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Case 1:19-cv-10788-GHW-DCF Document 33-2 Filed 03/27/20 Page 1 of 55
EXHIBIT B
Case 1:19-cv-10788-GHW-DCF Document 33-2 Filed 03/27/20 Page 2 of 55
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS AND ST. JOHN
GOVERNMENT OF THE UNITED STATES
VIRGIN ISLANDS, Case No.:
PLAINTIFF,
ACTION FOR DAMAGES
V.
DARREN K. INDYKE, in his capacity as the JURY TRIAL DEMANDED
EXECUTOR FOR THE EST ATE OF JEFFREY E.
EPSTEIN and ADMINISTRATOR OF THE 1953
TRUST; RICHARD D. KAHN, in his capacity as
the EXECUTOR FOR THE EST ATE OF JEFFREY
E. EPSTEIN, and ADMINISTRATOR OF THE
1953 TRUST; ESTATE OF JEFFREY E. EPSTEIN,
THE 1953 TRUST, PLAN D, LLC; GREAT ST.
JIM, LLC; NAUTILUS, INC.; HYPERION AIR,
LLC; POPLAR, INC., SOUTHERN TRUST
COMPANY, INC.; JOHN AND JANE DOES
DEFENDANTS,
FIRST AMENDED COMPLAINT
COMES NOW, the Government of the United States Virgin Islands ("Governmenf') and
files this First Amended Complaint against the above-named Defendants and in support thereof,
would show unto the Court as follows:
JURISDICTION AND PARTIES
1. 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 3 V.I.C. § 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate
for the public interest, safety, health and well-being of persons in the Virgin Islands.
Case 1:19-cv-10788-GHW-DCF Document 33-2 Filed 03/27/20 Page 3 of 55
GVI v. Estate of Jeffrey Epstein
GVI'
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