EFTA00162121

aaaffen222coataHm Catimuntent3E631 FRilifitiCCUM13123 FitageS6ccif 
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. 
EFTA00162341

dame11222auklilfaC91JESPR Camwireerlt3ffill FRIERti0CUMT,0233 Figagje9327ccI0TS3 
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, 
EFTA00162342

Claffirelnaaw-111111314BER Ilartaunreitt3E611 FfikeigLIMIZEB FREse933aff1233 
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. 
EFTA00162343

0affirellM2mAk13381(91JESPR Gamiuntent3ffill. 
FlzhgeN3cdf17Z3 
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. 
EFTA00162344

Gatmella2cau-DELIAMIR Ormatunient3E631 FRI liatiCCIEIME23 FRagEe933)aff17-2/3 
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. 
EFTA00162345

iThatellMove-MBIBITD3IR2 artmiuntentM 31 FRI ifdl0CIEIME23 RE/awe 931 at f 
GVI v. Estate of Jeffrey Epstein 
GVI'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. 
EFTA00162346

Offee11222coalitilEIR Camwrreent3ffill 
Rage952af 
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. 
EFTA00162347

Claasiell222mailiCSIdEBIR Camturrentt3ffill. 1Rf1$ti0]MTi1PZii Figajfe9Bcdt17Z3 
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. 
EFTA00162348

Glaffiella2a3m-MEDArlSIR firlimuneent3ffill FRiketiCCIEUM233 Fitaige9:91cdf2Z3 
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 after 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. 
EFTA00162349

alae81.122
102043SER CIDootmaati8Val. FlfileicIXDA/30123 Ft100400 of 723 
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 a seq. and 14 V.I.C. §§ 832-833 
371. 
The Government restates and realleges paragraphs 1 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 
EFTA00162350

Oafiell.122ektla02041SER Cl0otimeatithial. FifdEk0006B/33a123 Plaggethth of 123 
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). 
EFTA00162351

Casied.122
1002041SER Cl0onmentithial FifnEKON3/310723 Plagge3.02 of 123 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 66 of 76 
381. 
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-TWO 
Civil Conspiracy 
382. 
The Government restates and realleges paragraphs 1 to 381 of this Complaint as 
if fully set forth herein. 
383. 
Defendants acted in concert and joined with others to perform the wrongful acts 
identified in Counts 1 to 13, among others, concealing the sexual abuse of minor females by 
unlawful means. 
384. 
Each co-conspirator knew, or in the exercise of reasonable care should have 
known, about the conduct of the others and about the common unlawful scheme. 
385. 
These unlawful acts could not have been carried to the length and extent 
accomplished without the common understanding shared by Epstein and the Epstein Enterprise 
Defendants. 
386. 
Each of the Defendants had a duty to report, stop or terminate the wrongful 
conduct, but instead each Defendant concealed, assisted and furthered the wrongful acts by use 
of civil conspiracy. 
387. 
As a direct and proximate result of Defendants' conspiracy, the Virgin Island has 
been injured. 
388. 
Each co-conspirator is jointly and severally liable for the acts alleged herein. 
EFTA00162352

Oatied.122
100204ISSR Cesoormaati8thal FfideidAb11/310723 PEigge108 of /23 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 67 of 76 
COUNT TWENTY-THREE 
Fraudulent Claims Upon the Government—Southern Trust Company, Inc. 
Violation of the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. § 600 et seq. and 14 V.I.C. § 843 
389. 
The Government restates and realleges paragraphs 1 to 388 of this Complaint as 
if fully set forth herein. 
390. 
At all times relevant and material herein, each Defendant directly and indirectly 
participated in or associated with the Epstein Enterprise, an illicit enterprise. 
391. 
Each Defendant engaged in two or more occasions of conduct that constitute 
criminal predicate acts as defined by CICO, including, but not limited to, making fraudulent 
claims upon the Government. 
392. 
The Epstein Enterprise misrepresented the purpose, activities, employment, and 
income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax 
incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the 
Epstein Enterprise, with the active participation of Defendants Indyke and Kahn, used Southern 
Trust Company to employ, pay, and conceal the activities of participants in the criminal 
activities of the Enterprise. 
393. 
The Epstein Enterprise made and presented an application for tax incentives, 
testimony, and quarterly reports to the EDC, a commission of the Government, regarding the 
Southern Trust Company, knowing such claims to be false, fictitious, or fraudulent; knowingly 
and willfully falsified, concealed or covered up material facts regarding the Southern Trust 
Company; made false or fraudulent statements or representations about the purpose, activities, 
income, and employment of Southern Trust Company; and made and submitted false affidavits 
knowing the same to contain any fraudulent or fictitious statement or entry. 
EFTA00162353

