EXH-4 BI-3 Case Document Filed Page of Case Document Filed Page of IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST THOMAS AND ST JOHN GOVERNMENT OF THE UNITED ST A TES VIRGIN ISLANDS PLAINTIFF EST ATE OF JEFFREY EPSTEIN THE TRUST PLAN LLC GREAT ST JIM LLC NAUTILUS INC HYPERION AIR LLC POPLAR INC JOHN AND JANE DOES DEFENDANTS COMPLAINT Case Sf-cl 0J rri ACTION FOR DAMA QJ JU RY TRIAL DEMANDED COMES NOW the Government of the United States Virgin Islands Government and files th i Complaint against the above-named Defendants and in supp rt thereof would show unto the Court as follows JURISDICTION AND PARTIES The Attorney General of the United States Virgin Islands herein after Virgin Islands brings this action on behalf of the Plaintiff Government of the Virgin Islands pursuant to LC and her statutory authority to enforce the laws of the Virgin Islands and advocate for the public interest afety health and well-being of persons in the Virgin Islands This Court has subject matter jurisdiction over this civil matter pursuant to l.C and This Court has personal jurisdiction over the parties pursuant to LC Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of The Virgin Islands is an unincorporated territory of the United States It consists of St Thomas St Croix St John and Water Island and more than surrounding islands and Cays some of which are privately owned Among these privately owned islands are Little St James and Great St James Jeffrey Epstein Epstein was a resident of the Virgin Islands and he maintained a residence on Little St James which he acquired in and in he also purchased Great St James Epstein registered as a sex offender in the Virgin Islands in He was a Tier offender under Virgin Islands law based upon his Florida conviction of procuring a minor for prostitution As a Tier offender Epstein was required to register annually with the Virgin Islands Department of Justice VIDOJ and give advance notice of his travel to and from the Virgin Islands Epstein was also subject to random address verification by VIDOJ Epstein was found dead on August while in custody in New York for sex crimes Defendant Estate of Jeffrey Epstein The Estate created upon Epsteins death is domiciled in the Virgin Islands On August the Executors of The Estate Darren lndyke and Richard Kahn filed a Petition for Probate and Letters Testamentary which included Epsteins last will and testament with the Probate Division of the Superior Court of the Virgin Islands The Petition reports the value of the real and personal property in The Estate located in the Virgin Islands at dollars I According to the Petition the assets in the Virgin Islands thus far includes a million in cash Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of million in fixed income and equity investments million in hedge fund and private equity investments and million in planes boats and automobiles The Estate has not yet valued his fine arts antiques and other valuables The Estate also includes shares of various corporate entities which hold residences and real property used by Epstein namely a Brownstone in New York City valued at million Ranch in New Mexico valued at million Gated home in Palm Beach Florida valued at million Seven units in an apartment building in Paris valued at million and Great St James and Little St James collectively valued at million The Estate is responsible to pay damages for the acts committed by Epstein and the Epstein Enterprise described below Defendant The Trust The Trust was created by Epstein who amended and restated its tenns only two days before his suicide That same day Epstein revised his Last Will and Testament transferring all of his property real and personal wherever situated to The Trust The Trust also contains Epsteins financial assets and is also responsible to pay damages for the acts committed by Epstein and the Epstein Enterprise described below The Trusts administrators Darren Indyke and Richard Kahn filed a Certificate of Trust in the Superior Court of the Virgin Islands for The Trust on August Epstein maintained a deliberately complex web of Virgin Islands corporations limited liability companies foundations and other entities not all of which are yet known to the Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of Government of the Virgin Islands through which he carried out and concealed his criminal conduct Epstein regularly created new entities in the territory and transferred properties and funds between them in order to preserve and shield Epsteins asset and to facilitate and conceal the unlawful acts described in this Complaint These entities held properties including Little St James and Great St James at which Epstein trafficked and sexually abused women and underage girls Epstein owned and arranged for private planes helicopters boat and automobile to transport vi tims to from and within the Virgin Islands and provided money to pay these young women and underage girls Epstein sat at the hub of this web serving as president member manager or director of each of the entities and upon infonnation and belief directing their activities Defendant Nautilus Inc is a corporation establi hed and organized under the laws of the Virgin Islands It was incorporated November According to records of the Virgin Islands Recorder of Deeds Nautilus Inc owns Little St James a/k/a Par el Number a parcel of million square feet valued at million with buildings and improvements valued at million Epstein was president and director of Nautilus Inc which corporate filing describe as holding property for personal use Darren Indyke and Richard Kahn Executors of the Estate are the secretary and treasurer of Nautilus Inc respectively The Estate values Epstein holdings of Nautilus Inc which holds title to Little St James at million A deed recorded with the Virgin Islands Recorder of Deeds on December reflects that the property was transferred from a Delaware entity L.S LLC to Nautilus Inc for TEN DOLLARS and other good and valuable consideration The quitclaim deed lists Case Document Filed Page of GVI Estate of Jeffrey Epstein GVls Complaint Page of Jeffrey Epstein as the sole member of L.S.J LLC which it acquired Little Saint James via a warranty deed dated April As described below Epstein engaged in a pattern and practice of trafficking and sexually abusing young women and female children on this private secluded island of Little St James where Epstein and his associates could avoid detection of their illegal activity from Virgin Islands and federal law enforcement and prevent these young women and underage girls from leaving freely and escaping the abuse Thus Nautilus Inc participated in carrying out facilitating and concealing Epsteins crimes hence Little St James became an