EFTA00161836

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 27 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 26 of 76 
123. 
The Epstein Enterprise's violation of the construction and environmental laws was 
part of a pattern of behavior in flouting the laws of the Virgin Islands and holding itself above the 
law. Upon information and belief, as described above, the Epstein Enterprise undertook 
construction at Great St. James after 2016 to continue the scheme to carry out and conceal his 
trafficking and sexual abuse of young women and children in the Virgin Islands. These actions 
are also indicative of the Epstein Enterprise's disregard for Virgin Islands' law. The Epstein 
Enterprise used the Virgin Islands' land, resources, people, and laws for its illicit purposes. 
Rather than participating lawfully in this community, the Epstein Enterprise took advantage of 
the secluded nature of the islands in furtherance of its crimes. 
124. 
As a result of its deplorable and unlawful conduct, the Epstein Enterprise has 
subjected the Virgin Islands to public portrayals as a hiding place for human trafficking and sex 
crimes. 
D. The "Epstein Enterprise" Fraudulently Concealed its Conduct 
125. 
The Epstein Enterprise fraudulently concealed its actions to prevent detection by 
the Government of the Virgin Islands. 
126. 
The secluded properties at Little St. James and Great St. James were repeatedly 
used by the Epstein Enterprise as the locations for unlawfully soliciting, transporting, 
transferring, harboring, receiving, providing, isolating, patronizing, maintaining, deceiving, 
coercing, and sexually abusing young women and children and concealing these crimes. 
127. 
The Epstein Enterprise was able to hide the trafficking ring from law 
enforcement, despite the fact that Epstein was a registered sex offender. Given the isolation of 
the Little St. James and Great St. James and the nature of the crimes and of the victims targeted 
by the Epstein Enterprise, the activities of the Epstein Enterprise were not readily detectable. 
EFTA00161896

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 28 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 27 of 76 
Moreover, Epstein's great wealth and power likely made witnesses reluctant to report their 
observations to the local law enforcement. 
128. 
Upon information and belief, the Epstein Enterprise prevented its employees from 
cooperating with law enforcement. Employees and others were required to sign confidentiality 
agreements that prohibited them from speaking to or sharing information with law enforcement. 
If they were contacted by law enforcement they were to notify the Epstein Enterprise and be 
represented by Epstein's counsel. 
129. 
The employees were directed not to communicate or interact with guests visiting 
Little St. James and were also directed not to disclose to anyone events that occurred on the island. 
130. 
Monitoring a sex offender with his own private islands and the resources to fly 
victims in and out on private planes and helicopters presented unique challenges and allowed the 
Epstein Enterprise to limit scrutiny by the Government of the Virgin Islands. 
131. 
Sexual Offender Registration and Community Protection Act ("SORCPA") 14 
V.I.C. § 1721, et seq. requires sex offenders to register in their resident jurisdictions and to make 
periodic in-person appearances to verify and update their registration information. 
132. 
Epstein renewed his registration each year in the Virgin Islands. In addition, 
beyond this statutory requirement, the Virgin Islands periodically visited—or attempted to 
visit—Little St. James to conduct additional address verifications. 
133. 
At his last verification in July 2018, Epstein refused to permit Virgin Islands 
Department of Justice Investigators, assisted by United States Marshals, to enter Little St. James 
beyond its dock, claiming that the dock was his "front door." Instead, Epstein arranged to be met 
at his office on St. Thomas. 
EFTA00161897

