Second Amended Complaint (Redacted)

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS AND ST. JOHN

********************************
GOVERNMENT OF THE UNITED STATES

VIRGIN ISLANDS, Case No.: ST-20-CV-14
PLAINTIFF,
ACTION FOR DAMAGES
V.
JURY TRIAL DEMANDED
DARREN K. INDYKE, in his individual capacity
and in his capacity as the EXECUTOR FOR THE
ESTATE OF JEFFREY E. EPSTEIN and
ADMINISTRATOR OF THE 1953 TRUST;
RICHARD D. KAHN, in his individual capacity and
in his capacity as the EXECUTOR FOR THE
ESTATE OF JEFFREY E. EPSTEIN, and
ADMINISTRATOR OF 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.
__________________________________________
SECOND AMENDED COMPLAINT
COMES NOW, the Government of the United States Virgin Islands ("Government") and
files this Second Amended Complaint containing information that has become known through
further investigation and third-party discovery and in support thereof, would show unto the Court
as follows:
JURISDICTION AND PARTIES
1. The Attorney General of the United States Virgin Islands (herein after "Virgin
Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant
GVI v. Estate of Jeffrey Epstein
GVI’s Second Amended Complaint
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to 3 V.I.C. § 114 and 14 V.I.C. §607 and her statutory authority to enforce the laws of the Virgin
Islands, and advocate for the public interest, safety, health and well-being of persons in the
Virgin Islands.
2. This Court has subject matter jurisdiction over this civil matter pursuant to 4
V.I.C. § 76 and 14 V.I.C. § 607.
3. This Court has personal jurisdiction over the parties pursuant to 5 V.I.C. § 4903.
4. The Virgin Islands is an unincorporated territory of the United States. It consists
of St. Thomas, St. Croix, St. John, and Water Island, and more than 40 surrounding islands and
Cays, some of which are privately owned. Among these privately owned islands are Little St.
James and Great St. James.
5. Jeffrey E. Epstein ("Epstein") was a resident of the Virgin Islands and he
maintained a residence on Little St. James, which he acquired in 1998 and in 2016 he also
purchased Great St. James.
6. Epstein registered as a sex offender in the Virgin Islands in 2010. He was a Tier 1
offender under Virgin Islands law based upon his Florida conviction of procuring a minor for
prostitution. As a Tier 1 offender, Epstein was required to register annually with the Virgin
Islands Department of Justice ("VIDOJ") and give advance notice of his travel to and from the
Virgin Islands. Epstein was also subject to random address verification by VIDOJ.
7. Epstein was found dead on August 10, 2019 while in custody in New York for sex
crimes.
8. Defendant Darren K. Indyke ("Defendant Indyke") is co-executor of the Estate of
Jeffrey E. Epstein and Administrator of The 1953 Trust and was and/or is a participant in the
activity of the “Epstein Enterprise,” as set forth below.

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9. Defendant Richard D. Kahn ("Defendant Kahn") is co-executor of The Estate of
Jeffrey E. Epstein and Administrator of The 1953 Trust and was and/or is a participant in the
activity of the “Epstein Enterprise,” as set forth below.
10. Defendants Indyke and Kahn, in addition to administering the Estate under the
laws of the Virgin Islands, engaged in conduct in the Virgin Islands through their participation in
businesses, financial transactions, and accounts registered, held, and operating in the Virgin
Islands, and by filing documents with the Government of the Virgin Islands.
11. Defendant, the Estate of Jeffrey E. Epstein ("Estate"), created upon Epstein's death,
is domiciled in the Virgin Islands. On August 15, 2019, Defendants Indyke and Kahn filed a
Petition for Probate and Letters Testamentary which included Epstein's last will and testament
with the Probate Division of the Superior Court of the Virgin Islands.
12. The Petition reported the value of the real and personal property in The Estate
located in the Virgin Islands at $577,672,654.00 dollars.
13. According to the Petition, the assets in the Virgin Islands thus far included:
a. $56.5 million in cash;
b. $127 million in fixed income and equity investments;
c. $195 million in hedge fund and private equity investments; and
d. $18.5 million in planes, boats, and automobiles.
The Estate did not originally value his fine arts, antiques, and other valuables.
14. The Estate also included shares of various corporate entities which hold residences
and real property used by Epstein, namely:
a. Brownstone in New York City valued at $56 million;
b. Ranch in New Mexico valued at $72 million;

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c. Gated home in Palm Beach, Florida, valued at $12 million;
d. Seven units in an apartment building in Paris, valued at $8 million; and
e. Great St. James and Little St. James, collectively valued at $86 million.
15. At the time of this Second Amended Complaint filing, the Estate’s most recent
accounting, filed February 1, 2021, valued its total assets at $240,782,955.84, which is almost 60%
lower than the Estate’s starting valuation less than 18 months earlier when Defendants Indyke and
Kahn began their Co-Executorship of the Estate.
16. The Estate is responsible to pay penalties and damages for the acts committed by
Epstein and the Epstein Enterprise described below.
17. Defendant The 1953 Trust ("The Trust") was created by Epstein, who "amended
and restated" its terms only two days before his suicide. That same day, Epstein revised his Last
Will and Testament, transferring all of his "property, real and personal, wherever situated" to The
Trust. The Trust also contains Epstein's financial assets and is also responsible to pay damages
for the acts committed by Epstein and the Epstein Enterprise described below. Defendants
Indyke and Kahn, filed a Certificate of Trust in the Superior Court of the Virgin Islands for The
Trust on August 26, 2019.
18. Epstein maintained a deliberately complex web of Virgin Islands corporations,
limited liability companies, foundations, and other entities, not all of which are yet known to the
Government of the Virgin Islands, through which he carried out and concealed his criminal
conduct.
19. Epstein regularly created new entities in the territory and transferred properties
and funds between them in order to preserve and shield Epstein's assets and to facilitate and
conceal the unlawful acts described in this Complaint.

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20. These entities held properties, including Little St. James and Great St. James, at
which Epstein trafficked and sexually abused women and underage girls. Epstein owned and
arranged for private planes, helicopters, boat and automobiles to transport victims to, from, and
within the Virgin Islands, and provided money to pay these young women and underage girls.
21. Epstein sat at the hub of this web, serving as president, member, manager, or
director of each of the entities and, upon information and belief, directing their activities.
22. Defendant, Nautilus, Inc., is a corporation established and organized under the
laws of the Virgin Islands. It was incorporated on November 22, 2011.
23. According to records of the Virgin Islands Recorder of Deeds, Nautilus, Inc. owns
Little St. James, a/k/a Parcel Number 109803010100, a parcel of 3.1 million square feet valued
at $3.2 million, with buildings and improvements valued at $4 million.
24. Epstein was president and director of Nautilus, Inc., which corporate filings
describe as "holding property for personal use." Defendants Indyke and Kahn are the secretary
and treasurer of Nautilus, Inc., respectively. The Estate values Epstein's holdings of Nautilus,
Inc., which holds title to Little St. James at $63.9 million.
25. A deed recorded with the Virgin Islands Recorder of Deeds on December 30,
2011 reflects that the property was transferred from a Delaware entity, L.S.J., LLC, to Nautilus,
Inc. for "TEN DOLLARS ($10.00) and other good and valuable consideration." The quitclaim
deed lists Jeffrey Epstein as the sole member of L.S.J., LLC, which it acquired Little Saint James
via a warranty deed dated April 27, 1998.
26. As described below, Epstein engaged in a pattern and practice of trafficking and
sexually abusing young women and female children on this private, secluded island of Little St.
James where Epstein and his associates could avoid detection of their illegal activity from Virgin
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Islands and federal law enforcement and prevent these young women and underage girls from
leaving freely and escaping the abuse.
27. Thus, Nautilus, Inc. participated in carrying out, facilitating and concealing
Epstein's crimes, hence Little St. James became an instrumentality of those crimes.
28. Defendant, Great St. Jim, LLC, is a limited liability company established and
organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26,
2015. Great St. Jim, LLC, according to records of the Virgin Islands Recorder of Deeds, owns at
least three properties that make up Great St. James acquired on January 28, 2016: Parcel Number
109801010100, consisting of 3.5 million square feet and valued at $17.5 million; Parcel Number
109801010200, consisting of 450,000 square feet of land, valued at $2.8 million; and Parcel
Number 109801010300, 1.2 million square feet of land, valued at $2.7 million. According to a
warranty deed filed with the Virgin Islands Recorder of Deeds, Epstein, through Great St. Jim,
LLC, acquired the last two parcels for $5 million each.
29. Epstein is listed as manager and a member of Great St. Jim, LLC and the nature of
its business is described as "holding assets." Upon information and belief, Epstein purchased
these Great St. James properties—the island with closest proximity to Little St. James—to further
shield his conduct on Little St. James from view, prevent his detection by law enforcement or the
public, and allow him to continue and conceal his criminal enterprise. Epstein's significant
investment in the purchase of Great St. James demonstrates his intent to expand his illegal
operation in the Virgin Islands for years to come. Thus, Great St. Jim, LLC participated in
carrying out, concealing, facilitating and continuing Epstein's crimes, and Great St. James became
an instrumentality of those crimes.

