprise. 393. The Epstein Enterprise made and presented an application for tax incentives, testimony, and quarterly reports to the EDC, a commission of the Government, regarding the Southern Trust Company, 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 and submitted false affidavits knowing the same to contain any fraudulent or fictitious statement or entry. EFTA00162353

CH8.88.2221-)240/0994132R CDooureeti8th611 FREKONIKE123 Plagge100 of 123 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 68 of 76 394. These false statements and documents included affidavits, testimony, an application, and other documents that misrepresented that Southern Trust Company was engaged in, and failed to disclose it did not and could not carry out, in its stated purpose of providing consulting services in financial and biomedical informatics. 395. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude, and commercial sexual activity of underage girls and young women in knowing and reckless disregard of the laws of the Virgin Islands. 396. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 397. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 398. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. § 600 et seq. COUNT TWENTY-FOUR Fraudulent Claims Upon the Government—Southern Trust Company, Inc. Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 VI.C. § 600 et seq. and 14 V.I.C. § 843 399. The Government restates and realleges paragraphs 1 to 398 of this Complaint as if fully set forth herein. 400. At all times material herein, each Defendant joined in a conspiracy to commit fraudulent conveyances. EFTA00162354

C€18.8€1.221-)2410099413ER CDouumetif3th611 FRIEKOOM/33CP33 Piaggel.a) of 123 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 69 of 76 401. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy, including, but not limited to, transferring assets to and between various entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder or delay claims against them. 402. The Epstein Enterprise misrepresented the purpose, activities, employment, and income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epstein Enterprise, with the active participation of Defendants Indyke and Kahn, used Southern Trust Company to employ, pay, and conceal the activities of participants in the criminal activities of the Enterprise. 403. The Epstein Enterprise made and presented an application for tax incentives, testimony, and quarterly reports to the EDC, a commission of the Government, regarding the Southern Trust Company, 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 and submitted false affidavits knowing the same to contain any fraudulent or fictitious statement or entry. 404. These false statements and documents included affidavits, testimony, an application, and other documents that misrepresented that Southern Trust Company was engaged in, and failed to disclose it did not and could not carry out, in its stated purpose of providing consulting services in financial and biomedical informatics. 405. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, EFTA00162355

OZIfiet112201100204ISSR Cl0ommati8IMEII. FRJEK0ffibl3/310723 PRggel0E6 of 123 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 70 of 76 forced labor, sexual servitude, and commercial sexual activity of underage girls and young women in knowing and reckless disregard of the laws of the Virgin Islands. 406. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). 407. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs 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 Government restates and realleges paragraphs 1 to 407 of this Complaint as if fully set forth herein. 409. At all times relevant and material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 410. Each Defendant engaged in two or more occasions of conduct that constitute 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 Virgin Islands for each of the tax years from 2011 to 2018. 412. Defendant Cypress misrepresented the value of its assets held during each of these years by omitting the value of the 49 Zorro Ranch Road, Stanley, New Mexico property that it EFTA00162356

OBEit34.122 1002041SER C1000=30118Val FlideidDOMICE133 Plagge102 of 123 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 71 of 76 acquired in or about December 2011, and misrepresented the value of its expenses incurred during each of these years by omitting the annual amounts of property taxes it paid for the New Mexico property. 413. Defendant Maple misrepresented the value of its assets held during each of these years by omitting the value of the 9 East 71st Street, New York, New York property that it acquired in or about December 2011, and misrepresented the value of its 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 that it acquired in or about December 2011, and misrepresented the value of its expenses incurred during each of these years by omitting the annual amounts of property taxes it paid for the Palm Beach property. 415. Epstein and Defendant/Co-Executor Kahn signed each of Cypress, Maple, and Laurel's annual reports for these years in which they represented that "ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT . . . ." 416. Epstein appears to have maintained divided ownership of these properties, transferred ownership of them to the Virgin Islands, and then concealed this fact even from Virgin Islands authorities in an attempt to shield the properties from any judgment in the states where they are located. 417. Defendants' knowingly and willfully made false representations to the Government regarding the assets and expenses of Cypress, Maple, and Laurel, and their conduct EFTA00162357