instrumentality of those crimes Defendant Great St Jim LL is a limited liability company established and organized under the laws of the Virgin Islands Great St Jim LLC was organized on October Great St Jim LLC according to records of the Virgin Islands Recorder of Deeds owns at least three properties that make up Great St James acquired on January I Parcel Number consisting million square feet and valued at million Parcel Number IO consisting of square feet of land valued at million and Parcel Number million square feet of land valued at million According to a warranty deed filed with the Virgin Islands Recorder of Deeds Epstein through Great St Jim LLC acquired the last two parcels for million Epstein is listed as manager and a member of Great St Jim LLC and the nature of its business is described as holding assets Upon information and belief Epstein purchased these Great St James properties the island with closest proximity to Little St James to further shield his conduct on Little St James from view prevent his detection by law enforcement or the public and allow him to Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of continue and conceal his criminal enterprise Epsteins significant investment in the purchase of Great St James demonstrates his intent to expand his illegal operation in the Virgin Islands for years to come Thus Great St Jim LLC participated in carrying out concealing facilitating and continuing Epsteins crimes and Great St James became an instrumentality of those crimes Defendant Poplar Inc is a corporation established and organized under the laws of the Virgin Islands Poplar Inc was incorporated on November Epstein was president and director of Poplar Inc and its purpose was described in corporate filings as holding property for personal use Darren Indyke and Richard Kahn Executors of the Estate are secretary and treasurer of Poplar Inc respectively A certificate of incumbency provided to the Department of Planning and Natural Resources DPNR also lists Epstein as president of Poplar Inc and expressly authorizes the incorporators to conduct transactions related to permitting matters submitted on behalf of Great St Jim LLC Poplar Inc is listed as the signatory for the Annual Report for Great St Jim LLC and the signature appears to be Epsteins The Petition for Probate and Letters Testamentary filed by The Estate lists Poplar Inc as holding title to Great St James Thus Poplar Inc participated in carrying out concealing facilitating and continuing Epsteins crimes Defendant Plan LLC is a limited liability company established and organized under the laws of the Virgin Islands In its original Articles of Organization filed October and Annual Report filings Epsteins pilot Larry Visoski was listed as Plan LLCs sole manager member However the July Annual Report revealed Epstein as the principal behind Plan LLC Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of Upon information and belief Plan LLC owns one or more of the airplanes and helicopters that Epstein used to transport young women and children to and from the Virgin Islands to carry out the criminal pattern of activity described below Among the airplanes owned by Plan LLC is a Gulfstream with N-number N212JE Flight logs and travel notices indicate that Epstein used this plane to traffic and transport and young women and underage girls to the Virgin Islands Defendant Hyperion Air LLC is a limited liability company established and organized under the laws of the Virgin Islands on October Jeffrey Epstein is a manager member of Hyperion Air LLC along with his pilot Larry Visoski The purpose of Hyperion Air LLC is listed in its Annual Report as holding assets Hyperion Air LLC is the registered owner of a Bell helicopter with N-number JE and a Keystone helicopter with N-number N722JE Upon information and belief Epstein used these helicopters to transport young women and underage girls between St Thomas and Little St James John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered The Attorney General brings this action to seek all remedies available to the Government of the Virgin Islands in enforcing its laws and protecting the public interest and public safety These claims are distinct from and are not intended to supplant the claims of victims who were unconscionably harmed by Jeffrey Epstein and his associates Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of FACTUAL ALLEGATIONS A The Conduct of the Epstein Enterprise in the Virgin Islands Epstein and his associates including Defendants identified and recruited female victims including children and transported them to the Virgin Islands where they were abused and injured Epstein through and in association with Defendants trafficked raped sexually assaulted and held captive underage girls and young women at his properties in the Virgin Islands Epstein created a network of companies and individuals who participated in and conspired with him in a pattern of criminal activity related to the sex trafficking forced labor sexual assault child abuse and sexual servitude of these young women and children Epstein and his associates trafficked underage girls to the Virgin Islands held them captive and sexually abused them causing them grave physical mental and emotional injury To accomplish his illegal ends Epstein fonned an association in fact with multiple Defendants and others both companies and individuals who were willing to participate in facilitate and conceal Epsteins criminal activity in exchange for Epsteins bestowal of financial and other benefits including sexual services and forced labor from victims This illicit association of Epstein Defendants and his associates constitutes what is referred to herein as the Epstein Enterprise Epsteins associates in the Epstein Enterprise including but not limited to those named as Defendants knowingly facilitated participated in and concealed Epsteins illegal conduct Epstein used his wealth and power to create the Epstein Enterprise which engaged in a pattern of criminal activity in the Virgin Islands by repeatedly procuring and subjecting underage girls and young women to unlawful sexual conduct sex trafficking and forced labor Case Document Filed Page of GVI Estate of Jeffrey Epstein GVls Complaint Page of The Epstein Enterprise engaged in a pattern of criminal activity in the Virgin Islands and elsewhere with the criminal purpose and goal of placing a steady supply of vulnerable female children and young women into sexual servitude in service of Epsteins desires and those of his associates The Epstein Enterprise maintained and made available young women and underage girls for the purpose of engaging them in forced labor and sexual activities and used coercion and deception to procure abuse and