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30. Defendant, Poplar, Inc., is a corporation established and organized under the laws
of the Virgin Islands. Poplar, Inc. was incorporated on November 22, 2011. Epstein was
president and director of Poplar, Inc., and its purpose was described in corporate filings as
"holding property for personal use." Defendants Indyke and Kahn are secretary and treasurer of
Poplar, Inc., respectively.
31. A certificate of incumbency provided to the Department of Planning and Natural
Resources ("DPNR") also lists Epstein as president of Poplar, Inc. and expressly authorizes the
incorporators to conduct "transactions related to permitting matters submitted on behalf of Great
St. Jim, LLC."
32. Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim,
LLC, and the signature appears to be Epstein's. The Petition for Probate and Letters Testamentary
filed by The Estate lists Poplar, Inc. as holding title to Great St. James. Thus, Poplar, Inc.
participated in carrying out, concealing, facilitating and continuing Epstein's crimes.
33. Defendant, Plan D, LLC is a limited liability company established and organized
under the laws of the Virgin Islands. In its original Articles of Organization, filed October 19,
2012, and Annual Report filings, Epstein's pilot, Larry Visoski, was listed as Plan D, LLC's sole
manager/member. However, the July 31, 2019 Annual Report revealed Epstein as the principal
behind Plan D, LLC.
34. Upon information and belief, Plan D, LLC owns one or more of the airplanes and
helicopters that Epstein used to transport young women and children to and from the Virgin
Islands to carry out the criminal pattern of activity described below. Among the airplanes owned
by Plan D, LLC is a Gulfstream with N-number N212JE. Flight logs and travel notices indicate
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that Epstein used this plane to traffic and transport and young women and underage girls to the
Virgin Islands.
35. Defendant, Hyperion Air, LLC is a limited liability company established and
organized under the laws of the Virgin Islands on October 19, 2012. Jeffrey Epstein is a
manager/member of Hyperion Air, LLC, along with his pilot, Larry Visoski. The purpose of
Hyperion Air, LLC is listed in its Annual Report as "holding assets."
36. Hyperion Air, LLC is the registered owner of a Bell helicopter with N-number
N331JE and a Keystone helicopter with N-number N722JE. Upon information and belief,
Epstein used these helicopters to transport young women and underage girls between St. Thomas
and Little St. James.
37. Defendant Southern Trust Company, Inc. was originally incorporated in the Virgin
Islands on November 18, 2011 as Financial Informatics, Inc., but changed its name to Southern
Trust Company in September 2012. Southern Trust Company is a tenant at American Yacht
Harbor in Red Hook, St. Thomas, and Epstein is a "passive investor" in IGY-AYH, d/b/a
American Yacht Harbor. By the end of 2013, according to its corporate filings, Southern Trust
Company has assets of $198.5 million; four years later, its assets reached $391.3 million. From
2011 until at least 2018, Jeffrey Epstein was the President/Director of Southern Trust Company,
and Defendants Kahn and Indyke were Treasurer/Director and Secretary/Director, respectively.
Epstein was the sole owner of Southern Trust Company.
38. Defendant Cypress, Inc. is a Virgin Islands corporation that was formed and first
licensed in or about November 2011. 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 Cypress, Inc. Cypress, Inc. owns

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the property 49 Zorro Ranch Road in Stanley, New Mexico, which was transferred to it in or
about December 2011, shortly after it was incorporated.
39. Defendant Maple, Inc. is a Virgin Islands corporation that was formed and first
licensed in or about November 2011. 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 Maple, Inc. Maple, Inc. owns the
property 9 East 71st Street in New York, New York, which was transferred to it on or about
December 23, 2011, shortly after it was incorporated.
40. Defendant Laurel, Inc. is a Virgin Islands corporation that was formed and first
licensed in or about November 2011. 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 Laurel, Inc. Laurel, Inc. owns the
property 358 Brillo Way in Palm Beach, Florida, which was transferred to it in or about
December 2011, shortly after it was formed.
41. John and Jane Does represent individuals and entities whose identities or
involvement with Epstein are currently unknown. The Government of the Virgin Islands will
amend the Complaint to add these individuals and entities when discovered.
42. The Attorney General brings this action to seek all remedies available to the
Government of the Virgin Islands in enforcing its laws and protecting the public interest and
public safety. These claims are distinct from, and are not intended to supplant, the claims of
victims who were unconscionably harmed by Jeffrey Epstein and his associates.
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FACTUAL ALLEGATIONS
A. The Conduct of the "Epstein Enterprise" in the Virgin Islands
43. Epstein and his associates, including Defendants, identified and recruited female
victims, including children, and transported them to the Virgin Islands where they were abused
and injured. Epstein, through and in association with Defendants, trafficked, raped, sexually
assaulted and held captive underage girls and young women at his properties in the Virgin Islands.
44. Epstein created a network of companies and individuals who participated in and
conspired with him in a pattern of criminal activity related to the sex trafficking, forced labor,
sexual assault, child abuse, and sexual servitude of these young women and children. Epstein and
his associates trafficked underage girls to the Virgin Islands, held them captive, and sexually
abused them, causing them grave physical, mental, and emotional injury.
45. To accomplish his illegal ends, Epstein formed an association in fact with
multiple Defendants and others (both companies and individuals) who were willing to
participate in, facilitate, and conceal Epstein's criminal activity in exchange for Epstein's
bestowal of financial and other benefits, including sexual services and forced labor from
victims.
46. This illicit association of Epstein, Defendants, and his associates constitute what
is referred to herein as the "Epstein Enterprise." Epstein's associates in the Epstein Enterprise,
including, but not limited to, those named as Defendants knowingly facilitated, participated in,
and concealed Epstein's illegal conduct.
47. Epstein used his wealth and power to create the Epstein Enterprise which
engaged in a pattern of criminal activity in the Virgin Islands by repeatedly procuring and
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subjecting underage girls and young women to unlawful sexual conduct, sex trafficking, and
forced labor.
48. The Epstein Enterprise engaged in a pattern of criminal activity in the Virgin
Islands (and elsewhere) with the criminal purpose and goal of placing a steady supply of
vulnerable female children and young women into sexual servitude in service of Epstein's
desires, and those of his associates. The Epstein Enterprise maintained and made available
young women and underage girls for the purpose of engaging them in forced labor and sexual
activities and used coercion and deception to procure, abuse, and harbor its victims.
49. Flight logs and other sources establish that between 2001 and 2019 the Epstein
Enterprise transported underage girls and young women to the Virgin Islands, who were then taken
via helicopter or private vessel to Little St. James where they were then deceptively subjected to
sexual servitude, forced to engage in sexual acts and coerced into commercial sexual activity
and forced labor.
50. In furtherance of its criminal activities, the Epstein Enterprise used its aircrafts
to transport the young women and underage girls to the Virgin Islands for purposes of sexual
abuse and exploitation.
51. The Epstein Enterprise facilitated and participated in the sexual molestation and
exploitation of numerous girls between the age of 12 and 17 years old.
52. On the pretext of providing modeling opportunities, careers and contracts,
associates of the Epstein Enterprise, funded by the Epstein Enterprise, lured and recruited young
women and underage girls to travel to locations including the Virgin Islands where, upon
information and belief, based on the pattern and practice of the Epstein Enterprise, they were
sexually abused and exploited.