Ceae81.1224002134ISSR Cesoomeati8Val. FIRIddXMT30/23 Ragge108 of 723 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 72 of 76 in failing to inform the Government of each company's true assets and expenses, constitute fraud upon the Government. 14 V.I.C. § 843. 418. Defendants, through a pattern of criminal activity, acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or of real property. 419. Defendants benefitted directly and indirectly from the pattern of criminal activity conducted by the Epstein Enterprise. Defendants knowingly benefitted financially and/or obtained non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced sexual servitude, and commercial sexual activity of underage girls and young women, in knowing and reckless disregard of the laws of the Virgin Islands. 420. At all material times herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO, 14 V.I.C. §§ 600 et seq. COUNT TWENTY-SIX Fraudulent Claims Upon the Government—Cypress, Inc.; Maple, Inc.; Laurel, Inc. Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 600 et seq. and 14 V.I.C. § 843 421. The Government restates and realleges paragraphs 1 to 420 of this Complaint as if fully set forth herein. 422. At all material times herein, each Defendant engaged in a conspiracy to commit fraudulent conveyances. 423. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy, including, but not limited to, transferring assets to and between various entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder, or delay claims against them. EFTA00162358

Oaat3E1122 1002043SER CDoninfintit36(al. Fifdtk00M11/310733 PiAggelOg of 123 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 73 of 76 424. These false statements and documents included annual financial statements for the years 2011 to 2018 submitted by each Cypress, Maple, and Laurel to the Office of Lieutenant Governor of the Virgin Islands that misrepresented the value of the assets held and the amount of the expenses incurred by each company during each of these years. 425. Epstein appears to have maintained divided ownership of these properties, transferred ownership of them to the Virgin Islands, and then concealed this fact even from Virgin Islands authorities in an attempt to shield the properties from any judgment in the states where they are located. 426. Defendants knowingly benefitted financially and/or obtained other non-financial value from their participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude, and commercial sexual activity of underage girls and young women, in knowing and reckless disregard of the laws of the Virgin Islands. Notice of Allegation of PUNITIVE DAMAGES 427. The purpose of punitive damages in the common law is to punish the defendant for outrageous conduct that is reckless or intentional and to deter others from engaging in such conduct in the future. 428. This Complaint describes intentional conduct so egregious, persistent, and injurious that it shocks the conscience and offends a civilized society. 429. Punitive damages are especially important in the case of persons or companies that have so money, assets, and power that mere fines, penalties, and economic damages are simply not sufficient. EFTA00162359

OZ1fied.122ektla02043SERCOoutmsett86fi11 Fiftidc00a1/310733 Piaggelle of 123 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 74 of 76 430. At all times material herein, Epstein and the Epstein Enterprise engaged repeatedly in wrongful acts which were intentional and outrageous. The Government gives notice that it intends to pursue the possibility of punitive damages in any jury verdict. PRAYER FOR RELIEF WHEREFORE, the Government respectfully requests that the Court: A. Enter a judgment in favor of the Government and against Defendants on all counts; B. Declare that Defendants, through the Epstein Enterprise, have engaged in a pattern of criminal activity in the Virgin Islands including but not limited to human trafficking, forced labor and sexual servitude of female children and young women, unlawful sexual contact, child sexual abuse, child abuse and neglect, rape, prostitution civil conspiracy and other offenses related offenses, and civil conspiracy; C. Pursuant to 14 V.I.C. § 610, enforce and maintain the criminal activity liens the Government is filing contemporaneously with this lawsuit, or shall file in connection with this action; D. Pursuant to 14 V.I.C. § 607(a)(1) and 14 V.I.C. § 141, issue an order forfeiting and divesting in favor of the Government of the Virgin Islands all of Defendants' interests in any real and personal property used to facilitate the criminal enterprise carried out by the Epstein Enterprise, including but not limited to Little St. James Island and Greater St. James Island; E. Issue an order forfeiting to the Government of the Virgin Islands any proceeds or funds obtained by Defendants, whether directly or indirectly, during the course of the criminal activity of the Epstein Enterprise; EFTA00162360

