EFTA00161836.txt

"Plaintiff Government of the United States Virgin Islands ("Government") files this Complaint against JPMorgan Chase Bank, N.A. ("JP Morgan")"

"Epstein and his co-conspirators... would use means of force, threats of force, fraud, coercion... to sexually abuse young women and underage girls"

"Epstein—a Virgin Islands resident"

"Epstein, who resided in the Virgin Islands"

"young women and/or underage girls who were sexually abused and coerced into engaging in commercial sexual acts"

"A 15-year old victim was forced into sexual acts with Epstein and others"

"Another victim, who was first engaged in provide massages to Epstein, was then forced to perform sexual acts at Little St. James"

"She was repeatedly abused by Epstein and also was pressed to have sex with Epstein's business colleagues."

"Epstein created a network of companies and individuals... referred to herein as the 'Epstein Enterprise.'"

"Staley corresponded with Epstein while Epstein was incarcerated"

"visited Epstein's Virgin Islands residence on multiple occasions"

"Staley was the Chief Executive Officer of Barclays; however, Staley stepped down from that position in November 2021"

"Jane Doe 1, a woman who... Epstein purchased at the age of 14"

"Epstein paid more than $600,0000 to Jane Doe 1"

"Hyperion Air, Inc.—the Epstein-controlled company"

"used the Enhanced Education fund to pay $124,232 to Leslie Wexner"

"In 2004, Epstein introduced Staley to Glenn Dubin"

"Epstein moved his accounts to Deutsche Bank from 2013 to 2018"

"Jeffrey Epstein was a resident of the Virgin Islands"

"the Southern Trust Company—one of the companies Epstein owned"

"These communications show a close personal relationship and "profound" friendship between the two men"

"Epstein's lawyer, Darren K. Indyke"

"accountant, Richard Kahn"

"young women and underage girls to travel to the Virgin Islands where they engaged in sexual acts with Epstein and others"

"One victim was brought by Defendants more than 50 times between 2000 and 2002... where she was required to have sexual relations with Epstein"

"Another victim was brought by Defendants dozens of times between 2004 and 2017 to Little St. James, where she too... were required to have sexual rela"

"Defendants Indyke and Kahn were authorized signatories on the company's checking account"

"Defendants Indyke and Kahn were authorized signatories on the company's checking account"

"Epstein and his attorney, Ericka Kellerhals"

"Plan D, LLC knowingly and intentionally facilitated the trafficking scheme by flying underage girls and young women into the Virgin Islands"

"Great St. Jim, LLC and Nautilus, Inc. knowingly participated in the Epstein Enterprise and facilitated the trafficking"

"Epstein and others, using force or intimidation, engaged in sexual intercourse with underage girls without their consent"

"As a result of the Epstein Enterprise's actions numerous young girls suffered serious physical, mental and emotional injury"

"GVI v. Estate of Jeffrey Epstein"

"All Defendants Except Darren K. Indyke and Richard D. Kahn"

"All Defendants Except Darren K. Indyke and Richard D. Kahn"

"transferring assets to and between various entities controlled by Epstein and the Epstein Enterprise"

"Epstein traveled to Vienna and Monaco without disclosing that travel to the Virgin Islands sex offender registry"

"Epstein traveled to Vienna and Monaco without disclosing that travel to the Virgin Islands sex offender registry"

"GVI v. Estate of Jeffrey Epstein"

"the Epstein Enterprise undertook construction at Great St. James after 2016 to continue the scheme to carry out and conceal his trafficking and sexual"

"Epstein's pilot, Larry Visoski"

"Larry Visoski is identified as member or co-member in companies... Freedom Air Petroleum, LLC"

"Larry Visoski is identified as member or co-member in companies... JEGE, LLC"

"Another victim... was subjected to sexual abuse virtually every day, and on some days, multiple times a day by Epstein or his guests"

"Defendants Kahn and Indyke organized, controlled, and directed almost every aspect of the Epstein Enterprise"

"Defendants Kahn and Indyke organized, controlled, and directed almost every aspect of the Epstein Enterprise"

"As of October 23, 2007, Indyke was listed as President of the Foundation"

"fine Epstein had incurred for construction on Great St. James Island"

"Defendants Indyke and Kahn also directed, approved, enabled, and justified millions of dollars in payments that fueled the Epstein Enterprise's sex tr"