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53. Associates in the Epstein Enterprise recruited both victims and abusers into the
Epstein Enterprise, participated in sexual acts of rape and abuse of minors and witnessed
Epstein and others engage in sexual acts with children.
54. As recent as 2018, air traffic controllers and other airport personnel reported
seeing Epstein leave his plane with young girls some of whom appeared to be between the age
of 11 and 18 years.
55. Upon information and belief, based on Epstein's pattern of trafficking and
sexually abusing young girls, the Epstein Enterprise trafficked and abused these girls, and
others, in the Virgin Islands through 2018.
56. When sued in civil court for committing sex trafficking and sex crimes, Epstein
never denied engaging in sexual acts with underage females and procuring underage females for
prostitution, but instead consistently invoked his Fifth Amendment privilege against self-
incrimination.
57. Upon information and belief, the Epstein Enterprise kept a computerized list of
underage girls who were in or proximate to the Virgin Islands, and able to be transported to
Epstein's residence at Little St. James in the Virgin Islands.
58. The Epstein Enterprise engaged in a pattern of criminal conduct by trafficking
children and young women and placing them in sexual servitude and forced labor in the Virgin
Islands. The Epstein Enterprise repeatedly violated 14 V.I.C. §§ 133 to 138, which prohibit
trafficking and sexual abuse. The Epstein Enterprise also repeatedly violated laws against child
abuse and neglect, including 14 V.I.C. § 505, which defines the crime of child abuse as knowingly
or recklessly causing "a child to suffer physical, mental, or emotional injury," or causing a child to
be placed in a situation where such injury is foreseeable, and 14 V.I.C. § 506, which applies, as
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here, where the child suffers serious physical, mental, or emotional injury as a result of that abuse.
The harm to Epstein's victims was both fully foreseeable and deeply damaging.
59. The Epstein Enterprise knowingly recruited, transported, transferred, harbored,
received, procured, obtained, isolated, maintained, and enticed young women and girls to
engage in forced labor (such as providing massages) and, ultimately, sexual servitude at his little
St. James residence.
60. A 15-year old victim was forced into sexual acts with Epstein and others and then
attempted to escape by swimming off the Little St. James Island. Epstein and others organized a
search party that located her and kept her captive by, among other things, confiscating her passport.
Another victim, who was first engaged in provide massages to Epstein, was then forced to
perform sexual acts at Little St. James in the Virgin Islands. When she attempted to escape the
"private island," Epstein and a search party found her, returned her to his house, and suggested
physical restraint or harm if she failed to cooperate.
61. Another victim was flown by Epstein and his associates to New York or Palm
Beach and then to the Virgin Islands dozens of times from 2004, when she was age 20, to 2017.
She was repeatedly abused by Epstein and also was pressed to have sex with Epstein’s business
colleagues.
62. During the latter part of this period, she was forced into an arranged marriage to
another victim that was facilitated by Defendant/Co-Executor Indyke to prevent the other victim
from being deported. Indyke and a New York immigration lawyer retained by Epstein prepared
the victim for communications with U.S. immigration officials almost immediately after the
wedding. Defendant/Co-Executor Kahn provided a letter of reference for the immigration
proceeding. When the victim inquired about ending the marriage and leaving Epstein’s circle,
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Indyke repeatedly tried to talk her out of a divorce and threatened that she would lose Epstein’s
and his associates’ protection.
63. The Epstein Enterprise forced at least three separate arranged marriages, in each
case requiring American female victims to marry foreign victims to avoid their deportation. The
victims were coerced into to participating in these arranged marriages, and understood that there
would be consequences, including serious reputational and bodily harm, if they refused to enter
a marriage or attempted to end it. In each instance, Indyke and Kahn knowingly facilitated the
fraudulent and coerced marriages, performing and securing the legal and accounting work
involved and enabling a fraud that would further bind Epstein’s victims to him and enable
Epstein to continue to control and abuse these victims sexually.
64. The Epstein Enterprise deceptively lured underage girls and women into its
sex trafficking ring with money and promises of employment, career opportunities and
school assistance. The Epstein Enterprise preyed on their financial and other vulnerabilities,
and promised victims money, shelter, gifts, employment, tuition and other items of value.
For example, participants in the Epstein Enterprise targeted young and underage females
under the pretext that they would be paid substantially merely to provide massages to him
and others. However, once drawn in, victims were then pressured and coerced to engage in
sexual acts.
65. The Epstein Enterprise forced underage victims to recruit others to perform
services and engage in sexual acts—a trafficking pyramid scheme.
66. The Epstein Enterprise paid girls for each "meeting," with additional money if
they brought additional girls. Epstein reportedly required three meetings per day.
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67. The Epstein Enterprise used the term "work" as a code for sexual abuse, and,
upon information and belief, reportedly kept computer records of the contact information for the
victims.
68. Consistent with his creation and use of a complex web of entities to carry out
and conceal the criminal trafficking enterprise in the Virgin Islands, the Epstein Enterprise
sometimes paid young women and underage girls he exploited and trafficked through his
charitable foundations.
69. Once the girls and women were recruited, participants in the Epstein Enterprise
enforced their sexual servitude of victims by coercion, including but not limited to, confiscating
passports, controlling and extinguishing external communications, and threatening violence.
They also made fraudulent statements to family members of victims, claiming victims were
being well cared for and supported financially in college and other educational opportunities.
70. One of the victims, who was flown by Epstein and his associates to the Virgin
Islands dozens of times up until as late as 2017, described how Epstein exercised strict control
over her and other victims’ activity. The girls had to give notice if they left the main residence
and were kept to a rigid set of roles and rules. Epstein brought victims to business meetings,
where they were often required to massage his feet or run errands. Victims had to use Epstein-
approved doctors and sign consent forms for access to their medical records. Epstein also
required them to give him their email passwords. Each of these was a means of demonstrating
and reinforcing his control over the women and girls.
71. During this time period through 2017, this victim observed a succession of girls
and young women who were transported to Little St. James and while there were called into
Epstein’s office or sauna to engage in sexual acts.