harbor its victims Flight logs and other sources establish that between and the Epstein Enterprise transported underage girls and young women to the Virgin Islands who were then taken via helicopter or private vessel to Little St James where they were then deceptively subjected to sexual servitude forced to engage in sexual acts and coerced into commercial sexual activity and forced labor In furtherance of its criminal activities the Epstein Enterprise used its aircrafts to transport the young women and underage girls to the Virgin Islands for purposes of sexual abuse and exploitation The Epstein Enterprise facilitated and participated in the sexual molestation and exploitation of numerous girls between the age of and years old On the pretext of providing modeling opportunities careers and contracts associates of the Epstein Enterprise funded by the Epstein Enterprise lured and recruited young women and underage girls to travel to locations including the Virgin Islands where upon information and belief based on the pattern and practice of the Epstein Enterprise they were sexually abused and exploited Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of Associates in the Epstein Enterprise recruited both victims and abusers into the Epstein Enterprise participated in sexual acts of rape and abuse of minors and witnessed Epstein and others engage in sexual acts with children As recent as air traffic controllers and other airport personnel reported seeing Epstein leave his plane with young girls some of whom appeared to be between the age of and years Upon information and belief based on Epsteins pattern of trafficking and sexually abusing young girls the Epstein Enterprise trafficked and abused these girls and others in the Virgin Islands through When sued in civil court for committing sex trafficking and sex crimes Epstein never denied engaging in sexual acts with underage females and procuring underage females for prostitution but instead consistently invoked his Fifth Amendment privilege against self incrimination Upon information and belief the Epstein Enterprise kept a computerized list of underage girls who were in or proximate to the Virgin Islands and able to be transported to Epsteins residence at Little St James in the Virgin Islands The Epstein Enterprise engaged in a pattern of criminal conduct by trafficking children and young women and placing them in sexual servitude and forced labor in the Virgin Islands The Epstein Enterprise repeatedly violated V.I.C to which prohibit trafficking and sexual abuse The Epstein Enterprise also repeatedly violated laws against child abuse and neglect including LC which defines the crime of child abuse as knowingly or recklessly causing a child to suffer physical mental or emotional injury or causing a child to be placed in a situation where such injury is foreseeable and V.I.C which applies as Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of here where the child suffers serious physical mental or emotional injury as a result of that abuse The harm to Epsteins victims was both fully foreseeable and deeply damaging The Epstein Enterprise knowingly recruited transported transferred harbored received procured obtained isolated maintained and enticed young women and girls to engage in forced labor such as providing massages and ultimately sexual servitude at his little St James residence A year old victim was forced into sexual acts with Epstein and others and then attempted to escape by swimming off the Little St James island Epstein and others organized a search party that located her and kept her captive by among other things confiscating her passport Another victim who was first engaged in provide massages to Epstein was then forced to perform sexual acts at Little St James in the Virgin Islands When she attempted to escape from the private island Epstein and a search party found her returned her to his house and suggested physical restraint or hann if she failed to cooperate The Epstein Enterprise deceptively lured underage girls and women into its sex trafficking ring with money and promises of employment career opportunities and school assistance The Epstein Enterprise preyed on their financial and other vulnerabilities and promised victims money shelter gifts employment tuition and other items of value For example participants in the Epstein Enterprise targeted young and underage females under the pretext that they would be paid substantially merely to provide massages to him and others However once drawn in victims were then pressured and coerced to engage in sexual acts he Epstein Enterprise forced underage victims to recruit others to perform services and engage in sexual acts a trafficking pyramid scheme Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of The Epstein Enterprise paid girls for each meeting with additional money if they brought additional girls Epstein reportedly required three meetings per day The Epstein Enterprise used the term work as a code for sexual abuse and upon information and belief reportedly kept computer records of the contact infonnation for the victims Consistent with his creation and use of a complex web of entities to carry out and conceal the criminal trafficking enterprise in the Virgin Islands the Epstein Enterprise sometimes paid young women and underage girls he exploited and trafficked through his charitable foundations Once the girls and women were recruited participants in the Epstein Enterprise enforced their sexual servitude of victims by coercion including but not limited to confiscating passports controlling and extinguishing external communications and threatening violence They also made fraudulent statements to family members of victims claiming victims were being well cared for and supported financially in college and other educational opportunities The Epstein Enterprise transported held sexually abused trafficked and concealed women and children at his property in the Virgin Islands do ens of times over nearly two decades The Epstein Enterprise Abused Privileges of Residency to Carry out its Criminal Scheme The Epstein Enterprise in acquired Little St James in the Virgin Islands as the perfect hideaway and haven for trafficking young women and underage girls for sexual servitude child abuse and sexual assault Little St James is a secluded private island nearly two miles from St Thomas with no other residents It can be visited only by private boat or helicopter no public or commercial transportation is available to carry persons on or off the island and no Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of bridge connects the island to St Thomas Epstein had easy access to Little St James from the private airfield on St Thomas only minutes away by