EFTA00161836

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 47 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 46 of 76 
240. 
At all times material herein, each Defendant conspired with Epstein and other 
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, 
forced labor, and sexual servitude. 14 V.I.C. §604(j). 
241. 
At all times material herein, Defendants engaged in said pattern of criminal 
activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation 
of CICO. 14 V.I.C. §600 et seq. 
COUNT FIVE 
Human Trafficking — Sexual Servitude 
Violation of the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. § 600 et seq. and 14 V.I.0 § 135 
242. 
The Government restates and realleges paragraphs I to 241 of this Complaint as 
if fully set forth herein. 
243. 
At all times material herein, each Defendant directly and indirectly participated 
in or associated with the Epstein Enterprise, an illicit enterprise. 
244. 
The Epstein Enterprise engaged in two or more occasions of conduct that 
constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly 
maintaining or making available minors for the purpose of engaging the minors in commercial 
sexual activities or using coercion or deception to force young women to engage in commercial 
sexual activity in violation of 14 V.I.C. § 135. 
245. 
On the pretext of providing modeling opportunities, careers and contracts, 
Defendants facilitated the transporting or recruiting of young women and girls or lured and 
recruited young women and underage girls to travel to the Virgin Islands where they engaged in 
sexual acts with Epstein and others. In some instances, young women and underage girls were 
EFTA00161916

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 48 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 47 of 76 
given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts 
with Epstein and others. 
246. 
Defendants through a pattern of criminal activity directly and indirectly 
participated in or associated with the Epstein Enterprise, an illicit enterprise. 
247. 
Defendants through a pattern of criminal activity acquired and maintained, 
directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 
248. 
Defendants benefited, directly and indirectly, from the pattern of criminal 
activity conducted by the Epstein Enterprise. 
249. 
At all times material herein, Defendants engaged in said pattern of criminal 
activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation 
of CICO. 14 V.I.C. §600 et seq. 
COUNT SIX 
Human Trafficking — Sexual Servitude 
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. § 600 et seq. and 14 V.I.0 § 135 
250. 
The Government restates and realleges paragraphs 1 to 249 of this Complaint as 
if fully set forth herein. 
251. 
At all times material herein, each Defendant joined in a conspiracy to violate 
laws prohibiting human trafficking. 
252. 
Each Defendant engaged in acts that revealed its intent to join the criminal 
conspiracy by knowingly maintaining or making available minors for the purpose of engaging 
the minors in commercial sexual activities or using coercion or deception to force young women 
to engage in commercial sexual activity in violation of 14 V.I.C. § 135. 
EFTA00161917

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 49 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 48 of 76 
253. 
On the pretext of providing modeling opportunities, careers and contracts, 
Defendants facilitated the transporting or recruiting of young women and girls or lured and 
recruited young women and underage girls to travel to the Virgin Islands where they engaged in 
sexual acts with Epstein and others. In some instances, young women and underage girls were 
given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts 
with Epstein and others. 
254. 
Defendants knowingly benefited financially and/or obtained other non-financial 
value from participation in the Epstein Enterprise, which has engaged in human trafficking, 
forced labor, sexual servitude and commercial sexual activity of girls and young women in 
knowing or reckless disregard of the laws of the Virgin Islands. 
255. 
At all times material herein, each Defendant conspired with Epstein and other 
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, 
forced labor, and sexual servitude. 14 V.I.C. §6040. 
256. 
At all times material herein, Defendants engaged in said pattern of criminal 
activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation 
of CICO. 14 V.I.C. §600 et seq. 
COUNT SEVEN 
Human Trafficking — Patronizing Minors and Victims of Sexual Servitude 
Violation of the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. § 600 et seq. and 14 V.I.0 §§ 136-37 
257. 
The Government restates and realleges paragraphs I to 256 of this Complaint as 
if fully set forth herein. 
258. 
At all times material herein, each Defendant directly and indirectly participated 
in or associated with the Epstein Enterprise, an illicit enterprise. 
EFTA00161918