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72. Another victim, who was brought to Little St. James more than 50 times during
the years 2000 to 2002, when she was 17 to 19 years old, was required to have sexual relations
with “guests” of Epstein, and was subjected to sexual abuse virtually every day, and on some
days, multiple times a day by Epstein or his guests.
73. This victim, too, observed a large number of young women and girls around
Epstein at Little St. James. Many of them did not speak English, which was Epstein’s preference
since they spoke less.
74. Epstein sent these victims out to night clubs or on shopping trips to try to
identify and recruit other young women and girls, at times paying them a fee for each recruit.
75. The Epstein Enterprise transported, held, sexually abused, trafficked, and
concealed women and children at his property in the Virgin Islands dozens of times over nearly
two decades.
B. Defendants and Co-Executors Indyke and Kahn were Instrumental to the

Epstein Enterprise’s Human Trafficking and Financial Fraud.
76. Defendants Kahn and Indyke organized, controlled, and directed almost every
aspect of the Epstein Enterprise. They were officers in virtually every corporate entity that
Epstein created to fund and conceal his activities. They were deeply involved in the financial
activities of the Epstein-owned entities, including those of Defendant Southern Trust Company,
which made clear that Southern Trust did not provide the services described to the Government
as the basis for tax incentives that allowed Epstein to fraudulently obtain more than $80 million
from the Government.
77. Defendants Indyke and Kahn also directed, approved, enabled, and justified
millions of dollars in payments that fueled the Epstein Enterprise’s sex trafficking, including
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payments to women who were forced to have sex with Epstein and/or recruited others to be
victimized. Defendants Indyke and Kahn obtained large and frequent stocks of cash for Epstein
which, based on public knowledge, would have funded Epstein’s cash payments for
“massages”—code for forced sex.
78. Defendants Indyke and Kahn participated with Epstein in coercing his sex
trafficking victims, in at least three cases, to enter into arranged and forced marriages in order to
obtain immigration status for the foreign women so that they could continue to be available to
Epstein for his abuse – a doubly-deep assault on their will and dignity. Defendant Kahn
provided a letter of reference for at least one immigration application and tax services to the
spouses, and Defendant Indyke paid the immigration lawyer who applied for citizenship for the
women and threatened at least one who indicated that she would seek a divorce. They used
their professional skills and authority to carry out this abhorrent scheme.
79. Indyke and Kahn were, in short, the indispensable captains of Epstein’s criminal
enterprise, roles for which they were richly rewarded.
80. Defendants Kahn and Indyke controlled and directed the activities of the other
entities and personal bank accounts of Epstein accounts after they were funded. One, and
frequently both, of them were officers or directors of Butterfly Trust; of companies holding
Epstein’s real property (as laid out below); and of Financial Strategy Group, Ltd.; Financial
Trust, Inc.; FT Real Estate Inc.; Gratitude America, Inc.; Hyperion Air, Inc.; J. Epstein Virgin
Islands Foundation, Inc.; Jeepers, Inc.; Mort, Inc.; Nautilus, Inc.; and Zorro Development
Corporation; among others.
81. Along with their officer and director roles, Defendants Kahn and/or Indyke also
had signatory authority over virtually all of the accounts held by the Epstein Enterprise entities,
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which allowed them to personally authorize and sign off on payments totaling hundreds of
thousands of dollars to the Enterprise’s sex-trafficking and abuse victims, including those who
also acted as recruiters, and other expenses including legal fees, apartment rent, and tuition.
Further, they routinely withdrew cash in various ways, including ATMs, checks, or by
converting U.S. Dollars to Euros. In many instances, Kahn and/or Indyke structured these
transactions in order to evade the bank’s reporting requirements.
82. Defendant Kahn also oversaw the accounting and tax reporting for the other
entities in the Epstein Enterprise. As discussed below the “Tree entities,” Laurel, Maple, and
Cypress, filed materially false and misleading financial statements by not including the
properties in other states they owned or related expenses. These financial statements were
submitted to the Office of Lieutenant Governor of the Virgin Islands and signed by Defendant
Kahn. In addition, in 2013, Defendant Kahn also directed the outside accountant not to report
the properties on their respective tax returns.
83. The J. Epstein Virgin Islands Foundation, Inc. (the “Foundation”) is a 501(c)(3)
tax-exempt private foundation that was founded in June 2000 and registered in the Virgin
Islands.
84. As of October 23, 2007, Indyke was listed as President of the Foundation. He
also was a signatory on the Foundation’s checking accounts.
85. Between September 2015 and June 2019, Indyke signed Foundation account
checks for over $400,000 made payable to young female models and actresses, including a
former Russian model who received over $380,000 through monthly payments of $8,333 made
over a period of more than three and a half years until the middle of 2019.
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86. In November 2017, Indyke signed a Foundation check made payable to the
immigration lawyer in New York who was involved in one or more forced marriages arranged
among Epstein’s victims to secure a victim’s immigration status. The check’s memo line
references the former Russian model’s last name.
87. These payments were inconsistent with the charitable purpose of the Foundation
and designed to serve the private benefit and criminal activities of Epstein and the Epstein
Enterprise.
88. Earlier in 2017, Indyke signed a Foundation check for $160,000 to resolve a fine
Epstein had incurred for construction on Great St. James Island that violated Virgin Islands
environmental regulations and attempted to make the payment appear to be a charitable
donation. Over two years later, the Estate had to repay this amount to the Foundation after
questions were raised to Epstein’s lawyer about the propriety of the Foundation payment.
89. With help from Indyke and Kahn, Epstein established and operated separate
businesses through which he could pay victims and recruiters, and, upon information and belief,
which he used to maintain their immigration status.
90. JSC Interiors, LLC is a New York Limited Liability Company, the Articles of
Organization of which were filed in November 2014. The Articles list JSC, who was forced and
coerced to have sex with Epstein, as the company’s sole owner. JSC was manipulated,
exploited, and controlled by the Epstein Enterprise.
91. According to JSC’s operating agreement, Kahn was to be the initial Manager of
the company, with full and complete authority, power, and discretion to do all things necessary
or convenient to manage, control, and carry out the business. Kahn also had signatory authority
for JSC’s bank accounts.

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92. One of JSC’s bank accounts was funded entirely with money transferred from
Epstein’s personal bank accounts.
93. JSC’s payroll was paid to two persons, one of whom was the listed sole owner.
Kahn gave conflicting reports to JSC’s bank about the second person on the company’s payroll
and the reasons for its payments to her. Once, he described her as an interior designer, which
would justify the payments in light of JSC’s purported line of business, but which appears to
have been false. The other time, Kahn described this payroll recipient as a dentist, which would
not justify JSC Interiors’ payments to her, but which appears to be true.
94. LSJE, LLC is a Virgin Islands Limited Liability Company that was organized on
October 27, 2011. Defendants Indyke and Kahn were authorized signatories on the company’s
checking account.
95. Indyke and Kahn signed company checks for combined value of almost
$300,000 made out personally to young women or to, again, the immigration lawyer in New
York who was involved in one or more forced marriages arranged among Epstein’s victims to
secure a victim’s immigration status.
96. Upon information and belief, after his guilty plea in Florida for soliciting
prostitution from a minor, Epstein began to focus on procuring and abusing women from
Eastern Europe. These women’s immigration status and language barriers made them more
isolated, dependent, and vulnerable to Epstein’s abuse and manipulation.
97. The Butterfly Trust is a trust created for the benefit of numerous persons who
performed work for Epstein, including numerous young women with Eastern European
surnames and also including Indyke and Kahn themselves. Indyke and Kahn were authorized
signatories on the Trust’s checking account.

