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2020.07.13_Exhibit_A

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 I THE SUPERIOR COURf
 OF THE VIRGIN ISLANDS



  FILED
 July 13, 2020

 TAMARA CHARLES
CLERK OF TIIE COURT




                         EXHIBIT A
                                                                                                 ,.,·.




                   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 ESTATE OF JEFFREY E.
 EPSTEIN and ADMINISTRATOR OF THE 1953
 TRUST; RICHARD D. KAHN, in his capacity as
 the EXECUTOR FOR THE ESTATE OF JEFFREY
 E. EPSTEIN, and ADMINISTRATOR OF THE
 1953 TRUST; ESTATE OF JEFFREY E. EPSTEIN,
 THE 1953 TRUST, PLAN D, LLC; OREAT 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 ("Government") 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.
GVI v. Estate of Jeffrey Epstein
GVl's First Amended Complaint
Page 2 of 55

         2.    This Court has s

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