St. Thomas, U.S. Virgin Islands
LocationRelationship Network
2023.10.03%20Response.pdf
In this May 2023 filing to the Superior Court of the Virgin Islands, a pro se incarcerated Ghislaine Maxwell requests a 180-day stay in her civil suit for indemnification against the Estate of Jeffrey Epstein. Maxwell argues she needs time to find new counsel following her previous attorney's withdrawal, citing severe communication restrictions and lack of access to legal resources (computers, state case law) within FCI Tallahassee. She also argues the civil case should be paused pending the outcome of her criminal appeal (2nd Circuit Case 22-14626-CR) and cites a 2002 lawsuit (Shanks v. Wexner) as evidence that Epstein historically indemnified her for legal costs.
2022.08.02%20Memorandum%20Of%20Law.pdf
This document is a Supplemental Brief filed on August 1, 2022, by the Co-Executors of the Estate of Jeffrey Epstein (Indyke and Kahn) in the Superior Court of the Virgin Islands. The brief supports a Motion to Dismiss Ghislaine Maxwell's complaint seeking indemnification from the Estate. The Co-Executors argue that because Maxwell was convicted of intentional criminal acts (sex trafficking and conspiracy) in the Southern District of New York on June 29, 2022, public policy prohibits enforcing any contract or equitable doctrine that would indemnify her for the financial consequences of her crimes.
2020.09.22%20Reply%20Motion.pdf
This document is a Reply Brief filed by the Government of the U.S. Virgin Islands supporting its motion to intervene in Ghislaine Maxwell's lawsuit against the Epstein Estate. The Government argues it must intervene to prevent the dissipation of Estate assets, which Maxwell seeks for her legal defense, because those assets are needed to satisfy potential judgments in the Government's separate 'CICO' (racketeering) enforcement action against the Estate. The brief reveals that the Estate is actively paying legal fees for other associates, including an immigration attorney suspected of obtaining visas for trafficking victims.
2020.09.22%20Exhibit%20M.pdf
This document is a legal letter filed on September 22, 2020, from the Estate of Jeffrey Epstein's legal counsel to Magistrate Judge Hermon-Percell. The letter responds to accusations by the Virgin Islands Attorney General that the Estate is concealing financial information or 'structuring' transactions to avoid scrutiny. The Estate argues that the Attorney General has already received full transparency via subpoenas to FirstBank and requests the Court order the release of liens on the Estate's accounts to prevent irreparable harm.
2020.07.30%20Stipulation%20For%20Extension%20of%20Time.pdf
This document is a legal stipulation filed on July 30, 2020, in the Superior Court of the Virgin Islands (Case ST-20-CV-155). It represents an agreement between Ghislaine Maxwell (Plaintiff) and the Government of the U.S. Virgin Islands (Proposed Intervenor) to extend the deadline for Maxwell to respond to the Government's Motion to Intervene until August 17, 2020. The document lists the Estate of Jeffrey Epstein and his executors, Darren K. Indyke and Richard D. Kahn, as defendants.
2022.03.17%20%20Notice%20-%20Notice%20to%20the%20Court.pdf
This document is an opposition brief filed by the Government of the U.S. Virgin Islands against the Epstein Estate's request for over $112,000 in attorneys' fees. The Government argues that the Estate is not a 'prevailing party' because the underlying court orders were not final judgments, and that the requested hourly rates (up to $1,315/hr) are excessive compared to the local standard of $350/hr. The filing also references the Government's broader CICO lawsuit alleging Epstein used his VI businesses to transport and abuse victims on Little St. James Island.
2021.03.29%20Response%20-%20Response.pdf
This document is a legal response filed by the Co-Executors of Jeffrey Epstein's estate (Indyke and Kahn) on March 29, 2021, opposing the US Virgin Islands Government's appeal regarding their failed motion to intervene in probate proceedings. The executors argue the Government's petition is untimely as the original motion was denied over a year prior, and that the Government's emergency motion regarding estate assets is moot because the estate has replenished the Victims' Compensation Program funds. Attached exhibits include the original 2020 opposition brief and a March 2021 press release confirming the sale of Epstein's NYC and Palm Beach properties to fund the compensation program.
