First Amended Complaint (Legal Document) - EFTA00018778

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Extraction Summary

4

People

10

Organizations

12

Locations

8

Events

4

Relationships

3

Quotes

Document Information

Type: First amended complaint (legal document)

File Size: 5.86 MB

Summary

This document is the First Amended Complaint filed by the Government of the United States Virgin Islands against the Estate of Jeffrey Epstein and associated entities and individuals. It details Epstein's residency in the Virgin Islands, his status as a registered sex offender, his death, and the complex web of corporations and trusts he used to conceal assets and facilitate criminal activities, including the trafficking and sexual abuse of women and underage girls on Little St. James and Great St. James. The complaint outlines the substantial value of Epstein's estate and assets located globally, as well as the roles of his co-executors, Darren K. Indyke and Richard D. Kahn.

People (4)

Name	Role	Context
Jeffrey E. Epstein	Resident, sex offender, deceased	Subject of the complaint, resident of Virgin Islands, acquired Little St. James (1998) and Great St. James (2016), re...
Darren K. Indyke	Co-executor, Administrator	Co-executor for the Estate of Jeffrey E. Epstein and Administrator of The 1953 Trust. Filed Petition for Probate and ...
Richard D. Kahn	Co-executor, Administrator	Co-executor for the Estate of Jeffrey E. Epstein and Administrator of The 1953 Trust. Filed Petition for Probate and ...
John and Jane Does	Defendants	Unnamed defendants in the lawsuit.

Organizations (10)

Name	Type	Context
Government of the United States Virgin Islands		Plaintiff in the action for damages, represented by the Attorney General.
Estate of Jeffrey E. Epstein		Defendant, created upon Epstein's death, domiciled in the Virgin Islands. Its assets are detailed.
The 1953 Trust		Defendant, created by Epstein, amended and restated two days before his suicide, recipient of all of Epstein's proper...
PLAN D, LLC		Defendant, corporate entity associated with Epstein.
GREAT ST. JME, LLC		Defendant, corporate entity associated with Epstein.
NAUTILUS, INC.		Defendant, corporation established under Virgin Islands law (Nov 22, 2011), owns Little St. James (Parcel 109803010100).
HYPERION AIR, LLC		Defendant, corporate entity associated with Epstein.
POPLAR, INC.		Defendant, corporate entity associated with Epstein.
SOUTHERN TRUST COMPANY, INC.		Defendant, corporate entity associated with Epstein.
Virgin Islands Department of Justice (VIDOJ)		Enforces sex offender registration and address verification.

Timeline (8 events)

1998

Jeffrey Epstein acquired Little St. James.

Little St. James, Virgin Islands

Jeffrey E. Epstein

View

2010

Jeffrey Epstein registered as a sex offender in the Virgin Islands.

Virgin Islands

Jeffrey E. Epstein

View

2011-11-22

Nautilus, Inc. was incorporated under the laws of the Virgin Islands.

Virgin Islands

View

2016

Jeffrey Epstein purchased Great St. James.

Great St. James, Virgin Islands

Jeffrey E. Epstein

View

2019-08-10

Jeffrey Epstein was found dead while in custody for sex crimes.

New York

Jeffrey E. Epstein

View

2019-08-13

Epstein amended and restated The 1953 Trust terms and revised his Last Will and Testament, transferring all property to The Trust.

Jeffrey E. Epstein

View

2019-08-15

Defendants Indyke and Kahn filed a Petition for Probate and Letters Testamentary.

Superior Court of the Virgin Islands, Probate Division

Darren K. Indyke Richard D. Kahn

View

2019-08-26

Defendants Indyke and Kahn filed a Certificate of Trust for The 1953 Trust.

