EFTA00162121

ekstliMacm-AMMU4dIS MmmummftaBR PkW0CUMMEM FizOmealbagh3 
GVI v. Estate of Jeffrey Epstein 
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. 
EFTA00162301

Game 
IniRem411MIT1BER Ilamlimmitt31:611 FFiltellirIVU3) 233 Filitiffe rat 
f103 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
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 
EFTA00162302

02ffitellMove-111MDAT1BIR2 flAnaurrentt3ffill FfillEdICBMIlleZ8 FILIttffeS33cdffS3 
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, 
EFTA00162303

GaimellMow-132HBOLD3IR DacawnientM31. FRikiti0CIEIME23 FiquffealkEUTS3 
GVI v. Estate of Jeffrey Epstein 
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. 
EFTA00162304

(aaselIMEare-BEIKIAT1HIR ElDicaunentt3E631 FRilititICCULTIE23 FRagEe53)oif17-2/3 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 19 of 76 
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. 
EFTA00162305

flaaffe11222coalJESPR flamwnentl3E631 FRISICCUMME23 FRagfe533.cdf2S3 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 20 of 76 
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. 
EFTA00162306

(C 
fl
 ElainturnrEent3E631 fltit$t10IME23 Fiquxe552affJ7273 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 21 of 76 
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." 
EFTA00162307

0ataie11222matailIR famwnient3ffill. FRitiEd10flUalk223 FittageSIEGJO7Z3 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 22 of 76 
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 
EFTA00162308

Claine11222coataaiR Camwrreent3ffill FRISMYLIIII33 FRitifre591af 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 23 of 76 
I IO. 
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 
EFTA00162309

aSelIZMOVOMME914/3IIR Eammtent3E631 FRIERtiCUYET1123 FRatijBEThaff103 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 24 of 76 
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 
EFTA00162310

Claaael1222coataBIR Catutwrreent3E631 
QEaJ12Z'3
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 25 of 76 
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. 
EFTA00162311

Eatommteitt3E6-11 FFiketaLY11312233 FREgeffilloff17.33 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 26 of 76 
123. 
The Epstein Enterprise's violation of the construction and environmental laws was 
part of a pattern of behavior in flouting the laws of the Virgin Islands and holding itself above the 
law. Upon information and belief, as described above, the Epstein Enterprise undertook 
construction at Great St. James after 2016 to continue the scheme to carry out and conceal his 
trafficking and sexual abuse of young women and children in the Virgin Islands. These actions 
are also indicative of the Epstein Enterprise's disregard for Virgin Islands' law. The Epstein 
Enterprise used the Virgin Islands' land, resources, people, and laws for its illicit purposes. 
Rather than participating lawfully in this community, the Epstein Enterprise took advantage of 
the secluded nature of the islands in furtherance of its crimes. 
124. 
As a result of its deplorable and unlawful conduct, the Epstein Enterprise has 
subjected the Virgin Islands to public portrayals as a hiding place for human trafficking and sex 
crimes. 
D. The "Epstein Enterprise" Fraudulently Concealed its Conduct 
125. 
The Epstein Enterprise fraudulently concealed its actions to prevent detection by 
the Government of the Virgin Islands. 
126. 
The secluded properties at Little St. James and Great St. James were repeatedly 
used by the Epstein Enterprise as the locations for unlawfully soliciting, transporting, 
transferring, harboring, receiving, providing, isolating, patronizing, maintaining, deceiving, 
coercing, and sexually abusing young women and children and concealing these crimes. 
127. 
The Epstein Enterprise was able to hide the trafficking ring from law 
enforcement, despite the fact that Epstein was a registered sex offender. Given the isolation of 
the Little St. James and Great St. James and the nature of the crimes and of the victims targeted 
by the Epstein Enterprise, the activities of the Epstein Enterprise were not readily detectable. 
EFTA00162312