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98. Indyke and Kahn signed trust checks for combined value of over $1,000,000
made out personally to young women, or their associated entities, who in some instances were
not beneficiaries of the trust.
99. Defendants and Co-Executors Indyke and Kahn also were deeply involved with
transactions made in and out of Epstein’s personal accounts, for which Indyke had signatory
authority, that were flagged by bank representatives and the New York Department of Financial
Services as potentially suspicious.
100. Indyke also engaged in repeated transactions that seem designed to have
provided Epstein with cash in small enough increments to avoid triggering financial reporting
requirements. It is well known that Epstein paid girls and women in cash for sexual encounters
that began as or were euphemistically described as massages, or for recruiting other girls to
provide such massages.
101. On July 20, 2016, Indyke brought two checks to a branch teller window for
withdrawal, one for $7,500 drawn on Epstein’s personal account and one for $4,000 drawn on
Indyke’s business account. Indyke presented the $7,500 check for cashing and stated that he
would be cashing the other check the next business day to avoid all the paperwork. On July 21,
2016, Indyke returned to cash the $4,000 check.
102. From June 2018 to February 2019, there was a series of 97 separate withdrawals
of $1,000 made from this account at an ATM that is a short walk from Indyke’s law office.
103. From this same account, Indyke wrote 11 checks, between April 2016 and April
2019, for the purpose of converting U.S. dollars to Euros totaling over $126,000. Some of the
checks contained the notation “Euros for safe.”

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104. Also, Indyke withdrew large amounts of cash in single transactions. For
instance, on January 17, 2018, Indyke cashed a check for $100,000. Although Indyke cashed
the check, Kahn arranged with the Bank representative to have the cash ready for pickup.
105. Payments from this account, for which Indyke had signatory authority, totaling
over $2,500,000 were made to dozens of women with Eastern European surnames, purportedly
for hotel expenses, tuition, and rent, and to, again, the immigration lawyer in New York who was
involved in one or more forced marriages arranged among Epstein’s victims to secure victims’
immigration status.
106. For another of Epstein’s personal accounts with the same bank, Indyke, from
2014 to 2016, made almost 45 separate check-cashing withdrawals at a pace of two to three per
month, each for the amount of $7,500, which was the bank’s limit for third-party withdrawals.
107. From this same account, between June 2014 and September 2015, Indyke wrote
eight checks for the purpose of converting U.S. dollars to Euros. Each of the checks to
effectuate the conversion approximated $7,500, presumably in order to evade reporting
requirements, with some containing the notation “Euros for safe.”
108. Payments from this account totaling over $1,000,000 were made to dozens of
women with Eastern European surnames and to, again, the immigration lawyer in New York
who was involved in one or more forced marriages arranged among Epstein’s victims to secure
a victim’s immigration status.
109. Indyke made wire transfers from another of Epstein’s personal accounts with a
different bank totaling almost $50,000 between November 2016 and July 2019 (just before
Epstein’s arrest) to women with Eastern European surnames, including one known to have
recruited young women and girls for Epstein.

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110. From another of Epstein’s personal accounts with another different bank, for
which Indyke had signatory authority, someone acting on Epstein’s behalf made a total of 21
separate withdrawals each in the amount of $1,000 on every but one business day from April 9,
2019 to May 8, 2019.
111. Payments from this account totaling almost $60,000 were transferred by wire to
young women mostly at foreign beneficiary banks in February and March 2016.
112. Upon information and belief, based on their authority for the accounts, their
interactions with the relevant banks, and records indicating that they made or approved the
transactions, these payments could have only been made with the knowledge and/or at the
direction of Indyke and Kahn.
113. The sheer complexity of the infrastructure that Epstein set up and maintained
with the participation of Kahn and Indyke suggest their unlawful purpose. Based on the
Government’s current knowledge, Epstein, with Kahn and Indyke, held and managed at least
140 different bank accounts for Epstein and Epstein-owned entities, many of which existed only
to transfer payments to other entities and accounts.
114. Kahn and Indyke profited substantially from their relationship with Epstein.
The amount of their payments is further evidence of the illicit nature of the work they
performed.
115. From 2011 to 2019, Epstein and Epstein-owned entities paid over $16 million
net to Defendant/Co-Executor Indyke, and over $10 million net to Defendant/Co-Executor
Kahn. This includes loans that are still outstanding to Indyke- and Kahn-related entities. Based
on records obtained so far, tax forms provided by Epstein entities did not report nearly the full
compensation to Indyke and Kahn.

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116. Indyke and Kahn were paid through multiple entities, including HBRK
Associates, Inc. (Kahn), Coatue Enterprises, LLC (Kahn), Birch Tree BR, LLC (Indyke)
Harlequin Dane, LLC (Indyke) and Darren K Indyke, PLLC, which functioned as shell
companies and engaged in no activities other than to coordinate the activities of Epstein’s
Enterprise, including the receiving and sending money to other entities they held.
117. Since they were appointed as Co-Executors of the Epstein Estate in 2019,
Defendants Indyke and Kahn have approved the release of Estate funds to pay for the legal fees
and costs of persons who—like the Co-Executors themselves—are alleged herein to have
participated in the criminal activity of the Epstein Enterprise.
C. The "Epstein Enterprise" Abused Privileges of Residency to Carry out its

Criminal Scheme
118. The Epstein Enterprise in 1998 acquired Little St. James in the Virgin Islands as
the perfect hideaway and haven for trafficking young women and underage girls for sexual
servitude, child abuse and sexual assault. Little St. James is a secluded, private island, nearly
two miles from St. Thomas with no other residents. It can be visited only by private boat or
helicopter; no public or commercial transportation is available to carry persons on or off the
island, and no bridge connects the island to St. Thomas. Epstein had easy access to Little St.
James from the private airfield on St. Thomas, only 10 minutes away by his private helicopter,
but the women and children he trafficked, abused, and held there were not able to leave without
his permission and assistance, as it was too far and dangerous to swim to St. Thomas.
119. In 2016, upon information and belief, using a straw purchaser to hide Epstein's
identity, the Epstein Enterprise acquired Great St. James the nearest island to Little St. James. By
then, Epstein was a convicted sex offender. Upon information and belief, the Epstein Enterprise
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purchased the island for more than $20 million because its participants wanted to ensure that the
island did not become a base from which others could view their activities or visitors. By acquiring
ownership and control of Great St. James to the exclusion of others, the Epstein Enterprise created
additional barriers to prevent those held involuntarily on Little St. James from escaping or
obtaining help from others.
120. Great St. James and Little St. James are environmentally sensitive locations, with
native coral and wildlife protected by federal and territorial law and enforcement authorities. The
Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in
the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin
Islands. Under its authority, DPNR repeatedly issued citations and assessed thousands of dollars
of fines for violations of the Virgin Islands construction code and environmental protection laws
on both Little St. James and Great St. James—significant penalties to the agency and to the
average resident of the Virgin Islands. But because of Epstein's enormous wealth, these fines had
little effect in curbing or stopping the Epstein Enterprise's unlawful conduct or conforming its
activities to the law.
121. As a result of illegal construction activity of the Epstein Enterprise, the Virgin
Islands has incurred, and will incur, significant expenses to remove the illegal construction or
remediate its effects on natural resources in and around Little St. James and Great St. James. The
extent of the potential environmental damage is unknown at this time as the illegal construction
has not been removed or remediated.
122. The Epstein Enterprise continues to attempt to prevent or limit DPNR authorities
from conducting random inspections on the Little St. James and Great St. James necessary to
comply with Virgin Islands law.