his private helicopter but the women and children he trafficked abused and held there were not able to leave without his permission and assistance as it was too far and dangerous to swim to St Thomas In upon information and belief using a straw purchaser to hide Epsteins identity the Epstein Enterprise acquired Great St James the nearest island to Little St James By then Epstein was a convicted sex offender Upon information and belief the Epstein Enterprise purchased the island for more than million because its participants wanted to ensure that the island did not become a base from which others could view their activities or visitors By acquiring ownership and control of Great St James to the exclusion of others the Epstein Enterprise created additional barriers to prevent those held involuntarily on Little St James from escaping or obtaining help from others Great St James and Little St James are environmentally sensitive locations with native coral and wildlife protected by federal and territorial law and enforcement authorities The Department of Planning and Natural Resources DPNR regulates and monitors construction in the Coastal Zone to protect maintain and manage the precious natural resources of the Virgin Islands Under its authority DPNR repeatedly issued citations and assessed thousands of dollars of fines for violations of the Virgin Islands construction code and environmental protection laws on both Little St James and Great St James significant penalties to the agency and to the average resident of the Virgin Islands But because of Epstein enormous wealth these fines had little effect in curbing or stopping the Epstein Enterprises unlawful conduct or conforming its activities to the law Case Document Filed Page of GVI Estate of Jeffrey Epstein GVls Complaint Page of As a result of illegal construction activity of the Epstein Enterprise the Virgin Islands has incurred and will incur significant expenses to remove the illegal construction or remediate its effects on natural resources in and around Little St James and Great St James The extent of the potential environmental damage is unknown at this time as the illegal construction has not been removed or remediated The Epstein Enterprise continues to attempt to prevent or limit DPNR authorities from conducting random inspections on the Little St James and Great St James necessary to comply with Virgin Islands law The Epstein Enterprises 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 constru tion at Great St James after 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 Enterprises 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 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 Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of The Epstein Enterprise Fraudulently Concealed its Conduct The Epstein Enterprise fraudulently concealed its actions to prevent detection by the Government of the Virgin Islands 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 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 Moreover Epsteins great wealth and power likely made witnesses reluctant to report their observations to the local law enforcement 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 Epsteins counsel 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 Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of 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 Sexual Offender Registration and Community Protection Act SORCPA LC et seq requires sex offenders registered in the Virgin Islands to make periodic in person appearances to verify and update their registration information 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 At his last verification in July 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 Epstein also misled the Government regarding his travel plans On March the Virgin Islands was notified that Epstein would be traveling to France for days on the private plane owned by Plan LLC His notification form did not disclose travel to any other countries It was later discovered by law enforcement authorities that Epstein also travelled to Vienna and Monaco during that trip 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 inspections referring to them as invasions of Epsteins 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 Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of required to cooperate with the inspections to assure compliance with the law throughout the construction phases These efforts represent Epstein Enterprises intent to conceal its unlawful activity on Little St James and Great St James 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 and soon after Epstein registered as a sex offender in the Virgin Islands Epsteins 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 I to hold assets and JEGE LLC registered October to hold assets Other Epstein entities include LSJ Employees LLC registered October to provide services Southern Financial LLC registered February to provide services and LSJ Emergency LLC registered December to provide services Some of these companies held considerable assets Financial Informatics Inc incorporated November also known as Southern Trust Company Inc had assets of approximately million in I and Financial Trust Company Inc incorporated November had assets of million when it publicly filed its last balance sheet in 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 Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of The Estate continues to engage in a course of conduct aimed at concealing the criminal activities of the Epstein Enterprise On November Epsteins 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 Epstein Motion at The program proposed by the Estate whose executors are trustees of The 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 Epsteins conduct Motion at It acts to conceal the criminal activities of the Epstein Enterprise and shield its participants from liability and accountability for the injury they caused to the victims 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 The Epstein Enterprise Violated Numerous Virgin Islands Laws The pattern of criminal activity engaged in by Epstein and other participants in the Epstein Enterprise violated V.I.C and of the Criminally Influenced and Corrupt Organizations Act CICO The Epstein Enterprise also violated Title Chapter 3A The Virgin Islands Uniform Prevention of and Remedies for Human Trafficking Act relating to Trafficking of Persons Title Chapter relating to Child Protection and Child Abuse and Neglect Title Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of Chapter relating to Prostitution and Related Offenses Title Chapter relating to Rape and Sexual Assault and other related offenses as well as other