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 29 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 28 of 76 
134. 
Epstein also misled the Government regarding his travel plans. On March 19, 2019, 
the Virgin Islands was notified that Epstein would be traveling to France for 10 days on the private 
plane owned by Plan D, LLC. His notification form did not disclose travel to any other countries. It 
was later found by law enforcement authorities that Epstein also travelled to Vienna and Monaco 
during that trip. 
135. 
Similarly, the Epstein Enterprise sought to prevent DPNR from conducting 
routine site visits to inspect unpermitted and potentially damaging construction activity on Great 
St. James. The Epstein Enterprise repeatedly objected to DPNR's inspections referring to them as 
"invasions" of Epstein's constitutional right to privacy in his home, which he described defined 
as the entire island. These DPNR inspections are required for all construction and Virgin Islands 
residents are required to cooperate with the inspections to assure compliance with the law 
throughout the construction phases. 
136. 
These efforts represent Epstein Enterprise's intent to conceal its unlawful activity 
on Little St. James and Great St. James. 
137. 
The Epstein Enterprise also created numerous corporations and limited liability 
companies in the Virgin Islands to help conceal its unlawful activity. Most of these companies were 
created in 2011 and 2012, soon after Epstein registered as a sex offender in the Virgin Islands. 
138. 
Epstein's pilot, Larry Visoski is identified as member or co-member in companies 
that serviced and maintained the planes that the Epstein Enterprise used to traffick young women 
and children — Freedom Air Petroleum, LLC (registered November 28, 2011 to hold assets); 
and JEGE, LLC (registered October 19, 2012 to hold assets). 
EFTA00161898

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 30 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 29 of 76 
139. 
Other Epstein entities include LSJ Employees, LLC (registered October 27, 2011 
to provide services); Southern Financial, LLC (registered February 25, 2013 to provide services) 
and LSJ Emergency, LLC (registered December 2, 2015 to provide services). 
140. 
Some of these companies held considerable assets: Financial Informatics, Inc. 
(incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of 
approximately $391 million in 2015; and Financial Trust Company, Inc. (incorporated November 
6, 1998) had assets of $212 million when it publicly filed its last balance sheet in 2012. 
141. 
Though often absent in the original incorporation or registration documents or 
annual filings, Epstein ultimately appeared as president, director, manager, or sole member of 
each of these companies. Upon information and belief, the purpose of this complex array of 
corporate entities-some of which may still be discovered—was to allow Epstein to shelter his 
assets in order to fund, carry out, and conceal his identity and pattern of criminal conduct. 
142. 
The Estate continues to engage in a course of conduct aimed at concealing the 
criminal activities of the Epstein Enterprise. On November 24, 2019, Epstein's Estate filed an 
Expedited Motion for Establishment of a Voluntary Claims Resolution Program in the Superior 
Court of the Virgin Islands. ("Motion"). According to the Motion, the proposed program was to 
be designed to "establish an independent and voluntary claims resolution program for purposes 
of resolving sexual abuse claims against Jeffrey E. Epstein." (Motion, at 1). 
143. 
The program proposed by the Estate, whose executors are trustees of The 1953 
Trust and officers in at least two Epstein entities, imposes confidentiality requirements and 
requires any claimant accepting an award under the program to sacrifice any other claims against 
"any person or entity arising from or related to Mr. Epstein's conduct." (Motion, at 5). It acts to 
EFTA00161899

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 31 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 30 of 76 
conceal the criminal activities of the Epstein Enterprise and shield its participants from liability 
and accountability for the injury they caused to the victims. 
144. 
The Estate also refused to agree to preserve documents or to release individuals 
from the non-disclosure agreements. 
145. 
Two days before his death, Epstein amended The Trust and his Last Will and 
Testament. Upon information and belief, he did so, as part of a pattern and ongoing effort to 
conceal and shield his assets from potential recovery by claimants. 
E. The "Epstein Enterprise" Violated Numerous Virgin Islands Laws 
146. 
The pattern of criminal activity engaged in by Epstein and other participants in 
the Epstein Enterprise violated 14 V.I.C. §§ 605 and 607 of the Criminally Influenced and 
Corrupt Organizations Act ("CICO"). 
147. 
The Epstein Enterprise also violated Title 14, Chapter 3A, The Virgin Islands 
Uniform Prevention of and Remedies for Human Trafficking Act relating to Trafficking of 
Persons; Title 14, Chapter 24, relating to Child Protection and Child Abuse and Neglect; Title 
14, Chapter 81, relating to Prostitution and Related Offenses; Title 18, Chapter 85, relating to 
Rape and Sexual Assault and other related offenses, as well as other Virgin Islands laws. 
148. 
The Epstein Enterprise violated Virgin Islands laws by engaging in the human 
trafficking of underage girls and young women and commercial sex with young women and 
underage girls by force, fraud, enticement, or coercion, which serve as predicates to the Epstein 
Enterprise's violations of CICO. 
149. 
Certain participants who recruited women and underage girls to be trafficked 
and forced into sexual servitude themselves were sexually trafficked and abused by the Epstein 
Enterprise and may be afforded the protections of 14 V.I.C. § 145. 
EFTA00161900

