EFTA00162121

OffilellMovi-DIEIRT1HIR fikozurreent3(611. FRI kitiOCIEIMME Figtige/36ailVZ'3
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 35 of 76 
with Epstein. Indyke was a signatory on Southern Trust's primary bank account to which funds 
were wired, primarily from a single source, as described below. Kahn, as Southern Trust's 
treasurer, oversaw its accounting, invoicing, and tax reporting. Indyke also authorized a 
majority of the wire transfers from Southern Trust's bank account in order to fund the various 
entities and personal bank accounts of Epstein, and had full inquiry capabilities over the 
account. 
170. 
Bank records show that virtually all of Southern Trust Company's income came 
from a single source (including related entities). 
171. 
In all, the single source paid $158 million to Defendant Southern Trust Company 
from 2013 to 2017, which constitutes 85% of the total revenues reported by Southern Trust 
Company. These funds appear to have not been used to pay for informatics or datamining 
services. 
172. 
These payments to Southern Trust were the main source of funds for Epstein's 
Enterprise. Indeed, no other entity in Epstein's Enterprise generated revenues. Funds received 
from the single source were funneled, at the direction of Kahn and Indyke, to Epstein's personal 
accounts, and other Epstein entities to fund his criminal activities. 
173. 
For the period between January 1, 2013 and December 31, 2017, Southern Trust 
Company received tax exemptions totaling $73.6 million. 
174. 
As of December 31, 2017, Southern Trust Company, Inc. elected to file its 
income tax as an S-corporation, which elects to pass corporate income, losses, deductions and 
credits through to its sole shareholder—Jeffrey Epstein—for tax purposes. For this time period, 
Epstein's income tax exemption was $71.3 million. 
EFTA00162321

GamelnazatillIMITIBIR Elltouunreant3(611. FRIEutiCEILIME23 Figage 1.9_/ at= 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 36 of 76 
175. 
Including gross receipt taxes, the Government currently estimates that, as a 
result of the EDC incentive, Epstein was able to avoid paying $80,576,236 in taxes. 
176. 
Based upon these facts, it is clear that Southern Trust Company did not perform 
the "informatics" business represented to the EDC and could not have generated the business 
income attributable to that business. Instead, upon information and belief, Southern Trust 
Company existed to secure tax benefits for Epstein, to employ individuals associated with the 
Epstein Enterprise, and to provide a source of income to support his criminal activities and 
properties in the Virgin Islands. 
2. 
Defendants Cypress, Inc.; Maple, Inc.; and Laurel, Inc. 
177. 
Epstein formed Cypress, Inc.; Maple, Inc.; and Laurel, Inc. as Virgin Islands 
corporations in or about November 2011. 
178. 
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 each of Cypress, Inc.; Maple, Inc.; and Laurel, Inc. 
179. 
Defendant Cypress, Inc. acquired ownership of the property 49 Zone Ranch 
Road in Stanley, New Mexico in or about December 2011, shortly after Cypress was formed. 
180. 
Defendant Maple, Inc. acquired ownership of the property 9 East 71st Street in 
New York, New York on or about December 23, 2011, shortly after Maple was formed. Maple 
acquired ownership of the property from Nine East 71st Street Corporation, which was owned by 
Epstein. 
181. 
Defendant Laurel, Inc. acquired ownership of the property 358 Brillo Way in 
Palm Beach, Florida in or about December 2011, shortly after Cyrpess was formed. Laurel 
acquired ownership of the property from Epstein personally. 
EFTA00162322

daelnazati-lThh1BER fiamiumetttafill FFilleildraB1233 Flgaffe fatal/2/3 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 37 of 76 
182. 
Epstein appears to have maintained divided ownership of these properties, 
transferred ownership of them to the Virgin Islands, and then concealed this fact even from 
Virgin Islands authorities in an attempt to shield the properties from any judgment in the states 
where they are located. 
183. 
The financial statements submitted by each of these three Defendant corporations 
to the Office of Lieutenant Governor of the Virgin Islands were false and misleading due to their 
failure to include the above properties owned by each company or the related expenses incurred 
by each company, such as property taxes. 
184. 
For instance, Cypress's Balance Sheet as of December 31, 2018 did not reflect 
any assets other than cash of $18,824. Further, Cypress reported only $301 in expenses for the 
year ended December 31, 2018, despite it paying 
185. 
Similarly, in 2017, Cypress reported as its only asset cash in the amount of 
$29,736 and expenses of $150, despite it paying 
186. 
Similarly, for the tax years 2011 through 2016, Cypress did not include the value 
of the New Mexico property in the total assets it reported and did not include any expenses 
related to the New Mexico property in the total expenses it reported to the Government. 
187. 
Likewise, Maple's balance sheet as of December 31, 2018 did not reflect any 
assets other than cash of $21,265. Further, Maple reported only $300 in expenses for the year 
ended December 31, 2018, despite it paying 
EFTA00162323