CH8.88.2221-)240/0994132R CDooureeti8th611 FREKONIKE123 Plagge100 of 123 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 68 of 76 
394. 
These false statements and documents included affidavits, testimony, an 
application, and other documents that misrepresented that Southern Trust Company was 
engaged in, and failed to disclose it did not and could not carry out, in its stated purpose of 
providing consulting services in financial and biomedical informatics. 
395. 
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 underage girls and young 
women in knowing and reckless disregard of the laws of the Virgin Islands. 
396. 
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. 
397. 
Defendants benefited, directly and indirectly, from the pattern of criminal 
activity conducted by the Epstein Enterprise. 
398. 
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-FOUR 
Fraudulent Claims Upon the Government—Southern Trust Company, Inc. 
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 
14 VI.C. § 600 et seq. and 14 V.I.C. § 843 
399. 
The Government restates and realleges paragraphs 1 to 398 of this Complaint as 
if fully set forth herein. 
400. 
At all times material herein, each Defendant joined in a conspiracy to commit 
fraudulent conveyances. 
EFTA00162354

C€18.8€1.221-)2410099413ER CDouumetif3th611 FRIEKOOM/33CP33 Piaggel.a) of 123 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 69 of 76 
401. 
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 
entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder or delay claims 
against them. 
402. 
The Epstein Enterprise misrepresented the purpose, activities, employment, and 
income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax 
incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epstein 
Enterprise, with the active participation of Defendants Indyke and Kahn, used Southern Trust 
Company to employ, pay, and conceal the activities of participants in the criminal activities of 
the Enterprise. 
403. 
The Epstein Enterprise made and presented an application for tax incentives, 
testimony, and quarterly reports to the EDC, a commission of the Government, regarding the 
Southern Trust Company, knowing such claims to be false, fictitious, or fraudulent; knowingly 
and willfully falsified, concealed or covered up material facts regarding the Southern Trust 
Company; made false or fraudulent statements or representations about the purpose, activities, 
income, and employment of Southern Trust Company; and made and submitted false affidavits 
knowing the same to contain any fraudulent or fictitious statement or entry. 
404. 
These false statements and documents included affidavits, testimony, an 
application, and other documents that misrepresented that Southern Trust Company was 
engaged in, and failed to disclose it did not and could not carry out, in its stated purpose of 
providing consulting services in financial and biomedical informatics. 
405. 
Defendants knowingly benefited financially and/or obtained other non-financial 
value from participation in the Epstein Enterprise, which has engaged in human trafficking, 
EFTA00162355

OZIfiet112201100204ISSR Cl0ommati8IMEII. FRJEK0ffibl3/310723 PRggel0E6 of 123 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 70 of 76 
forced labor, sexual servitude, and commercial sexual activity of underage girls and young 
women in knowing and reckless disregard of the laws of the Virgin Islands. 
406. 
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). 
407. 
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-FIVE 
Fraudulent Claims Upon the Government—Cypress, Inc.; Maple, Inc.; Laurel, Inc. 
Violation of the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. §.§. 600 et seq. and 14 V.I.C. § 843 
408. 
The Government restates and realleges paragraphs 1 to 407 of this Complaint as if 
fully set forth herein. 
409. 
At all times relevant and material herein, each Defendant directly and indirectly 
participated in or associated with the Epstein Enterprise, an illicit enterprise. 
410. 
Each Defendant engaged in two or more occasions of conduct that constitute 
criminal predicate acts as defined by CICO, including but not limited to making fraudulent 
claims upon the Government. 
411. 
Defendants Cypress, Maple, and Laurel misrepresented the values of their assets 
held and expenses incurred in their annual reporting to the Government of the United States 
Virgin Islands for each of the tax years from 2011 to 2018. 
412. 
Defendant Cypress misrepresented the value of its assets held during each of these 
years by omitting the value of the 49 Zorro Ranch Road, Stanley, New Mexico property that it 
EFTA00162356

OBEit34.122
1002041SER C1000=30118Val FlideidDOMICE133 Plagge102 of 123 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 71 of 76 
acquired in or about December 2011, and misrepresented the value of its expenses incurred 
during each of these years by omitting the annual amounts of property taxes it paid for the New 
Mexico property. 
413. 
Defendant Maple misrepresented the value of its assets held during each of these 
years by omitting the value of the 9 East 71st Street, New York, New York property that it 
acquired in or about December 2011, and misrepresented the value of its expenses incurred 
during each of these years by omitting the annual amounts of property taxes it paid for the New 
York property. 
414. 
Defendant Laurel misrepresented the value of its assets held during each of these 
years by omitting the value of the 358 Brillo Way, Palm Beach, Florida property that it acquired 
in or about December 2011, and misrepresented the value of its expenses incurred during each of 
these years by omitting the annual amounts of property taxes it paid for the Palm Beach property. 
415. 
Epstein and Defendant/Co-Executor Kahn signed each of Cypress, Maple, and 
Laurel's annual reports for these years in which they represented that "ALL STATEMENTS 
CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE 
TRUE AND CORRECT . . . ." 
416. 
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. 
417. 
Defendants' knowingly and willfully made false representations to the 
Government regarding the assets and expenses of Cypress, Maple, and Laurel, and their conduct 
EFTA00162357