026.pdf
This document is the formal Answer and Affirmative Defenses filed by the Co-Executors of the Jeffrey Epstein Estate (Darren K. Indyke and Richard D. Kahn) in response to a civil complaint by Annie Farmer. The executors generally deny knowledge of the specific allegations of abuse but admit to certain procedural facts, such as Epstein's arrest date (July 6, 2019), death date (August 10, 2019), and property ownership in NY, NM, USVI, FL, and France. They assert ten affirmative defenses, including failure to state a claim, contributory negligence, assumption of risk, and statute of limitations arguments challenging the New York Child Victims' Act.
EFTA00037891.pdf
This document is a chain of emails between law enforcement officials (FAA/FBI) dated August 14-15, 2019, discussing the location and ownership of Jeffrey Epstein's aircraft shortly after his death. An FAA Special Agent reports that Epstein's Gulfstream (N212JE) is located in a hangar in Kennesaw, Georgia, and details its recent flight history from Paris to Teterboro to Brunswick. The emails also identify Lawrence Visoski as the pilot and manager for Epstein's shell companies, Plan D LLC and Hyperion Air LLC, which own the Gulfstream and a Bell helicopter (N331JE).
EFTA00037862.pdf
This document is an email chain involving an FAA Law Enforcement Assistance Program Special Agent regarding aircraft owned by Jeffrey Epstein. The emails track the movement of Gulfstream N212JE from Paris to New Jersey to Georgia in July 2019 and identify its current location at Cobb County Airport. It also identifies a Bell 430 helicopter (N331JE) linked to Epstein and notes that Lawrence Visoski, a known pilot for Epstein, is the registrant/manager for the LLCs (Plan D LLC and Hyperion Air LLC) owning these aircraft.
EFTA00037855.pdf
This document is an email chain from August 2019 in which an FAA Special Agent provides intelligence regarding Jeffrey Epstein's Gulfstream GV-SP aircraft (N212JE). The email reports the aircraft is located in a hangar in Kennesaw, Georgia, and details its recent flight history from Paris to Teterboro and then to Georgia in July 2019. It also identifies the registered owner as 'Plan D LLC' in the US Virgin Islands, managed by Lawrence Visoski, who is noted as a known pilot for Epstein.
EFTA00037807.pdf
This document is an email chain from August 2019 between FAA Law Enforcement Assistance Program agents and other officials regarding Jeffrey Epstein's Gulfstream GV-SP aircraft (N212JE). The emails identify the aircraft's location in a hangar in Kennesaw, Georgia, and detail its flight history from Paris to Teterboro to Brunswick, GA in July 2019. The correspondence confirms that while the plane is registered to 'Plan D LLC' in the USVI with Lawrence Visoski listed as manager, it is effectively owned by Epstein, and Visoski is identified as his pilot.
EFTA00037608.pdf
This document is a U.S. Customs and Border Protection TECS traveler list generated on April 23, 2019. It details a private flight (Tail # N212JE) on June 2, 2018, arriving in Islip, NY (KISP) from St. Thomas (TIST). The manifest lists Jeffrey Epstein as a passenger and David Rodgers and Lawrence Visoski as crew members; Epstein is flagged with multiple law enforcement database hits including NCIC.
EFTA00037590.pdf
This document is a U.S. Customs and Border Protection TECS Traveler List generated on April 23, 2019. It details a private flight (Tail # N212JE) on May 27, 2018, departing from TIST (St. Thomas) and arriving at KPBI (West Palm Beach) at 19:00. The manifest lists Jeffrey Epstein as the sole passenger and David Rodgers and Lawrence Visoski Jr. as crew members.
EFTA00030126.pdf
This document is a 2011 real estate deed transferring the property at 9 East 71st Street, New York, NY, from Nine East 71st Street Corporation to Maple, Inc., a U.S. Virgin Islands corporation. The deed is signed by Jeffrey E. Epstein as President of the grantor corporation. The file also includes a 1989 deed for the same property, a 2019 title search report showing a forfeiture action by the United States against Jeffrey Epstein, and 2019 property tax bills for Maple, Inc.
EFTA00023437.pdf
This document is an email chain between the SDNY U.S. Attorney's Office and the FAA's Law Enforcement Assistance Program regarding an investigation into aircraft owned by Jeffrey Epstein and Ghislaine Maxwell. The FAA agent provides a comprehensive history of registration, sales, and tail number changes for ten specific aircraft (including the 'Lolita Express' Boeing 727 and Gulfstream jets) linked to shell companies like Plan D LLC, JEGE Inc., and Air Ghislaine. The correspondence also reveals flight movements around the time of Epstein's 2019 arrest and notes prior interest in these aircraft from the DEA and FBI.