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 50 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 49 of 76 
259. 
The Epstein Enterprise engaged in two or more occasions of conduct that 
constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly 
giving, agreeing to give, or offering to give items of value to young women and minors so that 
the young women and minors would engage in commercial sexual activity with Epstein, other 
Defendants, and other individuals in violation of 14 V.I.C. §§ 136-137. 
260. 
In some instances, young women and underage girls were given scholarships, 
money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and 
others. 
261. 
Defendants through a pattern of criminal activity directly and indirectly 
participated in or associated with the Epstein Enterprise, an illicit enterprise. 
262. 
Defendants through a pattern of criminal activity acquired and maintained, 
directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 
263. 
Defendants benefited, directly and indirectly, from the pattern of criminal 
activity conducted by the Epstein Enterprise. 
264. 
At all times material herein, Defendants engaged in said pattern of criminal 
activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation 
of CICO 14 V.I.C. §600 et seq. 
COUNT EIGHT 
Human Trafficking— Patronizing Minors and Victims of Sexual Servitude 
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 
14 
§ 600 et seq. and 14 V.I.0 H 136-37 
265. 
The Government restates and realleges paragraphs 1 to 264 of this Complaint as 
if fully set forth herein 
EFTA00161919

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 51 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 50 of 76 
266. 
At all times material herein, each Defendant joined in a conspiracy to violate 
laws prohibiting human trafficking. 
267. 
Each Defendant engaged in acts that revealed its intent to join and participate in 
the criminal conspiracy by knowingly giving, agreeing to give, or offering to give items of value 
to young women and minors so that the young women and minors would engage in commercial 
sexual activity with Epstein, other Defendants, and other individuals in violation of 14 V.I.C. §§ 
136-137. 
268. 
In some instances, young women and underage girls were given scholarships, 
money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and 
others. 
269. 
Defendants knowingly benefited financially and/or obtained other non-financial 
value from participation in the Epstein Enterprise, which has engaged in human trafficking, 
forced labor, sexual servitude and commercial sexual activity of girls and young women in 
knowing or reckless disregard of the laws of the Virgin Islands. 
270. 
At all times material herein, each Defendant conspired with Epstein and other 
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, 
forced labor, and sexual servitude. 
271. 
At all times material herein, Defendants engaged in said pattern of criminal 
activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation 
of CICO 14 V.I.C. §600 et seq. 
EFTA00161920

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 52 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 51 of 76 
COUNT NINE 
Child Abuse and Neglect—All Defendants Except Darren K. Indyke and Richard D. Kahn 
in Their Individual Capacities 
Violation of the Criminally Influenced and Corrupt Organization Act, 
14 V.I.C. § 600 et seq. and 14 V.I.0 §§ 505, 506 and 507 
272. 
The Government restates and realleges paragraphs 1 to 271 of this Complaint as 
if as if fully set forth herein. 
273. 
At all times material herein, each Defendant directly and indirectly participated 
in or associated with the Epstein Enterprise, an illicit enterprise. 
274. 
The Epstein Enterprise engaged in two or more occasions of conduct that 
constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly 
or recklessly causing a child to suffer physical, mental or emotional injury, or knowingly or 
recklessly causing a child to be placed in a situation where it is reasonably foreseeable that such 
child may suffer physical, mental or emotional injury, in violation Virgin Islands criminal laws 
prohibiting Child Abuse and Neglect in Title 14 V.I.C. § 500 et. seq. 
275. 
As a result of the Epstein Enterprise's actions numerous young girls suffered 
serious physical, mental and emotional injury. 
276. 
Defendants through a pattern of criminal activity acquired and maintained, 
directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 
277. 
Defendants benefited, directly and indirectly, from the pattern of criminal 
activity conducted by the Epstein Enterprise. 
278. 
At all times material herein, Defendants engaged in a pattern of criminal activity 
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of 
CICO. 14 V.I.C. §600 et seq. 
EFTA00161921