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 32 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 31 of 76 
150. 
Specifically, Plan D, LLC knowingly and intentionally facilitated the 
trafficking scheme by flying underage girls and young women into the Virgin Islands to be 
delivered into sexual servitude. Plan D LLC repeatedly made flights from the mainland to 
St. Thomas with Epstein and underage girls and young women for the purpose of engaging 
in sexual activity on Little St. James. On some occasions, they would transport Epstein 
and female children by helicopter to Little St. James. On other occasions, Epstein and the 
young women and girls would be transported by boat. 
151. 
Great St. Jim, LLC and Nautilus, Inc. knowingly participated in the Epstein 
Enterprise and facilitated the trafficking and sexual servitude of young women and underage 
girls by providing the secluded properties at, from, or to which Epstein and his associates were 
able to transport, transfer, receive, maintain, isolate, harbor, provide, entice, deceive, coerce, 
and sexually abuse underage girls and young women. 
152. 
The Epstein Enterprise engaged in a continuing course of unlawful conduct. 
153. 
After Epstein's suicide, the Epstein Enterprise continued to exist as each of the 
participants continued to conspire to prevent detection of the breadth and scope of the Epstein 
Enterprise's criminal wrongdoing and to prevent accountability. These conspiratorial acts are 
ongoing. 
154. 
The conduct of the Epstein Enterprise offends the core purpose of the Virgin 
Islands Uniform Prevention of and Remedies for Human Trafficking Act, 14 V.I.C. §131 et seq, 
and violates CICO, enacted to "curtail criminal activity and lessen its economic and political 
power in the Territory of the Virgin Islands by establishing new penal prohibitions and 
providing to law enforcement and the victims of criminal activity new civil sanctions and 
remedies." 14 V.I.C. § 601. 
EFTA00161901

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 33 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 32 of 76 
155. 
The Epstein Enterprise is an illicit enterprise within the meaning of 14 V.I.C. §§ 
604 and 605. 
156. 
The Government is entitled to recover civil penalties, damages and other 
remedies and to extinguish and recoup from the Epstein Enterprise and its participants any and 
all financial and other benefits, and any personal and real property that was used during the 
course of, or intended for use in the Course of the conduct or criminal activity in violation of the 
laws of the Virgin Islands. The Government is entitled to obtain through divestiture, forfeiture, 
or other equitable relief all properties and instrumentalities used by the Epstein Enterprise in the 
criminal pattern of trafficking and sexual abuse in the Virgin Islands, including but not limited 
to Great St. James and Little St. James, and all other remedies and penalties permitted by law in 
the interest of justice. 
F. The Epstein Enterprise Used Corporate Entities to Defraud the Government 
and Fund its Criminal Activities 
1. Defendant Southern Trust Company, Inc. 
157. 
In October 2012, the Southern Trust Company applied for economic benefits 
from the Economic Development Commission ("EDC"). The EDC is a subsidiary of the Virgin 
Islands Economic Development Authority ("EDA"), a semi-autonomous governmental 
instrumentality created and governed pursuant to 29 VIC § 1101. 
158. 
In sworn testimony at a public hearing on the tax incentive application 
conducted by the EDC on November 15, 2012, Epstein and his attorney, Ericka Kellerhals, 
described Southern Trust Company as providing "cutting edge consulting services" in the area 
of "biomedical and financial informatics." 
EFTA00161902