Clame11222coat-JESPR GDicaurrient3C631 FRISICCULIQUEB FRige /SIRE WM 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 38 of 76 
188. 
Similarly, in 2017, Maple reported as its only asset cash in the amount of 
$18,281 and expenses of $150, despite it paying 
189. 
Similarly, for the tax years 2011 through 2016, Maple did not include the value 
of the New York property in the total assets it reported and did not include any expenses related 
to the New York property in the total expenses it reported to the Government. 
190. 
Likewise, Laurel's balance sheet as of December 31, 2018 did not reflect any 
assets other than cash in the amount of $20,155. Further, Laurel reported only $300 in expenses 
for the year ended December 31, 2018, despite it paying 
191. 
Similarly, in 2017, Laurel reported as its only asset cash in the amount of 
$37,129 and expenses of $150, despite it paying 
192. 
Similarly, for the tax years 2011 through 2016, Laurel did not include the value 
of the Palm Beach property in the total assets it reported and did not include any expenses related 
to the Palm Beach property in the total expenses it reported to the Government. 
193. 
Neither Cypress's, Maple's, nor Laurel's financial statements ever reflected the 
reality of the above assets held or the above expenses incurred by each entity. 
194. 
The Annual Reports submitted on behalf of Cypress, Maple, and Laurel all were 
signed by Epstein and Defendant and Co-Executor Kahn with the representation that "ALL 
STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING 
DOCUMENTS, ARE TRUE AND CORRECT . . ." 
EFTA00162324

ftaffelnalow-1114:1134r1HIR ftElmtunterft3ffill. FRISKUILB/233 FILlaffe7f0cdffr3 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 39 of 76 
195. 
In fact, Indyke and Kahn knew or should have known that their attestations were 
false. Upon information and belief, particularly given the absence of any other justification for 
these transactions and the fraudulent nature of their reporting, these transactions were made for 
the sole purpose of sheltering these assets from collection. 
STATUTES OF LIMITATIONS ARE TOLLED AND DEFENDANTS ARE ESTOPPED 
FROM ASSERTING STATUTES OF LIMITATIONS AS DEFENSES 
1. 
Equitable Estoppel and Fraudulent Concealment 
196. 
Defendants are equitably estopped from relying upon a statute of limitations 
defense for conduct that occurred prior to the limitation period because they undertook active 
efforts to deceive the Government and to purposefully conceal their unlawful conduct and 
fraudulently assure public authorities that their conduct was in compliance with the laws, all with 
the goal of avoiding punishment. 
197. 
Defendants were deliberate in taking steps to conceal their criminal sex 
trafficking and abuse conduct and their fraudulent conduct in obtaining unearned tax benefits 
from the Government. Defendants' acts of concealment include, but are not limited to, the 
following. 
198. 
Defendants used Epstein's secluded island of Little St. James and his later 
purchase of the nearby island of Great St. James to shield their trafficking and sexual abuse of 
young women and female children from detection by law enforcement authorities and to prevent 
their victims from escaping. 
199. 
Defendants used Epstein's private aircraft to transport young women and female 
children to the Virgin Islands and to Little St. James while limiting public observation of this 
trafficking activity. 
EFTA00162325