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 53 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 52 of 76 
COUNT TEN 
Child Abuse and Neglect 
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act 
—All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual 
Capacities, 
14 V.I.C. § 600 et seq. and 14 V.I.0 §§ 505, 506 and 507 
279. 
The Government restates and realleges paragraphs I to 278 of this Complaint as 
if as if fully set forth herein. 
280. 
At all times material herein, each Defendant joined in a conspiracy to violate 
laws prohibiting child abuse and neglect. 
281. 
Each Defendant engaged in acts that revealed its intent to join and participate in the 
criminal conspiracy as they knowingly or recklessly caused a child to suffer physical, mental or 
emotional injury, or knowingly or recklessly caused a child to be placed in a situation where it is 
reasonably foreseeable that such child may suffer physical, mental or emotional injury, in violation 
Virgin Islands criminal laws prohibiting Child Abuse and Neglect in Tide 14 V.I.C. § 500 et seq. 
282. 
As a result of Defendants' actions, numerous young girls suffered serious 
physical, mental and emotional injury. 
283. 
Defendants knowingly benefited financially and/or obtained other non-financial 
value from participation in the Epstein Enterprise, which has engaged in human trafficking, 
forced labor, sexual servitude and commercial sexual activity of girls and young women in 
knowing or reckless disregard of the laws of the Virgin Islands. 
284. 
At all times material herein, each Defendant conspired with Epstein and other 
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, 
forced labor, and sexual servitude. 14 V.I.C. §604(j). 
EFTA00161922

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 54 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 53 of 76 
285. 
At all times material herein, Defendants engaged in a pattern of criminal activity 
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of 
CICO. 14 V.I.C. §600 et seq. 
COUNT ELEVEN 
Aggravated Rape—All Defendants Except Darren K. Indyke and Richard D. Kahn in 
Their Individual Capacities 
Violation of the Criminally Influenced and Corrupt Organization Act, 
14 V.I.C. § 600 et seq. and 14 V.I.0 § 1700a 
286. 
The Government restates and realleges paragraphs 1 to 285 of this Complaint as 
if fully set forth herein. 
287. 
At all times material herein, each Defendant directly and indirectly participated 
in or associated with the Epstein Enterprise, an illicit enterprise. 
288. 
The Epstein Enterprise engaged in two or more occasions of conduct that 
constitute criminal predicate acts as defined by CICO, including, but not limited to, conduct that 
constituted or facilitated the rape of minors by force, intimidation, or the perpetrator's position 
of authority over the victim. 
289. 
Epstein and others, using force or intimidation, engaged in sexual intercourse 
with underage girls without their consent in violation of 14 V.I.C. § 1700a. 
290. 
As a result of the Epstein Enterprise's actions, numerous underage girls suffered 
serious physical, mental and emotional injury. 
291. 
Defendants through a pattern of criminal activity acquired and maintained, 
directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 
292. 
Defendants benefited, directly and indirectly, from the pattern of criminal 
activity conducted by the Epstein Enterprise. 
EFTA00161923

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 55 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 54 of 76 
293. 
At all times material herein, Defendants engaged in a pattern of criminal activity 
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of 
CICO. 14 V.I.C. §600 et seq. 
COUNT TWELVE 
Aggravated Rape 
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 
—All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual 
Capacities, 
14 V.I.C. § 600 et seq. and 14 V.I.0 § 1700a 
294. 
The Government restates and realleges paragraphs I to 293 of this Complaint as 
if fully set forth herein. 
295. 
At all times material herein, each Defendant joined in a conspiracy to violate 
laws prohibiting aggravated rape. 
296. 
Each Defendant engaged in acts that revealed its intent to join and participate in 
the criminal conspiracy by engaging in conduct that constituted or facilitated the rape of minors 
by force, intimidation, or the perpetrator's position of authority over the victim. 
297. 
Epstein and others, using force or intimidation, engaged in sexual intercourse 
with underage girls without their consent in violation of 14 V.I.C. § I700a. 
298. 
As a result of Defendants' actions, numerous underage girls suffered serious 
physical, mental and emotional injury 
299. 
Defendants knowingly benefited financially and/or obtained other non-financial 
value from participation in the Epstein Enterprise, which has engaged in human trafficking, 
forced labor, sexual servitude and commercial sexual activity of girls and young women in 
knowing or reckless disregard of the laws of the Virgin Islands. 
EFTA00161924