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123. The Epstein Enterprise's violation of the construction and environmental laws was
part of a pattern of behavior in flouting the laws of the Virgin Islands and holding itself above the
law. Upon information and belief, as described above, the Epstein Enterprise undertook
construction at Great St. James after 2016 to continue the scheme to carry out and conceal his
trafficking and sexual abuse of young women and children in the Virgin Islands. These actions
are also indicative of the Epstein Enterprise's disregard for Virgin Islands' law. The Epstein
Enterprise used the Virgin Islands' land, resources, people, and laws for its illicit purposes.
Rather than participating lawfully in this community, the Epstein Enterprise took advantage of
the secluded nature of the islands in furtherance of its crimes.
124. As a result of its deplorable and unlawful conduct, the Epstein Enterprise has
subjected the Virgin Islands to public portrayals as a hiding place for human trafficking and sex
crimes.
D. The "Epstein Enterprise" Fraudulently Concealed its Conduct
125. The Epstein Enterprise fraudulently concealed its actions to prevent detection by
the Government of the Virgin Islands.
126. The secluded properties at Little St. James and Great St. James were repeatedly
used by the Epstein Enterprise as the locations for unlawfully soliciting, transporting,
transferring, harboring, receiving, providing, isolating, patronizing, maintaining, deceiving,
coercing, and sexually abusing young women and children and concealing these crimes.
127. The Epstein Enterprise was able to hide the trafficking ring from law
enforcement, despite the fact that Epstein was a registered sex offender. Given the isolation of
the Little St. James and Great St. James and the nature of the crimes and of the victims targeted
by the Epstein Enterprise, the activities of the Epstein Enterprise were not readily detectable.
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Moreover, Epstein's great wealth and power likely made witnesses reluctant to report their
observations to the local law enforcement.
128. Upon information and belief, the Epstein Enterprise prevented its employees from
cooperating with law enforcement. Employees and others were required to sign confidentiality
agreements that prohibited them from speaking to or sharing information with law enforcement.
If they were contacted by law enforcement they were to notify the Epstein Enterprise and be
represented by Epstein's counsel.
129. The employees were directed not to communicate or interact with guests visiting
Little St. James and were also directed not to disclose to anyone events that occurred on the island.
130. Monitoring a sex offender with his own private islands and the resources to fly
victims in and out on private planes and helicopters presented unique challenges and allowed the
Epstein Enterprise to limit scrutiny by the Government of the Virgin Islands.
131. Sexual Offender Registration and Community Protection Act ("SORCPA") 14
V.I.C. § 1721, et. seq. requires sex offenders to register in their resident jurisdictions and to make
periodic in-person appearances to verify and update their registration information.
132. Epstein renewed his registration each year in the Virgin Islands. In addition,
beyond this statutory requirement, the Virgin Islands periodically visited—or attempted to
visit—Little St. James to conduct additional address verifications.
133. At his last verification in July 2018, Epstein refused to permit Virgin Islands
Department of Justice Investigators, assisted by United States Marshals, to enter Little St. James
beyond its dock, claiming that the dock was his "front door." Instead, Epstein arranged to be met
at his office on St. Thomas.

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134. Epstein also misled the Government regarding his travel plans. On March 19, 2019,
the Virgin Islands was notified that Epstein would be traveling to France for 10 days on the private
plane owned by Plan D, LLC. His notification form did not disclose travel to any other countries. It
was later found by law enforcement authorities that Epstein also travelled to Vienna and Monaco
during that trip.
135. Similarly, the Epstein Enterprise sought to prevent DPNR from conducting
routine site visits to inspect unpermitted and potentially damaging construction activity on Great
St. James. The Epstein Enterprise repeatedly objected to DPNR's inspections referring to them as
"invasions" of Epstein's constitutional right to privacy in his home, which he described defined
as the entire island. These DPNR inspections are required for all construction and Virgin Islands
residents are required to cooperate with the inspections to assure compliance with the law
throughout the construction phases.
136. These efforts represent Epstein Enterprise's intent to conceal its unlawful activity
on Little St. James and Great St. James.
137. The Epstein Enterprise also created numerous corporations and limited liability
companies in the Virgin Islands to help conceal its unlawful activity. Most of these companies were
created in 2011 and 2012, soon after Epstein registered as a sex offender in the Virgin Islands.
138. Epstein's pilot, Larry Visoski is identified as member or co-member in companies
that serviced and maintained the planes that the Epstein Enterprise used to traffick young women
and children — Freedom Air Petroleum, LLC (registered November 28, 2011 to hold assets);
and JEGE, LLC (registered October 19, 2012 to hold assets).

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139. Other Epstein entities include LSJ Employees, LLC (registered October 27, 2011
to provide services); Southern Financial, LLC (registered February 25, 2013 to provide services)
and LSJ Emergency, LLC (registered December 2, 2015 to provide services).
140. Some of these companies held considerable assets: Financial Informatics, Inc.
(incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of
approximately $391 million in 2015; and Financial Trust Company, Inc. (incorporated November
6, 1998) had assets of $212 million when it publicly filed its last balance sheet in 2012.
141. Though often absent in the original incorporation or registration documents or
annual filings, Epstein ultimately appeared as president, director, manager, or sole member of
each of these companies. Upon information and belief, the purpose of this complex array of
corporate entities—some of which may still be discovered—was to allow Epstein to shelter his
assets in order to fund, carry out, and conceal his identity and pattern of criminal conduct.
142. The Estate continues to engage in a course of conduct aimed at concealing the
criminal activities of the Epstein Enterprise. On November 24, 2019, Epstein's Estate filed an
Expedited Motion for Establishment of a Voluntary Claims Resolution Program in the Superior
Court of the Virgin Islands. ("Motion"). According to the Motion, the proposed program was to
be designed to "establish an independent and voluntary claims resolution program for purposes
of resolving sexual abuse claims against Jeffrey E. Epstein." (Motion, at 1).
143. The program proposed by the Estate, whose executors are trustees of The 1953
Trust and officers in at least two Epstein entities, imposes confidentiality requirements and
requires any claimant accepting an award under the program to sacrifice any other claims against
"any person or entity arising from or related to Mr. Epstein's conduct." (Motion, at 5). It acts to
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conceal the criminal activities of the Epstein Enterprise and shield its participants from liability
and accountability for the injury they caused to the victims.
144. The Estate also refused to agree to preserve documents or to release individuals
from the non-disclosure agreements.
145. Two days before his death, Epstein amended The Trust and his Last Will and
Testament. Upon information and belief, he did so, as part of a pattern and ongoing effort to
conceal and shield his assets from potential recovery by claimants.
E. The "Epstein Enterprise" Violated Numerous Virgin Islands Laws
146. The pattern of criminal activity engaged in by Epstein and other participants in
the Epstein Enterprise violated 14 V.I.C. §§ 605 and 607 of the Criminally Influenced and
Corrupt Organizations Act ("CICO").
147. The Epstein Enterprise also violated Title 14, Chapter 3A, The Virgin Islands
Uniform Prevention of and Remedies for Human Trafficking Act relating to Trafficking of
Persons; Title 14, Chapter 24, relating to Child Protection and Child Abuse and Neglect; Title
14, Chapter 81, relating to Prostitution and Related Offenses; Title 18, Chapter 85, relating to
Rape and Sexual Assault and other related offenses, as well as other Virgin Islands laws.
148. The Epstein Enterprise violated Virgin Islands laws by engaging in the human
trafficking of underage girls and young women and commercial sex with young women and
underage girls by force, fraud, enticement, or coercion, which serve as predicates to the Epstein
Enterprise's violations of CICO.
149. Certain participants who recruited women and underage girls to be trafficked
and forced into sexual servitude themselves were sexually trafficked and abused by the Epstein
Enterprise and may be afforded the protections of 14 V.I.C. § 145.