Ceae81.1224002134ISSR Cesoomeati8Val. FIRIddXMT30/23 Ragge108 of 723 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 72 of 76 
in failing to inform the Government of each company's true assets and expenses, constitute fraud 
upon the Government. 14 V.I.C. § 843. 
418. 
Defendants, through a pattern of criminal activity, acquired and maintained, 
directly or indirectly, an interest in or control of the Epstein Enterprise or of real property. 
419. 
Defendants benefitted directly and indirectly from the pattern of criminal activity 
conducted by the Epstein Enterprise. Defendants knowingly benefitted financially and/or 
obtained non-financial value from participation in the Epstein Enterprise, which has engaged in 
human trafficking, forced sexual servitude, and commercial sexual activity of underage girls and 
young women, in knowing and reckless disregard of the laws of the Virgin Islands. 
420. 
At all material times 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-SIX 
Fraudulent Claims Upon the Government—Cypress, Inc.; Maple, Inc.; Laurel, Inc. 
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. §§ 600 et seq. and 14 V.I.C. § 843 
421. 
The Government restates and realleges paragraphs 1 to 420 of this Complaint as if 
fully set forth herein. 
422. 
At all material times herein, each Defendant engaged in a conspiracy to commit 
fraudulent conveyances. 
423. 
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 
entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder, or delay claims 
against them. 
EFTA00162358

Oaat3E1122
1002043SER CDoninfintit36(al. Fifdtk00M11/310733 PiAggelOg of 123 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 73 of 76 
424. 
These false statements and documents included annual financial statements for the 
years 2011 to 2018 submitted by each Cypress, Maple, and Laurel to the Office of Lieutenant 
Governor of the Virgin Islands that misrepresented the value of the assets held and the amount of 
the expenses incurred by each company during each of these years. 
425. 
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. 
426. 
Defendants knowingly benefitted financially and/or obtained other non-financial 
value from their participation in the Epstein Enterprise, which has engaged in human trafficking, 
forced labor, sexual servitude, and commercial sexual activity of underage girls and young 
women, in knowing and reckless disregard of the laws of the Virgin Islands. 
Notice of Allegation of 
PUNITIVE DAMAGES 
427. 
The purpose of punitive damages in the common law is to punish the defendant 
for outrageous conduct that is reckless or intentional and to deter others from engaging in such 
conduct in the future. 
428. 
This Complaint describes intentional conduct so egregious, persistent, and 
injurious that it shocks the conscience and offends a civilized society. 
429. 
Punitive damages are especially important in the case of persons or companies 
that have so money, assets, and power that mere fines, penalties, and economic damages are 
simply not sufficient. 
EFTA00162359

OZ1fied.122ektla02043SERCOoutmsett86fi11 Fiftidc00a1/310733 Piaggelle of 123 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 74 of 76 
430. 
At all times material herein, Epstein and the Epstein Enterprise engaged 
repeatedly in wrongful acts which were intentional and outrageous. The Government gives 
notice that it intends to pursue the possibility of punitive damages in any jury verdict. 
PRAYER FOR RELIEF 
WHEREFORE, the Government respectfully requests that the Court: 
A. 
Enter a judgment in favor of the Government and against Defendants on all 
counts; 
B. 
Declare that Defendants, through the Epstein Enterprise, have engaged in a 
pattern of criminal activity in the Virgin Islands including but not limited to human trafficking, 
forced labor and sexual servitude of female children and young women, unlawful sexual contact, 
child sexual abuse, child abuse and neglect, rape, prostitution civil conspiracy and other offenses 
related offenses, and civil conspiracy; 
C. 
Pursuant to 14 V.I.C. § 610, enforce and maintain the criminal activity liens the 
Government is filing contemporaneously with this lawsuit, or shall file in connection with this 
action; 
D. 
Pursuant to 14 V.I.C. § 607(a)(1) and 14 V.I.C. § 141, issue an order forfeiting 
and divesting in favor of the Government of the Virgin Islands all of Defendants' interests in any 
real and personal property used to facilitate the criminal enterprise carried out by the Epstein 
Enterprise, including but not limited to Little St. James Island and Greater St. James Island; 
E. 
Issue an order forfeiting to the Government of the Virgin Islands any proceeds or 
funds obtained by Defendants, whether directly or indirectly, during the course of the criminal 
activity of the Epstein Enterprise; 
EFTA00162360