Virgin Islands laws 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 Enterprises violations of CICO Certain participants who recruited young 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 V.I.C Specifically Plan 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 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 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 The Epstein Enterprise engaged in a continuing course of unlawful conduct Case Document Filed Page of GVI Estate of Jeffrey Epstein GVls Complaint Page of After Epsteins 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 Enterprises criminal wrongdoing and to prevent accountability These conspiratorial acts are ongoing The conduct of the Epstein Enterprise offends the core purpose of the Virgin Islands Uniform Prevention of and Remedies for Human Trafficking Act V.I.C 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 I.C The Epstein Enterprise is an illicit enterprise within the meaning of V.I.C and I The Government is entitled to recover civil penalties damages and other remedies and to extinguish and recoup from the Epstein Enterprise 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 Case Document Filed Page of GVI Estate of Jeffrey Epstein GVl Complaint Page of COUNT ONE Human Trafficking Trafficking an Individual Violation of the Criminally Influenced and Corrupt Organizations Act CICO V.I.C et seq and V.I.C The Government restates and realleges paragraphs to of this Complaint as if fully set forth herein At all times material herein each Defendant directly and indirectly participated in or associated with the Epstein Enterprise an illicit enterprise The Epstein Enterprise engaged in two or more occasions of conduct that constitutes 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 childr 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 I.C 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 Defendants benefited directly and indirectly from the pattern of criminal activity conducted by the Epstein Enterprise At all times material herein Defendants engaged in said pattern of criminal activit that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO V.I seq Case Document Filed Page of GVI Estate of Jeffrey Epstein GVls Complaint Page of COUNT TWO Human Trafficking Trafficking an Individual Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act V.I.C et seq and V.I.C The Government restates and realleges paragraphs of this Complaint as if fully set forth herein I At all times material herein each Defendant joined in a conspiracy to violate laws prohibiting human trafficking I 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 youn women in the furtherance and performance of forced labor sexual servitude and commercial sexual activity in violation of Virgin Islands laws codified in I.C 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 oung women in knowing or reckless disregard of the laws of the U.S Virgin Island 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 V.I.C At all times material herein Defendants eng a ged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO V.I.C seq Case Document Filed Page of GVI Estate of Jeffrey Epstein GVls Complaint Page of COUNT THREE Human Trafficking Forced Labor Violation of the Criminally Influenced and Corrupt Organizations Act CICO V.I.C et seq and V.I.C The Government restates and realleges paragraphs of this Complaint as if fully set forth herein At all times material herein each Defendant directly and indirectly participated in or associated with the Epstein Enterprise an illicit enterprise The Epstein Enterprise engaged in two or more occasions of conduct that constitutes 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 V.l.C I 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 hann or threats of serious hann 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 perfonn such labor or services individuals would suffer serious hann or physical restraint Defendants through a pattern of criminal activity directly and indirectly participated in or associated with the Epstein Enterprise an illicit enterprise 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 Defendants benefited directly and indirectly from the pattern of criminal activity conducted by the Epstein Enterprise Case Document Filed Page of GVI Estate of Jeffrey Epstein GVI Complaint Page of 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 V.l.C et COUNT FOUR Human Trafficking Forced Labor Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act V.I.C et seq and V.I.C The Government restates and realleges paragraphs of this Complaint as if fully set forth herein At all times material herein each Defendant joined in a conspiracy to violate laws prohibiting human trafficking 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 V.I.C 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 U.S Virgin Islands 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 V.I.C Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of 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 V.I.C et seq COUNT FIVE Human Trafficking Sexual Servitude Violation of the Criminally Influenced and Corrupt Organizations Act CICO et seq V.I.C The Government restates and realleges paragraphs of this Complaint as if fully set forth herein At all times material herein each Defendant directly and indirectly participated in or associated with the Epstein Enterprise an illicit enterprise The Epstein Enterprise engaged in two or more occasions of conduct that constitutes 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 V.I.C 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 Defendants through a pattern of criminal activity directly and indirectly participated in or associated with the Epstein Enterprise an illicit enterprise Case Document Filed Page of GVI Estate of Jeffrey Epstein GVI Complaint Page of 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 Defendants benefited directly and indirectly from the pattern of criminal activity conducted by the Epstein Enterprise 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 V.I.C et seq COUNT SIX Human Trafficking Sexual Servitude Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act et seq V.I.C The Government restates and realleges paragraphs of this Complaint as if fully set forth herein At all times material herein each Defendant joined in a conspiracy to violate laws prohibiting human trafficking 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 V.I.C On the pretext of providing modeling opportunities careers and contracts Defendants facilitated the transp rting or recruiting of young women and girls or lured and recruited young women and und rage girls to travel to the i rgin Islands where they engaged