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150. Specifically, Plan D, LLC knowingly and intentionally facilitated the
trafficking scheme by flying underage girls and young women into the Virgin Islands to be
delivered into sexual servitude. Plan D LLC repeatedly made flights from the mainland to
St. Thomas with Epstein and underage girls and young women for the purpose of engaging
in sexual activity on Little St. James. On some occasions, they would transpo rt Epstein
and female children by helicopter to Little St. James. On other occasions, Epstein and the
young women and girls would be transported by boat.
151. Great St. Jim, LLC and Nautilus, Inc. knowingly participated in the Epstein
Enterprise and facilitated the trafficking and sexual servitude of young women and underage
girls by providing the secluded properties at, from, or to which Epstein and his associates were
able to transport, transfer, receive, maintain, isolate, harbor, provide, entice, deceive, coerce,
and sexually abuse underage girls and young women.
152. The Epstein Enterprise engaged in a continuing course of unlawful conduct.
153. After Epstein's suicide, the Epstein Enterprise continued to exist as each of the
participants continued to conspire to prevent detection of the breadth and scope of the Epstein
Enterprise's criminal wrongdoing and to prevent accountability. These conspiratorial acts are
ongoing.
154. The conduct of the Epstein Enterprise offends the core purpose of the Virgin
Islands Uniform Prevention of and Remedies for Human Trafficking Act, 14 V.I.C. §131 et seq,
and violates CICO, enacted to "curtail criminal activity and lessen its economic and political
power in the Territory of the Virgin Islands by establishing new penal prohibitions and
providing to law enforcement and the victims of criminal activity new civil sanctions and
remedies." 14 V.I.C. § 601.

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155. The Epstein Enterprise is an illicit enterprise within the meaning of 14 V.I.C. §§
604 and 605.
156. The Government is entitled to recover civil penalties, damages and other
remedies and to extinguish and recoup from the Epstein Enterprise and its participants any and
all financial and other benefits, and any personal and real property that was used during the
course of, or intended for use in the Course of the conduct or criminal activity in violation of the
laws of the Virgin Islands. The Government is entitled to obtain through divestiture, forfeiture,
or other equitable relief all properties and instrumentalities used by the Epstein Enterprise in the
criminal pattern of trafficking and sexual abuse in the Virgin Islands, including but not limited
to Great St. James and Little St. James, and all other remedies and penalties permitted by law in
the interest of justice.
F. The Epstein Enterprise Used Corporate Entities to Defraud the Government

and Fund its Criminal Activities
1. Defendant Southern Trust Company, Inc.
157. In October 2012, the Southern Trust Company applied for economic benefits
from the Economic Development Commission ("EDC"). The EDC is a subsidiary of the Virgin
Islands Economic Development Authority ("EDA"), a semi-autonomous governmental
instrumentality created and governed pursuant to 29 VIC § 1101.
158. In sworn testimony at a public hearing on the tax incentive application
conducted by the EDC on November 15, 2012, Epstein and his attorney, Ericka Kellerhals,
described Southern Trust Company as providing "cutting edge consulting services" in the area
of "biomedical and financial informatics."

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159. The EDC granted Southern Trust Company a 10-year package of economic
incentives running from February 1, 2013 until January 31, 2023 that included a 90%
exemption from income taxes and 100% exemptions from gross receipts, excise, and
withholding taxes in the Virgin Islands.
160. Between 2013 and 2019, Southern Trust Company employed 13 different
individuals (not including Epstein). Of those 13 individuals, 11 served in administrative or
support roles: six as personal, administrative, or executive assistants, receptionists, or as a
driver/helper, one as an office manager, one as a clerk, and three in accounting or payroll
functions (though only one was licensed as a certified public accountant). There was one
network administrator/IT manager, and a second who was added in 2019.
161. In fact, several of those individuals seemed to perform other personal services
for Jeffrey Epstein. Though he was reported by Southern Trust Company to be resident of the
Virgin Islands, the network administrator/IT manager was issued a Florida driver's license,
which listed an address in Miami. Further, he appears, in fact, to have served as Epstein's driver
and picked up luggage and cargo from Epstein's private planes on his behalf.
162. Another executive assistant lived at 301 E. 66th Street, Apartment 11B, New
York, New York. Epstein's address book lists various units in this building as providing "Apt.
for models" and she is publicly identified as a model. As noted above, the Epstein Enterprise
used modeling opportunities and contracts as a pretext for recruiting underage girls and young
women into its sex trafficking scheme.
163. Financial records more recently obtained show that the employee described
above whom Kahn represented to be, alternatively, an interior designer and a dentist, was also a
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paid employee of Southern Trust Company, which did not actually or even pretend to perform
either interior design or dentistry services, in 2019.
164. During several time periods, Southern Trust Company affirmed to EDC that it
had no employees who were non-residents, even though it employed non-residents.
165. Southern Trust company does not appear to have had any clients and performed
no visible informatics services. According to financial records, it held no investments for others.
Instead, its employees performed tasks related to any number of other Epstein-owned companies
or properties, such as Little St. James.
166. Despite having no visible clients and only one full-time employee working on
information technology during the bulk of the period, Southern Trust Company reportedly
generated net income of $50.3 million in 2013, $67.5 million in 2014, $52.8 million in 2015, and
$4.8 million in 2016 and $17.1 million in 2017, with aggregate income of $117.8 million in 2014,
$170.6 million in 2015, $175.3 million in 2016 and $192.4 million in 2017, or aggregate income
for the period of $656 million.
167. Money received by Southern Trust was then funneled, frequently by Defendant
Indyke as authorized signatory, and often with copies given to Defendant Kahn, through other
Epstein-owned entities and accounts, funding payments to foreign women and for credit cards,
airplanes, and other instrumentalities of the Epstein Enterprise.
168. In fact, the main source of funds for the Epstein Enterprise came from Southern
Trust. Between 2013 and 2017, Southern Trust reported approximately $184 million in
revenues.
169. Defendants Kahn and Indyke directed and controlled the day-to-day activities of
Southern Trust in form and in substance, serving as members of its Board of Directors, along
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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.

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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 Zorro 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.

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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 $106,394.60 in Santa Fe property taxes on
November 6, 2018.
185. Similarly, in 2017, Cypress reported as its only asset cash in the amount of
$29,736 and expenses of $150, despite it paying $55,770.41 and $113,679.56 in Santa Fe
property taxes during 2017.
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 $336,471.87 in New York City property taxes
during 2018.
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188. Similarly, in 2017, Maple reported as its only asset cash in the amount of
$18,281 and expenses of $150, despite it paying $327,497.48 and $6,487.04 in New York City
property taxes during 2017.
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 $196,673.56 in Palm Beach property
taxes on November 6, 2018.
191. Similarly, in 2017, Laurel reported as its only asset cash in the amount of
$37,129 and expenses of $150, despite it paying $191,941.52 in Palm Beach property taxes on
October 31, 2017.
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 . . .”

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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.
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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. Defendants also attempted to conceal their criminal sex trafficking and abuse
conduct by paying large sums of money to participant-witnesses, including by paying for their
attorneys’ fees and case costs in litigation related to this conduct.
204. Epstein also threatened harm to victims and helped release damaging stories
about them to damage their credibility when they tried to go public with their stories of being
trafficked and sexually abused.
205. Epstein also instructed one or more Epstein Enterprise participant-witnesses to
destroy evidence relevant to ongoing court proceedings involving Defendants’ criminal sex
trafficking and abuse conduct.
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.
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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
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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.C § 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.