Superior Court of the Virgin Islands

Darren K. Indyke Richard D. Kahn

View

Locations (12)

Location	Context
Virgin Islands	Unincorporated territory of the United States; Epstein was a resident and sex offender here; location of many of his ...
St. Thomas	Island in the Virgin Islands.
St. John	Island in the Virgin Islands, site of Superior Court division.
St. Croix	Island in the Virgin Islands.
Water Island	Island in the Virgin Islands.
Little St. James	Privately owned island in the Virgin Islands, acquired by Epstein in 1998, later owned by Nautilus, Inc., valued at $...
Great St. James	Privately owned island in the Virgin Islands, purchased by Epstein in 2016, valued at $86 million collectively with L...
New York	Location where Epstein was in custody and found dead (August 10, 2019). Also a Brownstone in New York City valued at ...
New York City	Location of a Brownstone owned by Epstein, valued at $56 million.
New Mexico	Location of a Ranch owned by Epstein, valued at $72 million.
Palm Beach, Florida	Location of a gated home owned by Epstein, valued at $12 million.
Paris	Location of seven units in an apartment building owned by Epstein, valued at $8 million.

Relationships (4)

Jeffrey E. Epstein → Executor/Administrator → Darren K. Indyke

Indyke is co-executor of Epstein's Estate and Administrator of The 1953 Trust.

Jeffrey E. Epstein → Executor/Administrator → Richard D. Kahn

Kahn is co-executor of Epstein's Estate and Administrator of The 1953 Trust.

Jeffrey E. Epstein → Creator/Benefactor → The 1953 Trust

Epstein created and transferred all his property to The 1953 Trust.

Jeffrey E. Epstein → Associated entity (director/owner) → Nautilus, Inc.

Epstein directed activities of entities like Nautilus, Inc., which owned Little St. James.

Key Quotes (3)

"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."

Source

EFTA00018778.pdf

Quote #1

"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."

Source

EFTA00018778.pdf

Quote #2

"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."

Source

EFTA00018778.pdf

Quote #3

Full Extracted Text

Complete text extracted from the document (6,997 characters)

Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 1 of 55

EXHIBIT
A

EFTA00018778

Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 2 of 55

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

GOVERNMENT OF THE UNITED STATES
VIRGIN ISLANDS,

Case No.:

PLAINTIFF,

V.

ACTION FOR DAMAGES

DARREN K. INDYKE, in his capacity as the
EXECUTOR FOR THE ESTATE OF JEFFREY E.
EPSTEIN and ADMINISTRATOR OF THE 1953
TRUST; RICHARD D. KAHN, 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.
JME, LLC; NAUTILUS, INC.; HYPERION AIR,
LLC; POPLAR, INC.; SOUTHERN TRUST
COMPANY, INC.; JOHN AND JANE DOES

JURY TRIAL DEMANDED

SUPERIOR COURT

DEFENDANTS.

FIRST AMENDED COMPLAINT

COMES NOW, the Government of the United States Virgin Islands (“Government”) and

files this First Amended Complaint against the above-named Defendants 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

to 3 V.I.C. § 114 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.

EFTA00018779

Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 3 of 55
GVI v. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 2 of 55

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.

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

Jeffrey E. Epstein and Administrator of The 1953 Trust.

10. 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

EFTA00018780

Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 4 of 55
GVI v. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 3 of 55

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.

11. The Petition reports the value of the real and personal property in The Estate located

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

12. According to the Petition, the assets in the Virgin Islands thus far includes:

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 has not yet valued his fine arts, antiques, and other valuables.

13. The Estate also includes 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;

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.

14. The Estate is responsible to pay damages for the acts committed by Epstein and the

Epstein Enterprise described below.

15. 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.

EFTA00018781

Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 5 of 55
GVI v. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 4 of 55

16. 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.

17. 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.

18. 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.

19. 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.

20. 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.

21. Defendant, Nautilus, Inc., is a corporation established and organized under the laws

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

22. 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.

EFTA00018782

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EFTA00018778.pdf

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Extraction Summary

Document Information

People (4)

Organizations (10)

Timeline (8 events)

Locations (12)

Relationships (4)

Key Quotes (3)

Full Extracted Text

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