EFTA00161836

Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 21 of 34 
and inexcusable in the context of the heightened scrutiny that should have 
occurred in the monitoring of a high-risk customer." 
81. 
The NYSDFS also found fault with Deutsche Bank's failure to obtain answers 
regarding Epstein's use of his accounts to pay women with Eastern European surnames: "In a May 
2018 email, a compliance officer submitted an inquiry . . . about payments to the accounts of 
women with Eastern European surnames at a Russian bank, and asking for an explanation of the 
purpose of the wire transactions and Epstein's relationship with the counterparties."5
82. 
JP Morgan's failures to appropriately monitor Epstein's accounts and comply with 
federal banking regulations are even more egregious than Deutsche Bank's failures because JP 
Morgan failed to demonstrate even basic due diligence and continued its relationship with Epstein 
for over a decade, despite the glaring indications of criminal activity. 
83. 
84. 
VII. JP Morgan Fraudulently Concealed Its Continuing Violations 
85. 
JP Morgan's continuous illegal conduct has caused repeated and continuous injury. 
86. 
JP Morgan knew—including at the highest level of the bank—that Epstein was an 
extremely high-risk client. Between 2005 and 2013, there were myriad reports that Epstein 
sexually abused women and girls. In 2008, Epstein pled guilty to sexual offenses and registered as 
5 Id. at 15. 
21 
EFTA00161856

Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 22 of 34 
a sex offender. Despite JP Morgan's acknowledgement that it needed to closely monitor Epstein, 
JP Morgan ignored numerous red flags and failed to comply with federal banking regulations until 
years later after JP Morgan was no longer benefiting from Epstein's business. 
87. 
JP Morgan also engaged in a course of conduct aimed at fraudulently concealing 
its illegal conduct, including by failing to timely comply with federal banking regulations in order 
to profit from Epstein's wealth and connections. 
88. 
A key purpose of federal banking regulations is to give law enforcement real-time 
information so that it can act to detect violations of the law and protect public safety. 
89. 
The Government of the Virgin Islands did not know, and could not have known, 
that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind 
eye to unusual cash transactions and wires and failed to carry out or follow up on basic due 
diligence and to timely comply with federal banking regulations, as required by the law. 
90. 
Over more than a decade, JP Morgan clearly knew it was not complying with 
federal regulations in regard to Epstein-related accounts as evidenced by its too-little too-late 
efforts after Epstein was arrested on federal sex trafficking charges and shortly after his death, 
when JP Morgan belatedly complied with federal law. 
91. 
The continued illegal conduct by JP Morgan has caused repeated and continuous 
injury. JP Morgan's illegal conduct was not completed nor were all damages incurred until the 
wrongdoing ceased in August 2019 when JP Morgan began belatedly complying with federal 
banking regulations in regard to Epstein-related accounts. 
22 
EFTA00161857

Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 23 of 34 
CAUSES OF ACTION 
COUNT ONE 
Participating in a Sex-Trafficking Venture 
Violation of Trafficking Victims Protection Act 
18 U.S.C. §§ 1591(a)(2), 1595(d) (Parens Patriae) 
92. 
The Government restates and realleges paragraphs 1 to 91 of this Complaint as if 
fully set forth herein. 
93. 
The Government brings this Count as parens patriae on behalf of the residents and 
visitors of the United States Virgin Islands and pursuant to the Attorney General's express 
statutory authority. 
94. 
JP Morgan knowingly and intentionally participated in Epstein's sex-trafficking 
venture that was in and affecting interstate and foreign commerce, together and with others, in 
violation of 18 U.S.C. § 1591(a)(2) by facilitating payments to women and girls, channeling funds 
to Epstein to fund the operation, and concealing Epstein's criminal conduct by failing to comply 
with federal banking law. 
95. 
JP Morgan knowingly and intentionally benefitted financially from and received 
value for its participation in the sex-trafficking venture in which Epstein and his co-conspirators, 
with JP Morgan's knowledge or reckless disregard of the fact, would use means of force, threats 
of force, fraud, coercion, and a combination of such means to sexually abuse young women and 
underage girls, including by causing them to engage in commercial sex acts, in the Virgin Islands 
and elsewhere. 
96. 
Among the financial benefits that JP Morgan received for participating in and 
facilitating Epstein's sex-trafficking venture was the deposit of funds that Epstein—a Virgin 
Islands resident—and Epstein-controlled entities located in the Virgin Islands made to JP Morgan. 
JP Morgan profited from the use of these deposits. Epstein and Epstein-controlled entities located 
23 
EFTA00161858

Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 24 of 34 
in the Virgin Islands deposited these funds in exchange for JP Morgan's facilitation of and 
participation in Epstein's sex-trafficking venture. 
97. 
Also, among the financial benefits that JP Morgan received for participating in and 
facilitating Epstein's sex-trafficking venture were referrals of business opportunities from Epstein 
and his co-conspirators. JP Morgan profited from, or expected to profit from, these referred 
business opportunities. Epstein referred business entities and business opportunities to JP Morgan 
in exchange for its facilitation of and participation in Epstein's sex-trafficking venture. 
98. 
JP Morgan financially profited from the deposits made by Epstein and Epstein-
controlled entities located in the Virgin Islands and from the business opportunities referred to JP 
Morgan by Epstein and his co-conspirators in exchange for its known facilitation of and implicit 
participation in Epstein's sex trafficking venture. 
99. 
JP Morgan knew and recklessly disregarded and concealed the fact that it was 
Epstein's pattern and practice to use the channels and instrumentalities of interstate and foreign 
commerce to recruit, entice, harbor, transport, provide, obtain, and maintain young women and 
underage girls for purposes of causing them to engage in commercial sex acts in violation of 18 
U.S.C. § 1591(a)(1). 
100. 
JP Morgan and its employees had actual knowledge that they were facilitating 
Epstein's sexual abuse and sex-trafficking conspiracy to recruit, entice, harbor, transport, provide, 
obtain, and maintain young women and underage girls to engage in commercial sex acts through 
the means of force, threats of force, fraud, abuse of process, and coercion. 
101. 
Despite this knowledge, JP Morgan intentionally paid for, concealed, facilitated, 
and participated in Epstein's and his co-conspirators' violations of 18 U.S.C. § 1591(a), which JP 
Morgan knew and was in reckless disregard of the fact that Epstein and his co-conspirators would 
24 
EFTA00161859

Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 25 of 34 
use its bank accounts and financial transactions to coerce, defraud, and force young women and 
underage girls to engage in commercial sex acts. 
102. 
JP Morgan, through its employees and agents and their role in facilitating the 
financial aspect of Epstein's enterprise, actively facilitated or participated in the sex-trafficking 
conspiracy in which Epstein and his co-conspirators led young women and underage girls in the 
Virgin Islands and elsewhere to believe that they would be rewarded if they cooperated with 
Epstein and his co-conspirators and acquiesced to their demands. 
103. 
JP Morgan committed this affirmative conduct knowing or in reckless disregard of 
the fact that Epstein would use cash transactions and financial support provided by JP Morgan as 
a means to defraud, force, and coerce commercial sex acts from young women and underage girls. 
104. 
In addition to having actual knowledge that it was participating in and facilitating 
the Epstein sex-trafficking venture, JP Morgan also knew that it was participating in and 
facilitating a venture that was engaged in coercive sex trafficking in violation of 18 U.S.C. § 
1591(a)(1). 
105. 
In exchange for facilitating and covering up Epstein's commercial sex trafficking, 
JP Morgan's employees received financial benefits and career advancement from JP Morgan. 
106. 
Facilitating and covering up Epstein's sex trafficking venture was a means for JP 
Morgan employees to obtain economic success and promotion within JP Morgan. 
107. 
JP Morgan's knowing and intentional conduct has caused serious harm to the 
Virgin Islands and its residents, including without limitation financial harm, by facilitating the 
commission of sexual abuse against young women and underage girls, including their engagement 
in commercial sex acts, in the Virgin Islands. 
25 
EFTA00161860

Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 26 of 34 
108. 
JP Morgan's tortious conduct in violating the TVPA was outrageous and intentional 
because it was in deliberate furtherance of a widespread and dangerous criminal sex-trafficking 
venture operated in and from the Virgin Islands. JP Morgan's tortious conduct also evidenced a 
high degree of moral turpitude and demonstrated such wanton disregard for the safety of young 
women and underage girls in the Virgin Islands and elsewhere as to imply a deliberate indifference 
to its legal obligations. 
109. 
By virtue of these knowing and intentional violations of 18 U.S.C. § 1591(a)(2), JP 
Morgan is liable to the Government for all appropriate relief under 18 U.S.C. § 1595(d), including 
damages suffered by the Government and/or Epstein's victims, punitive damages, restitution, 
appropriate injunctive relief, fines, reasonable attorneys' fees, and all such other relief as the Court 
deems appropriate. 
COUNT TWO 
Criminal Activity—Participating, Directly or Indirectly, in a Sex-Trafficking Venture 
Violation of Trafficking Victims Protection Act, 18 U.S.C. § 1591(a)(2), 
actionable under Virgin Islands Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. §§ 604(e) and 605(a) 
110. 
The Government restates and realleges paragraphs 1 to 109 of this Complaint as if 
funny set forth herein. 
III. 
The Virgin Islands Legislature enacted the CICO Act with the purpose 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. 
112. 
At all times material herein, JP Morgan was a "person" identified in 14 V.I.C. § 
604(1). 
26 
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Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 27 of 34 
113. 
At all times material herein, Epstein and his co-conspirators were engaged in an 
illicit sex-trafficking "enterprise" as defined in 14 V.I.C. § 604(h). 
114. 
At all times material herein, JP Morgan supported and/or was associated with the 
Epstein sex-trafficking enterprise by providing banking and payment-processing services to 
Epstein, who resided in the Virgin Islands, and Epstein-controlled entities that were located and/or 
incorporated in the Virgin Islands. 
115. 
In providing banking and payment-processing services to Epstein and Epstein-
controlled entities in return for profits realized both from Epstein's and Epstein-controlled entities' 
accounts and from receiving referrals by Epstein of other high-value banking clients, JP Morgan 
knowingly, intentionally, and willfully benefitted financially and by receiving things of value from 
its participation, directly or indirectly, in Epstein's sex-trafficking venture and enterprise, in 
violation of 18 U.S.C. § 1591(a)(2). 
116. 
JP Morgan's knowing, intentional, and willful receipt of financial benefits and 
things of value from its facilitation and participation in Epstein's sex-trafficking venture and 
enterprise through the financial infrastructure it provided and concealed constitutes a felony under 
18 U.S.C. § 1591(b) and "criminal activity" as defined in 14 V.I.C. § 604(e). 
117. 
By knowingly, intentionally, and willfully receiving financial benefits and things 
of value from its participation, directly or indirectly, via financing in Epstein's sex-trafficking 
venture and enterprise, JP Morgan enabled Epstein to have ready and reliable access to and use of 
resources with which to recruit, entice, harbor, transport, provide, obtain, and maintain young 
women and underage girls for purposes of causing them to engage in commercial sex acts in the 
Virgin Islands and elsewhere. JP Morgan thereby unlawfully conducted and/or participated in, 
27 
EFTA00161862

Case 1 22-cv-10904-JSR Document 16 Filed 01/10/23 Page 28 of 34 
directly or indirectly, the affairs of the Epstein sex-trafficking enterprise through a pattern of illegal 
activity in violation of 14 V.I.C. § 605(a). 
118. 
JP Morgan's illegal activity has caused serious harm to the Virgin Islands and its 
residents, including without limitation financial harm, by facilitating the commission of sexual 
abuse against young women and underage girls, including their facilitation and participation, 
directly or indirectly, in commercial sex acts, in the Virgin Islands. 
119. 
By virtue of this pattern of illegal activity in furtherance of the Epstein sex-
trafficking enterprise, JP Morgan is liable to the Government for all appropriate civil remedies 
under 14 V.I.C. § 607, including treble damages suffered by the Government and/or Epstein's 
victims, civil penalties, restitution and/or disgorgement of ill-gotten gains, appropriate injunctive 
relief, attorneys' fees and costs, and all such other relief as the Court deems appropriate. 
COUNT THREE 
Criminal Activity—Willfully Failing To Comply With Federal Banking Law, 
Violation of Bank Secrecy Act, 31 U.S.C. § 5322(a), as it incorporates 
actionable under Virgin Islands 
Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 604(e) and 605(a) 
120. 
The Government restates and realleges paragraphs 1 to 119 of this Complaint as if 
fully set forth herein. 
121. 
The Virgin Islands Legislature enacted the CICO Act with the purpose 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. 
122. 
At all times material herein, JP Morgan was a "person" as defined in 14 V.I.C. 
§ 604(1). 
28 
EFTA00161863

Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 29 of 34 
123. 
At all times material herein, Epstein and his co-conspirators were engaged in an 
illicit sex-trafficking "enterprise" as defined in 14 V.I.C. § 604(h). 
124. 
At all times material herein, JP Morgan was employed by and/or associated with 
the Epstein sex-trafficking enterprise by providing banking and payment-processing services to 
Epstein, who resided in the Virgin Islands, and Epstein-controlled entities that were located and/or 
incorporated in the Virgin Islands. 
125. 
In providing banking and payment-processing services to Epstein and Epstein-
controlled entities, JP Morgan knowingly, intentionally, and willfully failed to comply with federal 
banking regulations in violation of 31 U.S.C. § 5322(a), 
. From accounts maintained and served at JP Morgan, 
Epstein and Epstein-controlled entities received payments of large dollar amounts for no apparent 
business or other lawful purpose and made repeated cash payments, sometimes in amounts and 
patterns designed to evade federal reporting requirements, to young women and/or underage girls 
who were sexually abused and coerced into engaging in commercial sexual acts in the Virgin 
Islands and elsewhere. 
126. 
JP Morgan's knowing, intentional, and willful failure to comply with federal 
banking regulations constitutes a felony under 31 U.S.C. § 5322(a) and "criminal activity" as 
defined in 14 V.I.C. § 604(e). 
29 
EFTA00161864

Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 30 of 34 
127. 
By knowingly, intentionally, and willfully failing to comply with federal banking 
regulations, JP Morgan enabled Epstein to have ready and reliable access to and use of resources 
with which to recruit, entice, harbor, transport, provide, obtain, and maintain young women and 
underage girls for purposes of causing them to engage in commercial sex acts in the Virgin Islands 
and elsewhere. JP Morgan thereby unlawfully conducted and/or participated in, directly or 
indirectly, the affairs of the Epstein sex-trafficking enterprise through a pattern of illegal activity 
in violation of 14 V.I.C. § 605(a). 
128. 
JP Morgan's illegal activity has caused serious harm to the Virgin Islands and its 
residents, including without limitation financial harm, by facilitating the commission of sexual 
abuse against young women and underage girls, including their engagement in commercial sex 
acts, in the Virgin Islands. 
129. 
By virtue of this pattern of illegal activity in furtherance of the Epstein sex-
trafficking enterprise, JP Morgan is liable to the Government for all appropriate civil remedies 
under 14 V.I.C. § 607, including treble damages suffered by the Government and/or Epstein's 
victims, civil penalties, restitution and/or disgorgement of ill-gotten gains, appropriate injunctive 
relief, attorneys' fees and costs, and all such other relief as the Court deems appropriate. 
COUNT FOUR 
Unfair Methods of Competition 
Violation of Virgin Islands Consumer Fraud 
and Deceptive Business Practices Act, 12A V.I.C. § 304 
130. 
The Government restates and realleges paragraphs 1 to 129 of this Complaint as if 
fully set forth herein. 
131. 
Section 304 of Title 12A of the Virgin Islands Code provides that "[i]t is unlawful 
for any person to engage in unfair methods of competition . . . in the conduct of any trade or 
commerce." 
30 
EFTA00161865

Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 31 of 34 
132. 
JP Morgan is a "person" as defined in 12A V.I.C. § 303(h). 
133. 
JP Morgan's provision of banking services and payment processing for Epstein and 
Epstein-controlled entities constitutes "ifirade or commerce" as defined in 12 V.I.C. § 303(k). 
134. 
In return for knowingly and intentionally participating in, directly or indirectly. 
facilitating, and concealing by failing to comply with federal banking regulations regarding 
Epstein-related accounts, JP Morgan both profited from the use of the funds in their accounts and 
received referrals of other high-value business opportunities from Epstein and his co-conspirators. 
135. 
By receiving referrals of high-value business opportunities from Epstein and his 
co-conspirators in return for participating in, directly or indirectly, facilitating, and concealing by 
failing to comply with federal banking regulations regarding Epstein-related accounts, JP Morgan 
unlawfully and unjustly enriched itself at the expense of other banks that complied with their legal 
obligations. This conduct constitutes an unfair method of competition in violation of 12A V.I.C. § 
304. 
136. 
By virtue of its knowing, intentional, and repeated acts constituting unfair 
competition, JP Morgan is liable to the Government for all appropriate civil remedies under 12A 
V.I.C. §§ 328 and 332, including damages, civil penalties awarded on a per-violation basis 
pursuant to 12A V.I.C. § 328(6), appropriate injunctive relief, attorneys' fees and costs, and all 
such other relief as the Court deems appropriate. 
REQUEST FOR RELIEF 
The Government respectfully requests that the Court enter judgment in its favor, and 
against JP Morgan, as follows: 
31 
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Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 32 of 34 
A. 
That the Court award the Government compensatory, consequential, general, and 
nominal damages, as suffered by the Government and/or Epstein's victims, and 
punitive damages, all against JP Morgan in amounts to be awarded at trial; 
B. 
That the Court award the Government punitive and exemplary damages against JP 
Morgan in an amount to be determined at trial; 
C. 
That the Court order JP Morgan to pay appropriate fines to the Government 
pursuant to 18 U.S.C. § 1591(b) in amounts to be determined at trial; 
D. 
That the Court order JP Morgan to provide restitution of all ill-gotten gains to the 
Government pursuant to 18 U.S.C. § 1593 and 14 V.I.C. § 607(a)(6) and 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 the CICO Act, in amounts to 
be determined at trial; 
E. 
That the Court award the Government treble damages against JP Morgan pursuant 
to 14 V.I.C. § 607(c) in an amount to be determined at trial; 
F. 
That the Court order JP Morgan to pay appropriate civil penalties to the 
Government pursuant to 14 V.I.C. § 607(e) and 12A V.I.C. § 328(b) and 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 the CICO Act, in amounts to 
be determined at trial; 
G. 
That the Court enter an injunction pursuant to 14 V.I.C. § 607(a)(2) and 12A V.I.C. 
§ 328(a)(2) to prevent further illegal conduct and any concealment of illegal 
conduct; 
32 
EFTA00161867

Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 33 of 34 
H. 
That the Court order JP Morgan to provide disgorgement of all ill-gotten gains to 
the Government pursuant to 14 V.I.C. § 607(a)(6) and 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 the CICO Act, in amounts to be 
determined at trial; 
I. 
That the Court award the Government attorneys' fees and costs pursuant to 18 
U.S.C. § 1595, 14 V.I.C. § 607(c), and 12A V.I.C. § 332 in amounts to be 
determined after trial; and 
J. 
That the Court award the Government and order JP Morgan to provide all such 
other relief as the Court deems appropriate. 
JURY DEMAND 
The Government demands a jury trial on all issues so triable. 
Dated: January 10, 2023 
CAROL THOMAS-JACOBS, ESQ. 
ACTING ATTORNEY GENERAL 
Is! David I. Ackerman 
DAVID I. ACKERMAN (NYS Bar #4110839) 
Motley Rice LLC 
401 9th Street NW, Suite 630 
Washington, DC 20004 
Tel: (202) 849-4962 
[email protected] 
CAROL THOMAS-JACOBS (NYS Bar #2941300) 
Admitted Pro Hac Vice 
Acting Attorney General of the United States 
Virgin Islands 
Virgin Islands Department of Justice 
34-38 Kronprindsens Gade 
St. Thomas, U.S. Virgin Islands 00802 
Tel.: (340) 774-5666 ext. 10101 
[email protected] 
33 
EFTA00161868

Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 34 of 34 
LINDA SINGER (NYS Bar #2473403) 
Admitted Pro Hac Vice 
Motley Rice LLC 
401 9th Street NW, Suite 630 
Washington, DC 20004 
Tel: (202) 232-5504 
lsingerernotleyrice.com 
PAIGE BOGGS 
Admitted Pro Hac Vice 
Motley Rice LLC 
401 9th Street NW, Suite 630 
Washington, DC 20004 
Tel: (202) 386-9629 
[email protected] 
34 
EFTA00161869

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 1 of 77 
Exhibit 1 
to Government's Amended Complaint 
against JPMorgan Chase Bank, N.A. 
EFTA00161870

IN THE SUPERIOR COURT 
OF THE VIRGIN ISLANDS Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 2 of 77 
FILED 
Novertber 30, 2022 12:02 PH 
ST-2 02 0-CV-000 / 4 
TAMARA CHARLES 
CLERK OF WE COURT 
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS 
DIVISION OF ST. THOMAS AND ST. JOHN 
******************************** 
GOVERNMENT OF THE UNITED STATES 
VIRGIN ISLANDS, 
PLAINTIFF, 
V. 
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. 
Case No.: ST-20-CV-14 
ACTION FOR DAMAGES 
JURY TRIAL DEMANDED 
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 
I. 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 
EFTA00161871

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 3 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 2 of 76 
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. 
EFTA00161872

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 4 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 3 of 76 
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. 
II. 
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; 
EFTA00161873

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 5 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 4 of 76 
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. 
EFTA00161874

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 6 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 5 of 76 
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 
EFTA00161875