Oafletl.12204100204ISSR Cl0oornfiati86111 Fifddc00M3/330733 Plaggell6 of 123 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 75 of 76 F. Pursuant to 14 V.I.C. § 607(a)(1), require Defendants to divest themselves of any real property or other interests in favor of the Government of the Virgin Islands used to further the goals of the Epstein Enterprise; G. Pursuant to 14 V.I.C. § 607(a)(3) and (5), order the dissolution of the Epstein Enterprise, including but not limited to, order the dissolution of the corporate Defendants; H. Pursuant to 14 V.I.C. § 607(a)(2) enter an injunction to prevent the further criminal conduct, and concealment of the criminal conduct, by the Epstein Enterprise; I. Pursuant to 14 V.I.C. § 607(a)(4), order the revocation of any and all licenses, permits and approvals that had been granted by any agency of the Territory, and require the repayment of any tax benefits that had been bestowed on any Defendant; J. Pursuant to 14 V.I.C. §§ 607(a)(6) and 607(k), order all assets and funds of the Estate of Jeffrey E. Epstein be placed into receivership; K. Pursuant to 14 V.I.C. § 607(e), award the Government the maximum civil penalty for each and every violation of law committed by the Epstein Enterprise; L. Pursuant to 14 V.I.C. § 607, award treble damages and all other available remedies, including attorneys' fees and costs; M. Award compensatory and punitive damages for Defendants' civil conspiracy; N. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; O. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 V.I.C. § 608(c)(4), to protect the rights of victims and innocent persons in the interest of justice and consistent with the purposes of CICO; P. Assess and award a judgment in favor of the Government and against the Defendants for attorneys' fees and costs and pre- and post-judgment interest; and EFTA00162361

081flt34122 1002041SSIR Moutmsett816611 FREKID0M3/310:123 Plagge312 of 123 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 76 of 76 Q. Award any and all other relief this Court deems appropriate. The Government demands a jury trial on all issues so triable. RESPECTFULLY SUBMITTED, DENISE N. GEORGE, ESQ. ATTORNEY GENERAL Dated: February 10.2021 /s/ Carol Thomas-Jacobs CAROL THOMAS-JACOBS, ESQ. Assistant Attorney General Virgin Islands Department of Justice Office of the Attorney General 34-38 Kronprindsens Gade St. Thomas, U.S. Virgin Islands 00802 Email: [email protected] (340) 774-5666 ext. 10101 EFTA00162362

CaisteatjakettD:19BOSEERIDdacroanleiteLES211114thaaW3E12223 Fla2 3 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS PLAINTIFF, V. JP MORGAN CHASE BANK, N.A. DEFENDANT. Case Number: OAP\ C ACTION FOR DAMAGES JURY TRIAL DEMANDED PROTECTIVE ORDER C)C\ 09 The parties having agreed to the following terms of confidentiality, and the Court having found that good cause exists for issuance of an appropriately tailored confidentiality order governing the pre-trial phase of this action, it is therefore hereby ORDERED that any person subject to this Order -- including without limitation the parties to this action, their representatives, agents, experts and consultants, all third parties providing discovery in this action, and all other interested persons with actual or constructive notice of this Order -- shall adhere to the following terms, upon pain of contempt: 1. Any person subject to this Order who receives from any other person any "Discovery Material" information of any kind provided in the course of discovery in this action) that is designated as "Confidential" pursuant to the terms of this Order shall not disclose such Confidential Discovery Material to anyone else except as expressly permitted hereunder. 2. The person producing any given Discovery Material may designate as Confidential only such portion of such material as consists of: a. previously nondisclosed financial information (including without EFTA00162363