One 
11Z120ualISITD3IR ElErnwrreent3ffill. FRiliatUDYL135233 
7fiaif3733
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 40 of 76 
200. 
Defendants used Epstein's businesses and ostensibly charitable foundations in 
the Virgin Islands to make payments to the victims who were trafficked and sexually abused 
while concealing these payments from detection by law enforcement authorities. 
201. 
Defendants also prevented Epstein Enterprise entity employees from cooperating 
with law enforcement by requiring them to sign confidentiality and non-disclosure agreements. 
202. 
Defendants also actively obstructed law enforcement by denying investigators 
access to Little St. James beyond its boat dock. 
203. 
204. 
205. 
206. 
Defendants also concealed their fraud on the Government in obtaining unearned 
tax benefits by providing false testimony and submitting false and inaccurate reporting to the 
Economic Development Commission to prevent detection of Defendant Southern Trust 
Company's non-compliance with requirements concerning the nature of its business and the 
residency of the persons it employed. 
207. 
The discovery of the nature, scope, and magnitude of Defendants' unlawful 
conduct and could not have been acquired earlier through the exercise of reasonable diligence. 
EFTA00162326

(C
 11222 coadeR 
0ltmwment3E631 FRIERtiCICULTIE23 Fitage 7672 af f J7273 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 41 of 76 
2. 
Continuing Violations 
208. 
The continuous criminal conduct by the Defendants has caused repeated and 
continuous injury. 
209. 
Defendants criminal trafficking and sexual abuse of young women and female 
children in the Virgin Islands occurred continuously from Epstein's purchase of Little St. James 
in 1998 through his arrest and death in prison in 2019. 
210. 
Flight logs and other sources establish that between 2001 and 2019, Defendants 
transported young women and female children to the Virgin Islands, where they were then 
transported by private helicopter or boat to Little St. James. 
211. 
Air traffic controllers and airport personnel have reported seeing, as recently as 
2018, Epstein leaving his private jet with young girls who appeared to be between the ages of 11 
and 18 years. 
212. 
One victim was brought by Defendants more than 50 times between 2000 and 
2002, when she was around 18 to 20 years old, to Little St. James, where she was required to 
have sexual relations with Epstein or his guests multiple times per day and where she saw large 
numbers of other young women and female children subject to the same treatment. 
213. 
Another victim was brought by Defendants dozens of times between 2004 and 
2017 to Little St. James, where she too observed a succession of young women and female 
children who likewise were transported to the island and were required to have sexual relations 
with Epstein and his guests. 
214. 
Defendants' fraud on the Government in obtaining unearned tax benefits through 
Defendant Southern Trust Company likewise was continuous inasmuch as Southern Trust's 
failure to perform the informatics services that it represented to the Economic Development 
EFTA00162327

GamtellMew-MglallER Caorwment3E631 FRIERMILIIIIE23 FRagEe74Baff17S3 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 42 of 76 
Commission and its false reporting of the residency and job descriptions of its employees were 
continuous from the start of the tax benefits in 2013 through Epstein's arrest and death in prison 
in 2019. 
215. 
The continued criminal conduct by Defendants has caused repeated and 
continuous injury. The criminal conduct of the Epstein Enterprise was not completed nor were 
all damages incurred until the wrongdoing ceased. 
COUNT ONE 
Human Trafficking — Trafficking an Individual 
Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"), 
14 V.I.C. § 600 et seq. and 14 V.I.0 § 133 
216. 
The Government restates and realleges paragraphs 1 to 215 of this Complaint as 
if fully set forth herein. 
217. 
At all times material herein, each Defendant directly and indirectly participated 
in or associated with the Epstein Enterprise, an illicit enterprise. 
218. 
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 
recruiting, transporting, transferring, harboring, receiving, providing, obtaining, isolating, 
maintaining, or enticing female children and young women in the furtherance and performance 
of forced labor, sexual servitude and commercial sexual activity in violation of Virgin Islands 
laws codified in 14 V.I.C. §§ 133-138. 
219. 
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. 
220. 
Defendants benefited, directly and indirectly, from the pattern of criminal 
activity conducted by the Epstein Enterprise. 
EFTA00162328

ClamelIML2carkiilffiffilJESPR Camwritent3ffill FRIERti0CILIME23 FigtgEe74)1cdUTZ3 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 43 of 76 
221. 
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 TWO 
Human Trafficking — Trafficking an Individual 
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. § 600 et seq. and 14 V.I.0 § 133 
222. 
The Government restates and realleges paragraphs 1 to 221 of this Complaint as 
if fully set forth herein. 
223. 
At all times material herein, each Defendant joined in a conspiracy to violate 
laws prohibiting human trafficking. 
224. 
Each Defendant engaged in acts that revealed its intent to join and participate in 
the criminal conspiracy by recruiting, transporting, transferring, harboring, receiving, providing, 
obtaining, isolating, maintaining or enticing female children and young women in the 
furtherance and performance of forced labor, sexual servitude and commercial sexual activity in 
violation of Virgin Islands laws codified in 14 V.I.C. § 133 -138. 
225. 
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. 
226. 
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). 
EFTA00162329