028fielnazari-lThhalBER ORmiumeitt3E611. FFiltell0M131233 11111wEe6233cC7Z3 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 27 of 76 
Moreover, Epstein's great wealth and power likely made witnesses reluctant to report their 
observations to the local law enforcement. 
128. 
Upon information and belief, the Epstein Enterprise prevented its employees from 
cooperating with law enforcement. Employees and others were required to sign confidentiality 
agreements that prohibited them from speaking to or sharing information with law enforcement. 
If they were contacted by law enforcement they were to notify the Epstein Enterprise and be 
represented by Epstein's counsel. 
129. 
The employees were directed not to communicate or interact with guests visiting 
Little St. James and were also directed not to disclose to anyone events that occurred on the island. 
130. 
Monitoring a sex offender with his own private islands and the resources to fly 
victims in and out on private planes and helicopters presented unique challenges and allowed the 
Epstein Enterprise to limit scrutiny by the Government of the Virgin Islands. 
131. 
Sexual Offender Registration and Community Protection Act ("SORCPA") 14 
V.I.C. § 1721, et seq. requires sex offenders to register in their resident jurisdictions and to make 
periodic in-person appearances to verify and update their registration information. 
132. 
Epstein renewed his registration each year in the Virgin Islands. In addition, 
beyond this statutory requirement, the Virgin Islands periodically visited—or attempted to 
visit—Little St. James to conduct additional address verifications. 
133. 
At his last verification in July 2018, Epstein refused to permit Virgin Islands 
Department of Justice Investigators, assisted by United States Marshals, to enter Little St. James 
beyond its dock, claiming that the dock was his "front door." Instead, Epstein arranged to be met 
at his office on St. Thomas. 
EFTA00162313

Clasie11222com-IBMWEBIR Catintuntent3ffill Ft
-KM/MEM FitatifeE2i9ccIOTS3 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 28 of 76 
134. 
Epstein also misled the Government regarding his travel plans. On March 19, 2019, 
the Virgin Islands was notified that Epstein would be traveling to France for 10 days on the private 
plane owned by Plan D, LLC. His notification form did not disclose travel to any other countries. It 
was later found by law enforcement authorities that Epstein also travelled to Vienna and Monaco 
during that trip. 
135. 
Similarly, the Epstein Enterprise sought to prevent DPNR from conducting 
routine site visits to inspect unpermitted and potentially damaging construction activity on Great 
St. James. The Epstein Enterprise repeatedly objected to DPNR's inspections referring to them as 
"invasions" of Epstein's constitutional right to privacy in his home, which he described defined 
as the entire island. These DPNR inspections are required for all construction and Virgin Islands 
residents are required to cooperate with the inspections to assure compliance with the law 
throughout the construction phases. 
136. 
These efforts represent Epstein Enterprise's intent to conceal its unlawful activity 
on Little St. James and Great St. James. 
137. 
The Epstein Enterprise also created numerous corporations and limited liability 
companies in the Virgin Islands to help conceal its unlawful activity. Most of these companies were 
created in 2011 and 2012, soon after Epstein registered as a sex offender in the Virgin Islands. 
138. 
Epstein's pilot, Larry Visoski is identified as member or co-member in companies 
that serviced and maintained the planes that the Epstein Enterprise used to traffick young women 
and children — Freedom Air Petroleum, LLC (registered November 28, 2011 to hold assets); 
and JEGE, LLC (registered October 19, 2012 to hold assets). 
EFTA00162314

0C1t
 fiRonurreent3ffia FFitiati01121233 FirtajjBER0alf1/28 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 29 of 76 
139. 
Other Epstein entities include LSJ Employees, LLC (registered October 27, 2011 
to provide services); Southern Financial, LLC (registered February 25, 2013 to provide services) 
and LSJ Emergency, LLC (registered December 2, 2015 to provide services). 
140. 
Some of these companies held considerable assets: Financial Informatics, Inc. 
(incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of 
approximately $391 million in 2015; and Financial Trust Company, Inc. (incorporated November 
6, 1998) had assets of $212 million when it publicly filed its last balance sheet in 2012. 
141. 
Though often absent in the original incorporation or registration documents or 
annual filings, Epstein ultimately appeared as president, director, manager, or sole member of 
each of these companies. Upon information and belief, the purpose of this complex array of 
corporate entities-some of which may still be discovered—was to allow Epstein to shelter his 
assets in order to fund, carry out, and conceal his identity and pattern of criminal conduct. 
142. 
The Estate continues to engage in a course of conduct aimed at concealing the 
criminal activities of the Epstein Enterprise. On November 24, 2019, Epstein's Estate filed an 
Expedited Motion for Establishment of a Voluntary Claims Resolution Program in the Superior 
Court of the Virgin Islands. ("Motion"). According to the Motion, the proposed program was to 
be designed to "establish an independent and voluntary claims resolution program for purposes 
of resolving sexual abuse claims against Jeffrey E. Epstein." (Motion, at 1). 
143. 
The program proposed by the Estate, whose executors are trustees of The 1953 
Trust and officers in at least two Epstein entities, imposes confidentiality requirements and 
requires any claimant accepting an award under the program to sacrifice any other claims against 
"any person or entity arising from or related to Mr. Epstein's conduct." (Motion, at 5). It acts to 
EFTA00162315