Castial222etelIOSOGIERIDdifibouenleiteLES2FIRMICCEW302423RitigNalittil23 limitation profitability reports or estimates, percentage fees, design fees, royalty rates, minimum guarantee payments, sales reports and sale margins); b. previously nondisclosed confidential reporting to law enforcement agencies; c. previously nondisclosed material relating to ownership or control of any non-public company; d. previously nondisclosed business plans, product development information, or marketing plans; e. any information of a personal or intimate nature regarding any individual; f. any information maintained by JPMorgan Chase Bank, N.A. or its affiliates that is required to be kept confidential pursuant to the Bank Secrecy Act, 31 U.S.C. §§ 5311 to 5336, or its implementing regulations ("BSA") but for which the appropriate regulatory authority has authorized disclosure, including but not limited to the fact that no BSA information exists, (`BSA- Protected Information")i and any information that, pursuant to 31 U.S.C. 5318(g)(2)(A)(1), 31 C.F.R. § 1020.320, 12 C.F.R § 21.11, Section 314(a) or (b) of the PATRIOT ACT, 12 U.S.C. §§ 3414(a)(3) and (c) or any other applicable regulations BSA-Protected Information maintained by other financial institutions are not within the scope of this Order and remain subject to the standard confidentiality requirements of the BSA and its implementing regulations. 2 EFTA00162364

Callastae/122SECtillEIBOSIMPDfiElcuaregitilLERRIFitrieD111021223 Regggabfd111123 concerning potential suspicious activity ("SAR-Related Information"), is not permitted to be produced unless authorized by the appropriate regulatory authority ("SAR-Protected Information"); g. any information that is confidential supervisory information ("CSP") of the Board of Governors of the Federal Reserve System as set forth in 12 C.F.R. § 261.2(c), non-public information of the Office of the Comptroller of the Currency or the former Office of Thrift Supervision as set forth in 12 C.F.R. § 4.32(b), exempt information of the Federal Deposit Insurance Corporation as set forth in 12 C.F.R. §§ 309.2, 309.5, and 309.6, and confidential information of the Consumer Financial Protection Board as set forth in 12 C.F.R. § 1070.2, and any other records concerning supervision, regulation, and examination of banks, savings associations, their holding companies and affiliates, and records compiled in connection with the enforcement responsibilities of federal and state financial regulatory agencies that is not permitted to be disclosed to a third party absent consent of the applicable regulator or government agency unless authorized by the appropriate regulatory authority ("CSI-Protected Information"); or h. any other category of information hereinafter given confidential status by the Court. 3 EFTA00162365

C alas fea.222.2etbalUILIGICSID thlhousitetialiS21111iMiECUIRCAB?3 FirSiggidgkilfealf112 3 3. With respect to the Confidential portion of any Discovery Material other than deposition transcripts and exhibits, the producing person or that person's counsel may designate such portion as "Confidential" by stamping or otherwise clearly marking as "Confidential" the protected portion in a manner that will not interfere with legibility or audibility, and by also producing for future public use another copy of said Discovery Material with the confidential information redacted. For the avoidance of doubt, nothing herein is intended to prevent a party from designating the entirety of a given document as "Confidential" if the party reasonably believes the entire document falls within one or more of the categories in paragraph 2, above. With respect to deposition transcripts and exhibits, a producing person or that person's counsel may indicate on the record that a question calls for Confidential information, in which case the transcript of the designated testimony shall be bound in a separate volume and marked "Confidential Information Governed by Protective Order" by the reporter. 4. If at any time prior to the trial of this action, a producing person realizes that some portion[s] of Discovery Material that that person previously produced without limitation should be designated as Confidential, he may so designate by so apprising all parties in writing, and such designated portion[s] of the Discovery Material will thereafter be treated as Confidential under the terms of this Order. If a party has disclosed such designated portion[s] of Discovery Material to anyone other than the individuals set forth in paragraph 5 below, that party shall make reasonable efforts to promptly retrieve such Discovery Material, and inform any recipient of the terms of the Order. 5. With the exception of the qualifications pertaining to BSA-Protected 4 EFTA00162366

