EFTA00162121

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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 "pit is unlawful 
for any person to engage in unfair methods of competition . . . in the conduct of any trade or 
commerce." 
30 
EFTA00162281

C 
:22-Ikextafil1,1114-3BR Deianiart(143. MEd 0111112/23 Page 32 aff ain 
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(b), 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 
EFTA00162282

C Esesd :22-Iked.-Clga9114-3BR DecanmenInta43. PIS M11/52/23 II:paw 323 di M3 
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 
EFTA00162283

CG sese. 22-IkelagaBIMGBR Deaacureffinlaa PIES 01/52/23 
Mt di 123 
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 1. 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 
EFTA00162284

Cayese. 22-Ike\l-CEDEGMSBR Deaactunn136.41 PDS 011/52/23 
Staff M3 
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 
[email protected] 
PAIGE BOGGS 
Admitted Pro Hac Vice 
Motley Rice LLC 
401 9th Street NW, Suite 630 
Washington, DC 20004 
Tel: (202) 386-9629 
pbog,[email protected] 
34 
EFTA00162285

Uteed.122
,AIM090413•SIR MoomuenB(6611 Faildc0(01123n23 P
b
iiigg€8 of T23 
Exhibit 1 
to Government's Amended Complaint 
against JPMorgan Chase Bank, N.A. 
EFTA00162286

IS THESUPERIORCOURT 
OFTHEAIRGINISLANDSCflaseL122
1240)O9O433SR COoomeen8f6611 EFfithelaD0M721223 PaggeS2 of 123 
FILED 
Novertber 30, 2022 12:02 PP/ 
ST-2020-CV-00014 
TAMARA CHARLES 
CLERK OF THE 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 
EFTA00162287

Oaaeell.1221-uNLI001041SSIR COoomeatiBf6611 FE EIWEInf223 PaggeS8 of 123 
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. 
EFTA00162288

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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; 
EFTA00162289

CflaseL222VEGB091941SSF2 Dtionomati86(11 Flitildc001/1/30123 Rigger10 of 123 
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. 
EFTA00162290

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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 
EFTA00162291

CflaseL222 1MOD0194138:2 Geoorm3ati8011. Flitildd)01/1/30/23 Pligge12 of 123 
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 v. Estate of Jeffrey Epstein 
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 
EFTA00162293

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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 
EFTA00162294

akmellMmAAMHMAdEBIR Mmmffrentta641 PkWCW/MDEM WOmelDWO722 
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. 
EFTA00162295

(
fl Zazao-lThIT1BER Ellituaunrattt3E611. FFiltatIMIMB FRzsge48.affSra 
GVI v. Estate of Jeffrey Epstein 
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 
EFTA00162296

Casellalow-111EDIITD3IR EIRlimmtent3E6-11 RatestIGELYIBIZEB 11 
4721
GVI v. Estate of Jeffrey Epstein 
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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GVI's Second Amended Complaint 
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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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. Defendant/Co-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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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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