in sexual acts with Epstein and others In some instances young women a nd underage girls were Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of given scholarships money gifts or other items of value in exchange for engaging in sexual acts with Epstein and others 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 U.S Virgin Islands 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 V.I.C 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 I.C seq COUNT SEVEN Human Trafficking Patronizing Minors and Victims of Sexual Servitude Violation of the Criminally Influenced and Corrupt Organizations Act CICO V.I.C et seq V.I.C The Government restates and realleges paragraphs of this Complaint as if fully set forth herein At all times material herein each Defendant directly and indirectly participated in or associated with the Epstein Enterprise an illicit enterprise The Epstein Enterprise engaged in two or more occasions of conduct that constitutes 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 Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of young women and mmors would engage in commercial sexual activity with Epstein other Defendants and other individuals in violation of V.l.C 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 Defendants through a pattern of criminal activity directly and indirectly participated in or associated with the Epstein Enterprise an illicit enterprise Defendants through a pattern of criminal activity acquired and maintained direct or indirectly an interest in or control of the Epstein Enterprise or real property Defendants benefited directly and indirectly from the pattern of criminal activity conducted by the Epstein Enterprise 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 V.I.C et seq COUNT EIGHT Human Trafficking Patronizing Minors and Victims of Sexual Servitude Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act V.I.C et seq V.I.C The Government restates and realleges paragraphs of this Complaint as if fully set forth herein At all times material herein each Defendant joined in a conspiracy to violate laws prohibiting human trafficking Case Document Filed Page of GVI Estate of Jeffrey Epstein GVls Complaint Page of 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 I.C 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 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 exual activity of girls and young women in knowing or reckless disregard of the laws of the U.S Virgin Islands 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 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 V.I.C seq COUNT NINE Child Abuse and Neglect Violation of the Criminally Influenced and Corrupt Organization Act CICO V.I et seq and The Government restates and realleges paragraphs of this Complaint as if fully set forth herein Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of At all times material herein each Defendant directly and indirectly participated in or associated with the Epstein Enterprise an illicit enterprise The Epstein Enterprise engaged in two or more occasions of conduct that constitutes 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 et seq As a result of the Epstein Enterprises actions numerous young girls suffered serious physical mental and emotional injury Defendants through a pattern of criminal activity acquired and maintained direct I or indirectly an interest in or control of the Epstein Enterprise or real property Defendants benefited directly and indirectly from the pattern of criminal activity conducted by the Epstein Enterprise 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 V.I.C et seq COUNT TEN Child Abuse and Neglect Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act V.I.C et seq V.I.C SOS and The Government restates and realleges paragraphs of this Complaint as if fully set forth herein Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of At all times material herein each Defendant joined in a conspiracy to violate laws prohibiting child abuse and neglect 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 Title V.l.C et seq As a result of fendants actions numerous young girls suffered serious physical mental and emotional injury 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 in knowing or reckless disregard of the laws of the Virgin Islands At all times material herein each Defendant conspired with Ep tein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise human tr a fficking forced labor and sexual servitude I.C 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 V.I.C seq Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of COUNT ELEVEN Aggravated Rape Violation of the Criminally Influenced and Corrupt Organization Act CICO V.I.C et seq V.I.C The Government restates and realleges paragraphs of this Complaint as if fully set forth herein At all times material herein each Defendant directly and indirectly participated in or associated with the Epstein Enterprise an illicit enterprise The Epstein Enterprise engaged in two or more occasions of conduct that constitutes 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 perpetrators position of authority over the victim Epstein and others using force or intimidation engaged in sexual intercourse with underage girls without their consent in violation of LC As a result of the Epstein Enterprise actions numerous underage girls suffered serious physical mental and emotional injury 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 Defendants benefited directly and indirectly from the pattern of criminal activity conducted by the Epstein Enterprise 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 I.C et Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of COUNT TWELVE Aggravated Rape Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act V.I.C et seq V.I.C The Government restates and realleges paragraphs of this Complaint as if fully set forth herein At all times material herein each Defendant joined in a conspiracy to violate laws prohibiting aggravated rape 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 perpetrators position of authority over the victim Epstein and others using force or intimidation engaged in sexual intercourse with underage girls without their consent in violation of As a result of Defendants actions numerous underage girls suffered serious physical mental and emotional injury Defendants knowingly benefited financially an 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 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 V.I.C I Case Document Filed Page of GVI Estate of Jeffrey Epstein GVls Complaint Page of 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 V.I.C et seq COUNT THIRTEEN Rape in the Second Degree Violation of the Criminally