ClamelnazareallInhalliER Ilamtunreitt3E6-11 FFikeilalltd31W33 FREseffiadf1233 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 30 of 76 
conceal the criminal activities of the Epstein Enterprise and shield its participants from liability 
and accountability for the injury they caused to the victims. 
144. 
The Estate also refused to agree to preserve documents or to release individuals 
from the non-disclosure agreements. 
145. 
Two days before his death, Epstein amended The Trust and his Last Will and 
Testament. Upon information and belief, he did so, as part of a pattern and ongoing effort to 
conceal and shield his assets from potential recovery by claimants. 
E. The "Epstein Enterprise" Violated Numerous Virgin Islands Laws 
146. 
The pattern of criminal activity engaged in by Epstein and other participants in 
the Epstein Enterprise violated 14 V.I.C. §§ 605 and 607 of the Criminally Influenced and 
Corrupt Organizations Act ("CICO"). 
147. 
The Epstein Enterprise also violated Title 14, Chapter 3A, The Virgin Islands 
Uniform Prevention of and Remedies for Human Trafficking Act relating to Trafficking of 
Persons; Title 14, Chapter 24, relating to Child Protection and Child Abuse and Neglect; Title 
14, Chapter 81, relating to Prostitution and Related Offenses; Title 18, Chapter 85, relating to 
Rape and Sexual Assault and other related offenses, as well as other Virgin Islands laws. 
148. 
The Epstein Enterprise violated Virgin Islands laws by engaging in the human 
trafficking of underage girls and young women and commercial sex with young women and 
underage girls by force, fraud, enticement, or coercion, which serve as predicates to the Epstein 
Enterprise's violations of CICO. 
149. 
Certain participants who recruited women and underage girls to be trafficked 
and forced into sexual servitude themselves were sexually trafficked and abused by the Epstein 
Enterprise and may be afforded the protections of 14 V.I.C. § 145. 
EFTA00162316

One IlMow-MIBEILD3IR DEEC0lunient3E631 FRI Si TIMM [Rage Mai f 17Z/3 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 31 of 76 
150. 
Specifically, Plan D, LLC knowingly and intentionally facilitated the 
trafficking scheme by flying underage girls and young women into the Virgin Islands to be 
delivered into sexual servitude. Plan D LLC repeatedly made flights from the mainland to 
St. Thomas with Epstein and underage girls and young women for the purpose of engaging 
in sexual activity on Little St. James. On some occasions, they would transport Epstein 
and female children by helicopter to Little St. James. On other occasions, Epstein and the 
young women and girls would be transported by boat. 
151. 
Great St. Jim, LLC and Nautilus, Inc. knowingly participated in the Epstein 
Enterprise and facilitated the trafficking and sexual servitude of young women and underage 
girls by providing the secluded properties at, from, or to which Epstein and his associates were 
able to transport, transfer, receive, maintain, isolate, harbor, provide, entice, deceive, coerce, 
and sexually abuse underage girls and young women. 
152. 
The Epstein Enterprise engaged in a continuing course of unlawful conduct. 
153. 
After Epstein's suicide, the Epstein Enterprise continued to exist as each of the 
participants continued to conspire to prevent detection of the breadth and scope of the Epstein 
Enterprise's criminal wrongdoing and to prevent accountability. These conspiratorial acts are 
ongoing. 
154. 
The conduct of the Epstein Enterprise offends the core purpose of the Virgin 
Islands Uniform Prevention of and Remedies for Human Trafficking Act, 14 V.I.C. §131 et seq, 
and violates CICO, enacted to "curtail criminal activity and lessen its economic and political 
power in the Territory of the Virgin Islands by establishing new penal prohibitions and 
providing to law enforcement and the victims of criminal activity new civil sanctions and 
remedies." 14 V.I.C. § 601. 
EFTA00162317