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 34 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 33 of 76 
159. 
The EDC granted Southern Trust Company a 10-year package of economic 
incentives running from February 1, 2013 until January 31, 2023 that included a 90% 
exemption from income taxes and 100% exemptions from gross receipts, excise, and 
withholding taxes in the Virgin Islands. 
160. 
Between 2013 and 2019, Southern Trust Company employed 13 different 
individuals (not including Epstein). Of those 13 individuals, 11 served in administrative or 
support roles: six as personal, administrative, or executive assistants, receptionists, or as a 
driver/helper, one as an office manager, one as a clerk, and three in accounting or payroll 
functions (though only one was licensed as a certified public accountant). There was one 
network administrator/IT manager, and a second who was added in 2019. 
161. 
In fact, several of those individuals seemed to perform other personal services 
for Jeffrey Epstein. Though he was reported by Southern Trust Company to be resident of the 
Virgin Islands, the network administrator/IT manager was issued a Florida driver's license, 
which listed an address in Miami. Further, he appears, in fact, to have served as Epstein's driver 
and picked up luggage and cargo from Epstein's private planes on his behalf. 
162. 
Another executive assistant lived at 301 E. 66th Street, Apartment I I B, New 
York, New York. Epstein's address book lists various units in this building as providing "Apt. 
for models" and she is publicly identified as a model. As noted above, the Epstein Enterprise 
used modeling opportunities and contracts as a pretext for recruiting underage girls and young 
women into its sex trafficking scheme. 
163. 
Financial records more recently obtained show that the employee described 
above whom Kahn represented to be, alternatively, 
was also a 
EFTA00161903

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 35 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 34 of 76 
which did not actually or even pretend to perform 
either 
in 2019. 
164. 
During several time periods, Southern Trust Company affirmed to EDC that it 
had no employees who were non-residents, even though it employed non-residents. 
165. 
Southern Trust company does not appear to have had any clients and performed 
no visible informatics services. According to financial records, it held no investments for others. 
Instead, its employees performed tasks related to any number of other Epstein-owned companies 
or properties, such as Little St. James. 
166. 
Despite having no visible clients and only one full-time employee working on 
information technology during the bulk of the period, Southern Trust Company reportedly 
generated net income of $50.3 million in 2013, $67.5 million in 2014, $52.8 million in 2015, and 
$4.8 million in 2016 and $17.1 million in 2017, with aggregate income of $117.8 million in 2014, 
$170.6 million in 2015, $175.3 million in 2016 and $192.4 million in 2017, or aggregate income 
for the period of $656 million. 
167. 
Money received by Southern Trust was then funneled, frequently by Defendant 
Indyke as authorized signatory, and often with copies given to Defendant Kahn, through other 
Epstein-owned entities and accounts, funding payments to foreign women and for credit cards, 
airplanes, and other instrumentalities of the Epstein Enterprise. 
168. 
In fact, the main source of funds for the Epstein Enterprise came from Southern 
Trust. Between 2013 and 2017, Southern Trust reported approximately $184 million in 
revenues. 
169. 
Defendants Kahn and Indyke directed and controlled the day-to-day activities of 
Southern Trust in form and in substance, serving as members of its Board of Directors, along 
EFTA00161904

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 36 of 77 
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. 
EFTA00161905

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 37 of 77 
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 Zorro 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. 
EFTA00161906

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 38 of 77 
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 
EFTA00161907

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 39 of 77 
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 . . ." 
EFTA00161908

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 40 of 77 
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. 
EFTA00161909

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 41 of 77 
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. 
EFTA00161910

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 42 of 77 
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 
EFTA00161911

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 43 of 77 
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. 
EFTA00161912

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 44 of 77 
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). 
EFTA00161913

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 45 of 77 
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. 
EFTA00161914

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 46 of 77 
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. 
EFTA00161915