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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.C § 133
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).

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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.C § 134
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.

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COUNT FOUR
Human Trafficking — Forced Labor
14 V.I.C. § 600 et seq. and 14 V.I.C § 134
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.

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COUNT FIVE
Human Trafficking — Sexual Servitude
14 V.I.C. § 600 et seq. and 14 V.I.C § 135
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.
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
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given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts
with Epstein and others.
COUNT SIX
Human Trafficking — Sexual Servitude
14 V.I.C. § 600 et seq. and 14 V.I.C § 135
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.

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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.
COUNT SEVEN
Human Trafficking — Patronizing Minors and Victims of Sexual Servitude
14 V.I.C. § 600 et seq. and 14 V.I.C §§ 136-37

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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.
of CICO 14 V.I.C. §600 et seq.
COUNT EIGHT
Human Trafficking — Patronizing Minors and Victims of Sexual Servitude
14 V.I.C. § 600 et seq. and 14 V.I.C §§ 136-37
if fully set forth herein

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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.
forced labor, and sexual servitude.
of CICO 14 V.I.C. §600 et seq.

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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.C §§ 505, 506 and 507
if as if fully set forth herein.
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.
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.

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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.C §§ 505, 506 and 507
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 Title 14 V.I.C. § 500 et seq.
282. As a result of Defendants' actions, numerous young girls suffered serious
physical, mental and emotional injury.

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COUNT ELEVEN
Aggravated Rape—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.C § 1700a
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

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COUNT TWELVE
Aggravated Rape
Capacities,
laws prohibiting aggravated rape.
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

Page 55 of 76
COUNT THIRTEEN
Rape in the Second Degree—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.C § 1702
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.

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COUNT FOURTEEN
Rape in the Second Degree
Capacities,
14 V.I.C. § 600 et seq. and 14 V.I.C § 1702
laws prohibiting rape in the second degree.
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.
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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
14 V.I.C. § 600 et seq. and 14 V.I.C §§ 1708 and 1709
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.

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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
Capacities,
14 V.I.C. § 600 et seq. and 14 V.I.C §§ 1708 and 1709
laws prohibiting unlawful sexual contact.
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

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14 V.I.C. §600 et seq.
COUNT SEVENTEEN
Prostitution and Keeping House of Prostitution
14 V.I.C. § 600 et seq. and 14 V.I.C. §§ 1622, 1624
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.

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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

Page 61 of 76
COUNT EIGHTEEN
Prostitution and Keeping House of Prostitution
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
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

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knowing or reckless disregard of the laws of the Virgin Islands
14 V.I.C. §600 et seq.
COUNT NINETEEN
Sex Offender Registry—Estate of Jeffrey E. Epstein
14 V.I.C. § 600 et seq. and 14 V.I.C. § 1721 et seq.
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.

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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.I.C. §604(j).
COUNT TWENTY
Fraudulent Conveyance
14 V.I.C. § 600 et seq. and 14 V.I.C. §§ 832-833
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.
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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
COUNT TWENTY-ONE
Fraudulent Conveyance
14 V.I.C. § 600 et seq. and 14 V.I.C. §§ 832-833
372. At all times material herein, each Defendant joined in a conspiracy to commit
fraudulent conveyances.
the criminal conspiracy, including, but not limited to, transferring assets to and between various
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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.

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COUNT TWENTY-TWO
Civil Conspiracy
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.
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COUNT TWENTY-THREE
Fraudulent Claims Upon the Government—Southern Trust Company, Inc.
14 V.I.C. § 600 et seq. and 14 V.I.C. § 843
390. At all times relevant and material herein, each Defendant directly and indirectly
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.

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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.
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.
CICO. 14 V.I.C. § 600 et seq.
COUNT TWENTY-FOUR
Fraudulent Claims Upon the Government—Southern Trust Company, Inc.
14 VI.C. § 600 et seq. and 14 V.I.C. § 843
400. At all times material herein, each Defendant joined in a conspiracy to commit
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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.
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women in knowing and reckless disregard of the laws of the Virgin Islands.
COUNT TWENTY-FIVE
Fraudulent Claims Upon the Government—Cypress, Inc.; Maple, Inc.; Laurel, Inc.
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
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
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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 . . . .”
417. Defendants’ knowingly and willfully made false representations to the
Government regarding the assets and expenses of Cypress, Maple, and Laurel, and their conduct
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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.
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
entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder, or delay claims
against them.
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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.
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,
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.

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;

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
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: ariel.smith@doj.vi.gov
(340) 774-5666 ext. 10101

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IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS

DIVISION OF ST. THOMAS AND ST. JOHN

GOVERNMENT OF THE UNITED STATES

SECOND AMENDED COMPLAINT

JURISDICTION AND PARTIES

V.I.C. § 76 and 14 V.I.C. § 607.

4. The Virgin Islands is an unincorporated territory of the United States. It consists

James and Great St. James.

5. Jeffrey E. Epstein ("Epstein") was a resident of the Virgin Islands and he

purchased Great St. James.

8. Defendant Darren K. Indyke ("Defendant Indyke") is co-executor of the Estate of

activity of the “Epstein Enterprise,” as set forth below.

9. Defendant Richard D. Kahn ("Defendant Kahn") is co-executor of The Estate of

activity of the “Epstein Enterprise,” as set forth below.

located in the Virgin Islands at $577,672,654.00 dollars.

a. $56.5 million in cash;

b. $127 million in fixed income and equity investments;

c. $195 million in hedge fund and private equity investments; and

d. $18.5 million in planes, boats, and automobiles.

and real property used by Epstein, namely:

a. Brownstone in New York City valued at $56 million;

b. Ranch in New Mexico valued at $72 million;

c. Gated home in Palm Beach, Florida, valued at $12 million;

d. Seven units in an apartment building in Paris, valued at $8 million; and

Kahn began their Co-Executorship of the Estate.

Epstein and the Epstein Enterprise described below.

Trust on August 26, 2019.

18. Epstein maintained a deliberately complex web of Virgin Islands corporations,

conceal the unlawful acts described in this Complaint.

laws of the Virgin Islands. It was incorporated on November 22, 2011.

at $3.2 million, with buildings and improvements valued at $4 million.

Inc., which holds title to Little St. James at $63.9 million.

via a warranty deed dated April 27, 1998.

leaving freely and escaping the abuse.

LLC, acquired the last two parcels for $5 million each.

an instrumentality of those crimes.

Poplar, Inc., respectively.

31. A certificate of incumbency provided to the Department of Planning and Natural

incorporators to conduct "transactions related to permitting matters submitted on behalf of Great

St. Jim, LLC."

participated in carrying out, concealing, facilitating and continuing Epstein's crimes.

behind Plan D, LLC.

Hyperion Air, LLC is listed in its Annual Report as "holding assets."

and Little St. James.

Epstein was the sole owner of Southern Trust Company.

as Vice President/Secretary/Director and Treasurer/Director of Cypress, Inc. Cypress, Inc. owns

about December 2011, shortly after it was incorporated.

December 23, 2011, shortly after it was incorporated.

President/Secretary/Director and Treasurer/Director of Laurel, Inc. Laurel, Inc. owns the

December 2011, shortly after it was formed.

and concealed Epstein's illegal conduct.

and forced labor.

abuse and exploitation.

exploitation of numerous girls between the age of 12 and 17 years old.

52. On the pretext of providing modeling opportunities, careers and contracts,

sexually abused and exploited.

Epstein and others engage in sexual acts with children.

others, in the Virgin Islands through 2018.

Epstein's residence at Little St. James in the Virgin Islands.