aaage 11 MROW-DIMMIT1HIR IEtcraurreartt3ffill. Ff1ifl$t10]YQl3;02i FRagEe6aBcdf17-2/3 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 32 of 76 
155. 
The Epstein Enterprise is an illicit enterprise within the meaning of 14 V.I.C. §§ 
604 and 605. 
156. 
The Government is entitled to recover civil penalties, damages and other 
remedies and to extinguish and recoup from the Epstein Enterprise and its participants any and 
all financial and other benefits, and any personal and real property that was used during the 
course of, or intended for use in the Course of the conduct or criminal activity in violation of the 
laws of the Virgin Islands. The Government is entitled to obtain through divestiture, forfeiture, 
or other equitable relief all properties and instrumentalities used by the Epstein Enterprise in the 
criminal pattern of trafficking and sexual abuse in the Virgin Islands, including but not limited 
to Great St. James and Little St. James, and all other remedies and penalties permitted by law in 
the interest of justice. 
F. The Epstein Enterprise Used Corporate Entities to Defraud the Government 
and Fund its Criminal Activities 
1. Defendant Southern Trust Company, Inc. 
157. 
In October 2012, the Southern Trust Company applied for economic benefits 
from the Economic Development Commission ("EDC"). The EDC is a subsidiary of the Virgin 
Islands Economic Development Authority ("EDA"), a semi-autonomous governmental 
instrumentality created and governed pursuant to 29 VIC § 1101. 
158. 
In sworn testimony at a public hearing on the tax incentive application 
conducted by the EDC on November 15, 2012, Epstein and his attorney, Ericka Kellerhals, 
described Southern Trust Company as providing "cutting edge consulting services" in the area 
of "biomedical and financial informatics." 
EFTA00162318

GaffivelnaawillfinIT1BER Elamiumeitt3E6-11 FFiltellilln3/1233 FILIageSlaf 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 33 of 76 
159. 
The EDC granted Southern Trust Company a 10-year package of economic 
incentives running from February 1, 2013 until January 31, 2023 that included a 90% 
exemption from income taxes and 100% exemptions from gross receipts, excise, and 
withholding taxes in the Virgin Islands. 
160. 
Between 2013 and 2019, Southern Trust Company employed 13 different 
individuals (not including Epstein). Of those 13 individuals, 11 served in administrative or 
support roles: six as personal, administrative, or executive assistants, receptionists, or as a 
driver/helper, one as an office manager, one as a clerk, and three in accounting or payroll 
functions (though only one was licensed as a certified public accountant). There was one 
network administrator/IT manager, and a second who was added in 2019. 
161. 
In fact, several of those individuals seemed to perform other personal services 
for Jeffrey Epstein. Though he was reported by Southern Trust Company to be resident of the 
Virgin Islands, the network administrator/IT manager was issued a Florida driver's license, 
which listed an address in Miami. Further, he appears, in fact, to have served as Epstein's driver 
and picked up luggage and cargo from Epstein's private planes on his behalf. 
162. 
Another executive assistant lived at 301 E. 66th Street, Apartment I I B, New 
York, New York. Epstein's address book lists various units in this building as providing "Apt. 
for models" and she is publicly identified as a model. As noted above, the Epstein Enterprise 
used modeling opportunities and contracts as a pretext for recruiting underage girls and young 
women into its sex trafficking scheme. 
163. 
Financial records more recently obtained show that the employee described 
above whom Kahn represented to be, alternatively, 
was also a 
EFTA00162319

GamellMew-IBTA3:4-JESPR Camwritent3ffill FRiliat1CCUMME23 Fitaige715cd072/3 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 34 of 76 
which did not actually or even pretend to perform 
either 
in 2019. 
164. 
During several time periods, Southern Trust Company affirmed to EDC that it 
had no employees who were non-residents, even though it employed non-residents. 
165. 
Southern Trust company does not appear to have had any clients and performed 
no visible informatics services. According to financial records, it held no investments for others. 
Instead, its employees performed tasks related to any number of other Epstein-owned companies 
or properties, such as Little St. James. 
166. 
Despite having no visible clients and only one full-time employee working on 
information technology during the bulk of the period, Southern Trust Company reportedly 
generated net income of $50.3 million in 2013, $67.5 million in 2014, $52.8 million in 2015, and 
$4.8 million in 2016 and $17.1 million in 2017, with aggregate income of $117.8 million in 2014, 
$170.6 million in 2015, $175.3 million in 2016 and $192.4 million in 2017, or aggregate income 
for the period of $656 million. 
167. 
Money received by Southern Trust was then funneled, frequently by Defendant 
Indyke as authorized signatory, and often with copies given to Defendant Kahn, through other 
Epstein-owned entities and accounts, funding payments to foreign women and for credit cards, 
airplanes, and other instrumentalities of the Epstein Enterprise. 
168. 
In fact, the main source of funds for the Epstein Enterprise came from Southern 
Trust. Between 2013 and 2017, Southern Trust reported approximately $184 million in 
revenues. 
169. 
Defendants Kahn and Indyke directed and controlled the day-to-day activities of 
Southern Trust in form and in substance, serving as members of its Board of Directors, along 
EFTA00162320