C tket1222€ etilTEIBOUERD difi1ousubeibiLli521111ikkM1113B8223 FfitiggaRpfdt1112 3 Information, SAR-Protected Information and/or CSI-Protected Information in paragraph 6, no person subject to this Order other than the producing person shall disclose any of the Discovery Material, designated by the producing person as Confidential excluding any material containing BSA-Protected Information, SAR- Protected Information and/or CSI-Protected Information to any other person whomsoever, except to: a. the parties to this action; b. counsel retained specifically for this action, including any paralegal, clerical and other assistant employed by such counsel and assigned to this matter; c. as to any document, its author, its addressee, and any other person indicated on the face of the document as having received a copy; d. any witness who counsel for a party in good faith believes may be called to testify at trial or deposition in this action, provided such person has first executed a Non-Disclosure Agreement in the form annexed as an Exhibit hereto; e. any person retained by a party to serve as an expert witness or otherwise provide specialized advice or services to counsel in connection with this action (including but not limited to professional jury or trial consultants, mock jurors, and persons or entities providing litigation support services — such as photocopying, videotaping, translating, preparing exhibits or demonstrations, and processing, hosting, organizing, storing, or 5 EFTA00162367

Catstealaketa091306133CFDdifilonareeiali52 RilitietC0113302033 RItiliffiggtheitE2 3 retrieving data in any form or medium — and their employees and subcontractors), provided such person has first executed a Non- Disclosure Agreement in the form annexed as an Exhibit hereto; f. any mediator or other dispute-resolution personnel, or any employee thereof, provided such person has first executed a Non- Disclosure Agreement in the form annexed as Exhibit hereto; g. insurers, reinsurers, insurance adjusters, and/or third party administrators of insurance policies that do or may provide insurance coverage applicable to this action; h. stenographers engaged to transcribe depositions conducted in this action and videographers engaged to record depositions conducted in this action; and i. the Court and its support personnel. 6. No person subject to this Order shall disclose any BSA-Protected Information, SAR-Protected Information, and/or CSI-Protected Information to any other person whomsoever, except to the following persons, consistent with any authorization received from the appropriate regulatory authority: a. the Government of the U.S. Virgin Islands and its counsel and JPMorgan Chase and its counsel, including any paralegal, clerical and other assistant employed by such counsel and assigned to this matter; b. any witness employed or formerly employed by JPMorgan Chase who counsel for the Government of the U.S. Virgin Islands or 6 EFTA00162368

C atilits&e21222eCtillESOGIEWfilacroaffaELBS2 FIRMS:C=1CM RItig3g477a610112 3 JPMorgan Chase in good faith believes may be called to testify at trial or deposition in this action, provided such person has first executed a Non-Disclosure Agreement in the form annexed as an Exhibit hereto; c. any person retained by the Government of the U.S. Virgin Islands or JPMorgan Chase to serve as an expert witness or otherwise provide specialized advice to counsel in connection with this action, provided such person has first executed a Non-Disclosure Agreement in the form annexed as an Exhibit hereto; d. stenographers engaged to transcribe depositions conducted in this action and videographers engaged to record depositions conducted in this action provided such person has first executed a Non-Disclosure Agreement in the form annexed as Exhibit hereto; and e. the Court and its support personnel. 7. Prior to any disclosure of any Confidential Discovery Material to any person referred to in subparagraphs 5(d), 5(e), or 5(f) above, such person shall be provided by counsel with a copy of this Protective Order and shall sign a Non-Disclosure Agreement in the form annexed as an Exhibit hereto stating that that person has read this Order and agrees to be bound by its terms. Said counsel shall retain each signed Non-Disclosure Agreement, hold it in escrow, and produce it to opposing counsel either prior to such person being permitted to testify (at deposition or trial) or at the conclusion of the case, whichever comes first. EFTA00162369

Castee2122260VECESOGEERDdifiYacerataliRilifittatIMIENZ23Rigialt23 8. All Confidential Discovery Material filed with the Court, and all portions of pleadings, motions or other papers filed with the Court that disclose such Confidential Discovery Material, shall be filed under seal with the Clerk of the Court and kept under seal until further order of the Court. The parties will use their best efforts to minimize such sealing. In any event, any party filing a motion or any other papers with the Court under seal shall also publicly file a redacted copy of the same, via the Court's Electronic Case Filing system, that redacts only the Confidential Discovery Material itself, and not text that in no material way reveals the Confidential Discovery Material. 9. Any party who either objects to any designation of confidentiality, or who, by contrast, requests still further limits on disclosure (such as "attorneys' eyes only" in extraordinary circumstances), may at any time prior to the trial of this action serve upon counsel for the designating person a written notice stating with particularity the grounds of the objection or request. If agreement cannot be reached promptly, counsel for all affected persons will convene a joint telephone call with the Court to obtain a ruling. 10. All persons are hereby placed on notice that the Court is unlikely to seal or otherwise afford confidential treatment to any Discovery Material introduced in evidence at trial, even if such material has previously been sealed or designated as Confidential. The Court also retains unfettered discretion whether or not to afford confidential treatment to any Confidential Document or information contained in any Confidential Document submitted to the Court in connection with any motion, application, or proceeding that may result in an order and/or decision by the Court. 11. Each person who has access to Discovery Material that has been 8 EFTA00162370