Influenced and Corrupt Organization Act CICO V.I.C et seq V.I.C The Government restates and realleges paragraphs I of this Complaint as if fully set forth herein At all times material herein each Defendant directly and indirectly participated in or associated with the Epstein Enterprise an illicit enterprise The Epstein Enterpri engaged in two or more occasions of conduct that constitutes criminal predicate acts as defined by CICO including but not limited to conduct that constituted or facilitated the rape of girls under years of age Epstein and others who engaged in rape were over years old at the time of the incidents As a result of the Epstein Enterprises actions numerous minors suffered serious physical mental and emotional injury 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 Defendants benefited directly and indirectly from the pattern of criminal activity conducted by the Epstein Enterprise Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of 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 V.I.C et seq COUNT FOURTEEN Rape in the Second Degree Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act V.I.C et seq V.I.C The Government restates and realleges paragraphs of this Complaint as if fully set forth herein At all times material herein each Defendant joined in a conspiracy to violate laws prohibiting rape in the second degree 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 years of age Epstein and others who engaged in rape were over years old at the time of the incidents As a result of Defendants actions numerous minors suffered serious physical mental and emotional injury 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 Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of 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 I.C 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 V.I.C et seq COUNT FIITEEN Unlawful Sexual Contact in the First or Second Degree Violation of the Criminally Influenced and Corrupt Organization Act CICO V.I.C et seq and The Government restates and realleges paragraphs of this Complaint as if as if fully set forth herein At all times material herein each Defendant directly and indirectly participated in or associated with the Epstein Enterprise an illicit enterprise The Epstein Enterprise engaged in two or more occasions of conduct that constitutes 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 and years of age Epstein and others who engaged in the sexual contact were over years old at the time of the incidents As a result of the Epstein Enterprises actions numerous young women and minors suffered serious physical mental and emotional injury 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 Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of Defendants benefited directly and indirectly from the pattern of criminal activity conducted by the Epstein Enterprise 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 V.I.C et seq COUNT SIXTEEN Unlawful Sexual Contact in the First or Second Degree Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act et seq V.J and The Government restates and realleges paragraphs I of this Complaint as if as if fully set forth herein At all times material herein each Defendant joined in a conspiracy to violate laws prohibiting unlawful sexual contact 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 and years of age Epstein and others who engaged in the sexual contact were over years old at the time of the incidents As a result of Defendants actions numerous young women and minors suffered serious physical mental and emotional injury 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 minor girls and young women in knowing or reckless disregard of the laws of the U.S Virgin Islands Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of 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 V.l.C 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 V.I.C et seq COUNT SEVENTEEN Prostitution and Keeping House of Prostitution Violation of the Criminally Influenced and Corrupt Organizations Act CICO V.I.C et seq The Government restates and realleges paragraphs of this Complaint as if fully set forth herein At all times material herein each Defendant directly and indirectly participated in or associated with the Epstein Enterprise an illicit enterprise The Epstein Enterprise engaged in two or more occasions of conduct that constitutes 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 The Epstein Enterprise knowingly persuaded induced enticed and or coerced young women and children to travel to the Virgin Islands to engage in prostitution and/or sexual activity and/or attempted to do the same 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 Case Document Filed Page of GVI Estate of Jeffrey Epstein GVls Complaint Page of 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 young women and children to remain there for such purposes The Epstein Enterprise directed took transported and or offered or agreed to take or transport young 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 a signation The Epstein Enterprise knew or should reasonably have known that some of the individuals that were the subjects of the actions described in this Count were minors As a result of Defendants actions numerous young women and minor suffered serious physical mental and emotional injury 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 Defendants benefited directly and indirectly from the pattern of crimin a activity conducted by the Epstein Enterprise 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 I.C et seq Case Document Filed Page of GVI Estate of Jeffrey Epstein GVI Complaint Page of COUNT EIGHTEEN Prostitution and Keeping House of Prostitution Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act V.I.C et seq V.I.C The Government restates and realleges paragraph of this Complaint as if fully set forth herein At all times material herein each Defendant joined a conspiracy to laws against prostitution 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 young 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 pennitting Epsteins 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 an or pennitted young women and children to remain there for such purposes and directing taking transporting an or offering or agreeing to take or transport young 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 V.I.C and Defendants knew or should reasonably have known that some of the individuals that were the subjects of the actions described in this Count were minors As a result of Defendants actions numerous young women and minors suffered serious physical mental and emotional injury Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of 