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GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 6 of 76 
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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GVI's Second Amended Complaint 
Page 7 of 76 
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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GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 8 of 76 
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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GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 9 of 76 
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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GVI's Second Amended Complaint 
Page 10 of 76 
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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GVI's Second Amended Complaint 
Page 11 of 76 
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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Page 12 of 76 
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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GVI's Second Amended Complaint 
Page 13 of 76 
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. DefendanUCo-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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GVI's Second Amended Complaint 
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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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GVI's Second Amended Complaint 
Page 15 of 76 
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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Page 16 of 76 
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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GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 17 of 76 
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 
; FT Real Estate Inc.; Gratitude America, 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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GVI's Second Amended Complaint 
Page 18 of 76 
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.
85. 
Between September 2015 and June 2019, Indyke 
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 
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. 
is a New York Limited Liability Company, the Articles of 
Organization of which were filed in November 2014. The Articles list 
who was forced and 
coerced to have sex with Epstein, 
. 
was manipulated, 
exploited, and controlled by the Epstein Enterprise. 
91. 
According to 
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 
bank accounts. 
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92. 
One of 
bank accounts was funded entirely with money transferred from 
Epstein's personal bank accounts. 
93. 
payroll was paid to two persons, one of whom was the listed sole owner. 
Kahn gave conflicting reports to 
bank about the second person on the company's payroll 
and the reasons for its payments to her. Once, he described her as an 
, which 
would justify the payments in light of 
purported line of business, but which appears to 
have been false. The other time, Kahn described this payroll recipient 
which would 
not justify 
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 
between November 2016 and July 2019 (just before 
Epstein's arrest) to 
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110. 
From another of Epstein's personal accounts with another different bank, for 
which 
someone acting on Epstein's behalf made a total of In 
III. 
Payments from this account totaling almost 
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 
to Defendant/Co-Executor Indyke, and over 
to Defendant/Co-Executor 
Kahn. This includes 
on records obtained so far, 
Based 
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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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