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 56 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 55 of 76 
300. 
At all times material herein, each Defendant conspired with Epstein and other 
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, 
forced labor, and sexual servitude. 14 V.I.C. §604(j). 
301. 
At all times material herein, Defendants engaged in a pattern of criminal activity 
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of 
CICO. 14 V.I.C. §600 et seq. 
COUNT THIRTEEN 
Rape in the Second Degree—All Defendants Except Darren K. Indyke and Richard D. 
Kahn in Their Individual Capacities 
Violation of the Criminally Influenced and Corrupt Organization Act, 
14 V.I.C. § 600 et seq. and 14 V.I.0 § 1702 
14 V.I.C. § 600 et seq. and 14 V.I.0 § 1700a 
302. 
The Government restates and realleges paragraphs 1 to 301 of this Complaint as 
if fully set forth herein. 
303. 
At all times material herein, each Defendant directly and indirectly participated 
in or associated with the Epstein Enterprise, an illicit enterprise. 
304. 
The Epstein Enterprise engaged in two or more occasions of conduct that 
constitute criminal predicate acts as defined by CICO, including, but not limited to, conduct that 
constituted or facilitated the rape of girls under 18 years of age. 
305. 
Epstein and others who engaged in rape were over 18 years old at the time of the 
incidents. 
306. 
As a result of the Epstein Enterprise's actions, numerous minors suffered serious 
physical, mental and emotional injury. 
307. 
Defendants through a pattern of criminal activity acquired and maintained, 
directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 
EFTA00161925

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 57 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 56 of 76 
308. 
Defendants benefited, directly and indirectly. from the pattern of criminal 
activity conducted by the Epstein Enterprise. 
309. 
At all times material herein, Defendants engaged in a pattern of criminal activity 
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of 
CICO. 14 V.I.C. §600 et seq. 
COUNT FOURTEEN 
Rape in the Second Degree 
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 
—All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual 
Capacities, 
14 V.I.C. § 600 et seq. and 14 V.I.0 § 1702 
310. 
The Government restates and realleges paragraphs I to 309 of this Complaint as 
if fully set forth herein. 
311. 
At all times material herein, each Defendant joined in a conspiracy to violate 
laws prohibiting rape in the second degree. 
312. 
Each Defendant engaged in acts that revealed its intent to join and participate in 
the criminal conspiracy by engaging in conduct that constituted or facilitated the rape of girls 
under 18 years of age. 
313. 
Epstein and others who engaged in rape were over 18 years old at the time of the 
incidents. 
314. 
As a result of Defendants' actions, numerous minors suffered serious physical, 
mental and emotional injury. 
315. 
Defendants knowingly benefited financially and/or obtained other non-financial 
value from participation in the Epstein Enterprise, which has engaged in human trafficking, 
EFTA00161926

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 58 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 57 of 76 
forced labor, sexual servitude and commercial sexual activity of girls and young women in 
knowing or reckless disregard of the laws of the Virgin Islands. 
316. 
At all times material herein, each Defendant conspired with Epstein and other 
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, 
forced labor, and sexual servitude. 14 V.I.C. §604(j). 
317. 
At all times material herein, Defendants engaged in a pattern of criminal activity 
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of 
CICO. 14 V.I.C. §600 et seq. 
COUNT FIFTEEN 
Unlawful Sexual Contact in the First or Second Degree—All Defendants Except Darren K. 
Indyke and Richard D. Kahn in Their Individual Capacities 
Violation of the Criminally Influenced and Corrupt Organization Act, 
14 V.I.C. § 600 et seq. and 14 V.I.0 §§ 1708 and 1709 
318. 
The Government restates and realleges paragraphs 1 to 317 of this Complaint as 
if as if fully set forth herein. 
319. 
At all times material herein, each Defendant directly and indirectly participated 
in or associated with the Epstein Enterprise, an illicit enterprise. 
320. 
The Epstein Enterprise engaged in two or more occasions of conduct that 
constitute criminal predicate acts as defined by CICO, including, but not limited to, using or 
facilitating the use of force or coercion to accomplish sexual contact or engaging in sexual 
contact with a minor between 13 and 16 years of age. 
321. 
Epstein and others who engaged in the sexual contact were over 18 years old at 
the time of the incidents. 
322. 
As a result of the Epstein Enterprise's actions numerous young women and 
minors suffered serious physical, mental and emotional injury. 
EFTA00161927