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 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 l.C 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 et COUNT Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of Epsteins violation SORPCA was part of a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise COUNT TWENTY Fraudulent Conveyance Violation of the Criminally Influenced and Corrupt Organizations Act CICO et seq V.I.C The Government restates and realleges paragraphs of this Complaint as if fully set forth herein At all times material herein each Defendant directly and indirectly participated in or associated with the Epstein Enterprise an illicit enterprise Each Defendant engaged in two or more occasions of conduct that constitutes 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 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 Trust At the time of these transfers Epstein had numerous actions pending against him related to his trafficking and sexual assaults seeking financial judgments Through these transfers Epstein and the Epstein Enterprise fraudulently removed property and effects beyond the jurisdiction of the probate court Epstein and the Epstein Enterprise were parties to the fraudulent conveyance of the property real or personal an or the interests or rights arising out of property contracts or conveyances of Epstein and the Epstein Enterprise Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of 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 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 Defendants benefited directly and indirectly from the pattern of criminal activity conducted by the Epstein Enterprise 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 V.I.C et seq COUNT TWENTY-ONE Fraudulent Conveyance Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act V.I.C et seq V.I.C The Government restates and realleges paragraphs I to of this Complaint as if fully set forth herein At all times material herein each Defendant joined in a conspiracy to commit fraudulent conveyances 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 Case Document Filed Page of GVI Estate of Jeffrey Epstein GVls Complaint Page44 of48 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 Trust At the time of this transfer Epstein had numerous actions pending against him related to his trafficking and sexual assaults seeking financial judgments Through this transfer Epstein and the Epstein Ente rprise fraudulently removed property and effects beyond the jurisdiction of the probate court 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 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 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 U.S Virgin Islands 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 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 V.I.C et seq Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of COUNT TWENTY-TWO Civil Conspiracy The Government restates and realleges paragraphs of this Complaint as if fully set forth herein Defendants acted in concert and joined with others to perform the wrongful acts identified in Counts to among others concealing the sexual abuse of minor females by unlawful means Each co-conspirator knew or in the exercise ofreasonable care should have known about the conduct of the others and about the common unlawful scheme 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 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 civ i conspiracy As a direct and proximate result of Defendants con piracy the Virgin Island has been injured Each co-conspirator is jointly and severally liable for the acts alleged herein Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of Notice of Allegation of PUNITIVE DAMAGES 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 This Complaint describes intentional conduct so egregious persistent and injurious that it shocks the conscience and offends a civilized society Punitive damages are especially important in the case of persons or companies that have money assets and power that mere fines penalties and economic damages are simply not sufficient 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 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 and other offenses related offenses and civil conspiracy Case Document Filed Page of GVI Estate of Jeffrey Epstein GVIs Complaint Page of Pursuant to V.I.C enforce and maintain the criminal activity liens the Government is filing contemporaneously with this lawsuit or shall file in connection with this action Pursuant to V.I.C a and V.I.C 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 within the territory of the U.S Virgin Islands 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 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 Pursuant to a require Defendants to divest themselves of any real property or other interests in favor of the Government of the Virgin Islands used to further the goals of the Epstein Enterprise Pursuant to V.I.C a and order the dissolution of the Epstein Enterprise including but not limited to order the dissolution of the corporate Defendants Pursuant to V.I.C a enter an injunction to prevent the further criminal conduct and concealment of the criminal conduct by the Epstein Enterprise I Pursuant to V.I.C a order the revocation of any and all licenses permits and approvals that had been granted by any agency of the Territory and require the repayment of any tax benefits that had been bestowed on any Defendant Pursuant to a award the Government the maximum civil penalty for each and every violation of law committed by the Epstein Enterprise Case Document Filed Page of GVI Estate of Jeffrey Epstein GVls Complaint Page of Pursuant to V.I.C award treble damages and all other available remedies including attorneys fees and costs Award compensatory and punitive damages for Defendants ivil conspiracy Void the transfer of assets as fraudulently conveyed to the The Trust Award such equitable relief including disgorgement of all ill-gotten gains as may be just and proper and appropriate pursuant to V.I.C to protect the rights of victims and innocent persons in the interest of justice and consistent with the purposes of CICO Assess and award a judgment in favor of the Government and against the Defendants for attorneys fees and costs and pre and post-judgment interest and Award any and all other relief this Court deems appropriate The Government demands a jury trial on all issues so triable Dated Januar RESPECTFULLY SUBMITTED GOVERNME OF THE UNITED STATES VIRGIN ISL ATTORNEY GENERAL I Department of Justice Office of the Attorney General Kronprindsens Gade GERS Building 2nd Floor St Thomas U.S.V.I Telephone
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