EFTA00021675.pdf
This document is an email chain between an FAA LEAP Special Agent and an SDNY Assistant US Attorney from Aug-Sept 2021. The FAA agent provides a comprehensive history of aircraft registrations, sales, and shell companies (Plan D, JEGE, Hyperion, Air Ghislaine) linked to Jeffrey Epstein, Ghislaine Maxwell, and their associates Larry Visoski and Darren Indyke. The report includes specific flight movements for N212JE (Gulfstream G550) in July 2019 (Paris to Teterboro to Georgia) around the time of Epstein's arrest.
EFTA00020959.pdf
This document is a Quitclaim Deed recorded on December 30, 2011, transferring ownership of Little St. James Island (Parcels A, B, & C) from L.S.J., LLC to Nautilus, Inc. Jeffrey Epstein signed the deed as the sole member of L.S.J., LLC and provided an affidavit stating he is also the sole beneficial owner of Nautilus, Inc., allowing for a stamp tax exemption on the transfer. The stated value for recording purposes was $6,442,100.00.
EFTA00016841.pdf
This document contains Jeffrey E. Epstein's Last Will and Testament (2001) and four subsequent Codicils (1st, 2nd, 3rd, and 5th). The will leaves all property to the 'Jeffrey E. Epstein 2001 Trust One'. Over time, the codicils change the appointed Executors (moving from Schantz/Hoffman to Jarecki/Cayne/Newman), designate Darren Indyke as successor, and increase executor compensation from $100,000 to $500,000. The 5th Codicil references a 'Fourth Codicil' dated September 5, 2007, which is not included in this specific packet.
EFTA00003034.pdf
This document is an Emergency Contact Form for LSJE, LLC (Little St. James Enterprise) filled out by employee Asheille Etienne on January 27, 2019. The form lists the employee's residence in St. Thomas, VI, and indicates they have no allergies or current medications ('N/A'). Sensitive personal information such as specific street address, phone numbers, email, date of birth, and driver's license number has been redacted.
EFTA00001884.pdf
A formal letter dated March 14, 2019, from the US Virgin Islands Department of Justice to Jeffrey Epstein, revoking previous travel notification privileges and instituting stricter requirements. The letter mandates that Epstein must appear in person to notify authorities of travel, specifically requiring 21 days' notice for international trips, citing International Megan's Law. It is signed by Acting Attorney General Carol Thomas-Jacobs.
DOJ-OGR-00019021.jpg
This document is a court transcript from a direct examination of a witness named Rodgers. The testimony focuses on two flights from July 2001, confirming that Jeffrey Epstein, Ghislaine Maxwell, and Virginia Roberts were passengers on a flight from Santa Fe to Teterboro. It also establishes that Jeffrey Epstein and Virginia Roberts were the only two passengers on a subsequent flight from St. Thomas to Palm Beach.
DOJ-OGR-00019018.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE, likely US v. Maxwell) featuring the direct examination of a witness named Rodgers, presumably a pilot. The testimony confirms flight details from May 2001, specifically noting that Jeffrey Epstein and Virginia Roberts flew alone from San Antonio to Palm Beach on May 5th, and that Epstein, Roberts, and Ghislaine Maxwell flew together from St. Thomas to Teterboro on May 14th.
DOJ-OGR-00019016.jpg
This document is a page from a court transcript (Case 1:20-cr-00330-PAE) recording the direct examination of a witness named Rodgers. The testimony confirms that Jeffrey Epstein and Virginia Roberts were passengers together on two flights on April 9, 2001, traveling from Palm Beach to Atlantic City, and then to Teterboro. It also documents a subsequent flight on April 11, 2001, from Teterboro to St. Thomas.
DOJ-OGR-00019009.jpg
This document is a page from a court transcript filed on August 10, 2022. In it, a witness named Rodgers confirms under direct examination that Jeffrey Epstein, Ghislaine Maxwell, and Virginia Roberts were passengers together on two separate flights. One of these flights is identified as taking place on January 30, 2001, from St. Thomas, U.S. Virgin Islands, to Palm Beach, Florida.
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