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 59 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 58 of 76 
323. 
Defendants through a pattern of criminal activity acquired and maintained, 
directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 
324. 
Defendants benefited, directly and indirectly, from the pattern of criminal 
activity conducted by the Epstein Enterprise. 
325. 
At all times material herein, Defendants engaged in a pattern of criminal activity 
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 
14 V.I.C. §600 et seq. 
COUNT SIXTEEN 
Unlawful Sexual Contact in the First or Second Degree 
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act 
—All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual 
Capacities, 
14 V.I.C. § 600 et seq. and 14 V.I.0 §.§. 1708 and 1709 
326. 
The Government restates and realleges paragraphs I to 325 of this Complaint as 
if as if fully set forth herein. 
327. 
At all times material herein, each Defendant joined in a conspiracy to violate 
laws prohibiting unlawful sexual contact. 
328. 
Each Defendant engaged in acts that revealed its intent to join and participate in 
the criminal conspiracy by using or facilitating the use of force or coercion to accomplish sexual 
contact or engaging in sexual contact with a minor between 13 and 16 years of age. 
329. 
Epstein and others who engaged in the sexual contact were over 18 years old at 
the time of the incidents. 
330. 
As a result of Defendants' actions, numerous young women and minors suffered 
serious physical, mental and emotional injury. 
EFTA00161928

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 60 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 59 of 76 
331. 
Defendants knowingly benefited financially and/or obtained other non-financial 
value from participation in the Epstein Enterprise, which has engaged in human trafficking, 
forced labor, sexual servitude and commercial sexual activity of girls and young women in 
knowing or reckless disregard of the laws of the Virgin Islands. 
332. 
At all times material herein, each Defendant conspired with Epstein and other 
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, 
forced labor, and sexual servitude. 14 V.I.C. §6040. 
333. 
At all times material herein, Defendants engaged in a pattern of criminal activity 
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 
14 V.I.C. §600 et seq. 
COUNT SEVENTEEN 
Prostitution and Keeping House of Prostitution 
Violation of the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. § 600 et seq. and 14 V.I.C. §§ 1622, 1624 
334. 
The Government restates and realleges paragraphs 1 to 333 of this Complaint as 
if fully set forth herein. 
335. 
At all times material herein, each Defendant directly and indirectly participated 
in or associated with the Epstein Enterprise, an illicit enterprise. 
336. 
The Epstein Enterprise engaged in two or more occasions of conduct that 
constitute criminal predicate acts as defined by CICO, including the engaging in or facilitating 
the knowing and/or reckless abuse of minors through the acts alleged herein. 
337. 
The Epstein Enterprise knowingly persuaded, induced, enticed, and/or coerced 
women and children to travel to the Virgin Islands to engage in prostitution and/or sexual 
activity, and/or attempted to do the same. 
EFTA00161929