ClatmellM2mAiffiglaJESPR Camwrreent3E631 FRIEEW0CILI13123 FRatifeethccf 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 44 of 76 
227. 
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 THREE 
Human Trafficking — Forced Labor 
Violation of the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. § 600 et seq. and 14 V.I.0 § 134 
228. 
The Government restates and realleges paragraphs 1 to 227 of this Complaint as 
if fully set forth herein. 
229. 
At all times material herein, each Defendant directly and indirectly participated 
in or associated with the Epstein Enterprise, an illicit enterprise. 
230. 
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 
using coercion to compel underage girls and young women to provide labor or services by 
forced labor in violation of 14 V.I.C. § 134. 
231. 
The Epstein Enterprise knowingly provided or obtained the labor services of 
individuals by means of force, threats of force, physical restraint, and/or threats of physical 
restraint; by means of serious harm or threats of serious harm; by means of abuse or threatened 
abuse of law or legal processes; and by means of the Epstein Enterprise with the intent to cause 
individuals to believe that, if individuals did not perform such labor or services, individuals 
would suffer serious harm or physical restraint. 
232. 
Defendants through a pattern of criminal activity directly and indirectly 
participated in or associated with the Epstein Enterprise, an illicit enterprise. 
EFTA00162330

datEarellMierall134rD3IR Dielument3E631 FRilliti0CIEUXE23 Figalre8tEcdf17Z3 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 45 of 76 
233. 
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. 
234. 
Defendants benefited, directly and indirectly, from the pattern of criminal 
activity conducted by the Epstein Enterprise. 
235. 
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 FOUR 
Human Trafficking — Forced Labor 
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. § 600 et seq. and 14 V.I.0 § 134 
236. 
The Government restates and realleges paragraphs 1 to 235 of this Complaint as 
if fully set forth herein. 
237. 
At all times material herein, each Defendant joined in a conspiracy to violate 
laws prohibiting human trafficking. 
238. 
Each Defendant engaged in acts that revealed its intent to join and participate in 
the criminal conspiracy by knowingly using coercion to compel underage girls and young 
women to provide labor or services by forced labor in violation of 14 V.I.C. § 134. 
239. 
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. 
EFTA00162331

Claine11222com-lilltagidEZPR aitmwment3E631 FRISICEIMII123 Rage8127aff17Z3 
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 1 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 
EFTA00162332

Clasie11222coataBIR 0ltunurreent3ffill FRIEROCIUME23 FRage8133ccIUTS3 
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. 
EFTA00162333

Oatemilalow-11MISITD3IR Mmunweitt3E6-31 MastiffLt41312233 Ramp 8:11)ccf 
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. 
EFTA00162334

flanife11222coal-JESPR Camwrrentt3ffia FRIEntiOCULLIM3 Flzhge8:10cdfJ7273 
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 Ad, 
14 
§ 600 et seq. and 14 V.I.0 §§ 136-37 
265. 
The Government restates and realleges paragraphs 1 to 264 of this Complaint as 
if fully set forth herein 
EFTA00162335

One IlMow-DMEIDATD3IR Dacaturreartl3ffia FRikt10CIEIB;023 Rage 8331 
Fa 
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. 
EFTA00162336

ClamellMew-MEIC91,1EZPR Caurtruneent3E631 FRitiftin/1135123 
872cdf I/2/3 
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. 
EFTA00162337

dateifell222coatJESPR Camwrientt3E631 FRil$t10IMI1123 Fitagfe£(630[1072/3 
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). 
EFTA00162338

CkmellMmAAMHMAJEOR MmummmtaBil PkWffliMMEM WOmeaglegh3 
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. 
EFTA00162339

ClaffiellMew-MglaThiPR 0ltinwnient3E631 FRISICICIMIE23 Fitage915a1072/3 
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. § 1700a. 
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. 
EFTA00162340