C anas&e2122eNIMBUGIERDtilikevartneiteLES2FIlildiattEW3E0223 Ra123 designated as Confidential shall take all due precautions to prevent the unauthorized or inadvertent disclosure of such material. 12. If, in connection with this litigation, a party inadvertently discloses information subject to a claim of attorney-client privilege or attorney work product protection, including any privilege or immunity from production associated with BSA, SAR-Related Information, and/or CSI ("Inadvertently Disclosed Information"), such disclosure shall not constitute or be deemed a waiver or forfeiture of any claim of privilege or work product or such other applicable protection with respect to the Inadvertently Disclosed Information and its subject matter. For avoidance of doubt, outside of authorization from an appropriate regulatory authority, the disclosure of BSA, SAR-Related Information and/or CSI shall not constitute or be deemed a waiver or forfeiture of any claim of privilege or work product or such other applicable protection with respect to such information. 13. If a disclosing party makes a claim of inadvertent disclosure, the receiving party shall not thereafter review the Inadvertently Disclosed Information for any purpose, except by order of the Court. The receiving party shall, within five business days, return or destroy all copies of the Inadvertently Disclosed Information, and provide a certification of counsel that all such information has been returned or destroyed. 14. Within five business days of the notification that such Inadvertently Disclosed Information has been returned or destroyed, the disclosing party shall produce a privilege log with respect to the Inadvertently Disclosed Information. 15. As with any information redacted or withheld, the receiving party may 9 EFTA00162371

Oaaase22222eelAD992aSESRCEDeananitttGEE2 PlIggaD2ceiLU3 move the Court for an Order compelling production of the Inadvertently Disclosed Information. The motion shall be filed under seal, and shall not assert as a ground for entering such an Order the fact or circumstances of the inadvertent production. 16. The disclosing party retains the burden of establishing the privileged or protected nature of any Inadvertently Disclosed Information. Nothing in this Order shall limit the right of any party to request an in camera review of the Inadvertently Disclosed Information. 17. This Protective Order shall survive the termination of the litigation. Within 30 days of the final disposition of this action, all Discovery Material designated as "Confidential," and all copies thereof, shall be promptly returned to the producing person, or, upon permission of the producing person, destroyed. For the avoidance of doubt, counsel of record in this action shall be permitted to keep copies of filings and work product that incorporates any Confidential Discovery Material, so long as counsel continues to treat such Confidential Discovery Material in accordance with this Order. 18. This Court shall retain jurisdiction over all persons subject to this Order to the extent necessary to enforce any obligations arising hereunder or to impose sanctions for any contempt thereof. SO STIPULATED AND AGREED. 10 EFTA00162372

O2taaa22222ettleD29214SERRCiThitarmanit+261I2 Plagttelnothfl .113 /s/ Linda Singer LINDA SINGER Admitted Pro Hac Vice Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 232-5504 [email protected] Dated: January 9, 2023 SO ORDERED. Dated: New York, New York /— 3 11 /s/ Boyd Johnson WILMER CUTLER PICKERING HALE AND DORR LLP Boyd M. Johnson III Robert L. Boone Hillary Chutter-Ames 7 World Trade Center 250 Greenwich Street New York, NY 10007 (t) (212) 230-8800 (f) (212) 230-8888 [email protected] [email protected] [email protected] Felicia H. Ellsworth 60 State Street Boston, MA 02109 (t) (617) 526-6687 (f) (617) 526-5000 [email protected] Dated: January 9, 2023 JEDWAKOFF, .S.D.J. EFTA00162373