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 61 of 77 
GVI v. Estate of Jeffrey Epstein 
GV1's Second Amended Complaint 
Page 60 of 76 
338. 
The Epstein Enterprise kept, maintained, and/or permitted his property at Little 
St. James to be used for the purpose of prostitution, lewdness or assignation with knowledge or 
reasonable cause to know the same. 
339. 
The Epstein Enterprise received or offered or agreed to receive women and 
children at his property at Little St. James for the purposes of prostitution, lewdness or 
assignation, and/or permitted women and children to remain there for such purposes. 
340. 
The Epstein Enterprise directed, took, transported, and or offered or agreed to 
take or transport women and children to Little St. James with the knowledge or reasonable cause 
to know that the purpose of such directing, taking or transporting was prostitution, lewdness or 
assignation. 
341. 
The Epstein Enterprise knew or should reasonably have known that individuals 
that were the subjects of the actions described in this Count were minors. 
342. 
As a result of Defendants' actions, numerous young women and minors suffered 
serious physical, mental and emotional injury. 
343. 
Defendants through a pattern of criminal activity acquired and maintained, 
directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 
344. 
Defendants benefited, directly and indirectly, from the pattern of criminal 
activity conducted by the Epstein Enterprise. 
345. 
At all times material herein, Defendants engaged in a pattern of criminal activity 
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of 
CICO. 14 V.I.C. §600 et seq. 
EFTA00161930

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 62 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 61 of 76 
COUNT EIGHTEEN 
Prostitution and Keeping House of Prostitution 
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. § 600 et seq. and 14 V.I.C. §§ 1622, 1624. 
346. 
The Government restated and realleges paragraph 1 to 345 of this Complaint as 
if fully set forth herein. 
347. 
At all times material herein, each Defendant joined a conspiracy to laws against 
prostitution. 
348. 
Each Defendant engaged in acts that revealed its intent to join and participate in the 
criminal conspiracy by engaging in or facilitating the persuasion, inducement, enticement or 
coercion of women and children to travel to the Virgin Islands to engage in prostitution and/or 
sexual activity, and/or attempted to do the same; keeping, maintaining, and/or permitting Epstein's 
property at Little St. James, to be used for the purpose of prostitution, lewdness or assignation with 
knowledge or reasonable cause to know the same; receiving, offering, or agreeing to receive 
individuals at his property at Little St. James for the purposes of prostitution, lewdness or 
assignation, and/or permitted women and children to remain there for such purposes; and directing, 
taking, transporting, and/or offering or agreeing to take or transport women and children to Little 
St. James with the knowledge or reasonable cause to know that the purpose of such directing, 
taking or transporting was prostitution, lewdness or assignation, in violation of 14 V.I.C. §§ 
1622 and 1624. 
349. 
Defendants knew or should reasonably have known that individuals that were 
the subjects of the actions described in this Count were minors. 
350. 
As a result of Defendants' actions numerous young women and minors suffered 
serious physical, mental and emotional injury. 
EFTA00161931

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 63 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 62 of 76 
351. 
Defendants knowingly benefited financially and/or obtained other non-financial 
value from participation in the Epstein Enterprise, which has engaged in human trafficking, 
forced labor, sexual servitude and commercial sexual activity of girls and young women in 
knowing or reckless disregard of the laws of the Virgin Islands 
352. 
At all times material herein, each Defendant conspired with Epstein and other 
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, 
forced labor, and sexual servitude. 14 V.I.C. §604(j). 
353. 
At all times material herein, Defendants engaged in a pattern of criminal activity 
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 
14 V.I.C. §600 et seq. 
COUNT NINETEEN 
Sex Offender Registry-Estate of Jeffrey E. Epstein 
Violation of the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. § 600 a seq. and 14 V.I.C. § 1721 et seq. 
354. 
The Government restates and realleges paragraphs 1 to 353 of this Complaint as 
if fully set forth herein. 
355. 
Epstein was required to, and did, register under the Virgin Islands Sexual 
Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 
et seq. 
356. 
SORCPA requires that offenders required to register provide information 
relating to intended travel in foreign commerce. 
357. 
On at least two occasions, Epstein traveled to Vienna and Monaco without 
disclosing that travel to the Virgin Islands sex offender registry. 
EFTA00161932

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 64 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 63 of 76 
358. 
Epstein's failure to disclose this travel before, during, or even alter his travel was 
knowing. 
359. 
Epstein's violation SORPCA was part of a pattern of criminal activity that was 
not isolated but was related to the affairs of the Epstein Enterprise. 14 V.LC. §604(j). 
COUNT TWENTY 
Fraudulent Conveyance 
Violation of the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. § 600 a seq. and 14 V.I.C. ft 832-833 
360. 
The Government restates and realleges paragraphs 1 to 359 of this Complaint as 
if fully set forth herein. 
361. 
At all times material herein, each Defendant directly and indirectly participated 
in or associated with the Epstein Enterprise, an illicit enterprise. 
362. 
Each Defendant engaged in two or more occasions of conduct that constitute 
criminal predicate acts as defined by CICO, including, but not limited to transferring assets to 
and between various entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, 
hinder or delay claims against them. 
363. 
Upon information and belief, in an effort to defeat the claims of creditors and 
avoid the oversight of the court probating his estate, Epstein, days before his death, transferred 
significant assets, including assets held by other Defendants, into The 1953 Trust. 
364. 
At the time of these transfers, Epstein had numerous actions pending against 
him related to his trafficking and sexual assaults seeking financial judgments. 
365. 
Through these transfers, Epstein and the Epstein Enterprise fraudulently 
removed property and effects beyond the jurisdiction of the probate court. 
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GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 64 of 76 
366. 
Epstein and the Epstein Enterprise were parties to the fraudulent conveyance of 
the property, real or personal, and/or the interests or rights arising out of property, contracts, or 
conveyances of Epstein and the Epstein Enterprise. 
367. 
Epstein and the Epstein Enterprise acted with the intent to defeat, hinder, or 
delay creditors and claimants, including the Government of the Virgin Islands, in collecting on 
their judgements, debts and demands 
368. 
Defendants through a pattern of criminal activity acquired and maintained, 
directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 
369. 
Defendants benefited, directly and indirectly, from the pattern of criminal 
activity conducted by the Epstein Enterprise. 
370. 
At all times material herein, Defendants engaged in a pattern of criminal activity 
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of 
CICO. 14 V.I.C. §600 et seq. 
COUNT TWENTY-ONE 
Fraudulent Conveyance 
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. § 600 et seq. and 14 V.I.C. §§ 832-833 
371. 
The Government restates and realleges paragraphs I to 370 of this Complaint as 
if fully set forth herein. 
372. 
At all times material herein, each Defendant joined in a conspiracy to commit 
fraudulent conveyances. 
373. 
Each Defendant engaged in acts that revealed its intent to join and participate in 
the criminal conspiracy, including, but not limited to, transferring assets to and between various 
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GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 65 of 76 
entities controlled by Epstein and the Epstein Enterprise to avoid. defeat. hinder or delay claims 
against them. 
374. 
Upon information and belief, in an effort to defeat the claims of creditors and 
avoid the oversight of the court probating his estate, Epstein, days before his death, transferred 
significant assets, including assets held by other Defendants, into The 1953 Trust. 
375. 
At the time of this transfer, Epstein had numerous actions pending against him 
related to his trafficking and sexual assaults seeking financial judgments. 
376. 
Through this transfer, Epstein and the Epstein Enterprise fraudulently removed 
property and effects beyond the jurisdiction of the probate court. 
377. 
Epstein and the Epstein Enterprise were parties to the fraudulent conveyance of 
the property, real or personal, and/or the interests or rights arising out of property, contracts, or 
conveyances of Epstein and the Epstein Enterprise. 
378. 
Epstein and the Epstein Enterprise acted with the intent to defeat, hinder, or 
delay the Government of the Virgin Islands and other creditors and claimants to collect on their 
judgements, debts and demands. 
379. 
Defendants knowingly benefited financially and/or obtained other non-financial 
value from participation in the Epstein Enterprise, which has engaged in human trafficking, 
forced labor, sexual servitude and commercial sexual activity of girls and young women in 
knowing or reckless disregard of the laws of the Virgin Islands. 
380. 
At all times material herein, each Defendant conspired with Epstein and other 
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking. 
forced labor, and sexual servitude. 14 V.I.C. §604(j). 
EFTA00161935