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I~ THE SUPERIOR COURT
OF THE VIRGIN ISLANDS
FILED
March 17, 2022 06:09 eM
ST-2021-RV-OOOOS
TAMARA CHARLES
CLERK OF THE COURT
Government Exhibit 1
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS AND ST. JOHN
********************************
GOVERNMENT OF THE UNITED STATES
VIRGIN ISLANDS, Case No.: ST-20-CV-14
PLAINTIFF,
ACTION FOR DAMAGES
V.
JURY TRIAL DEMANDED
DARREN K. INDYKE, in his individual capacity
and in his capacity as the EXECUTOR FOR THE
ESTATE OF JEFFREY E. EPSTEIN and
ADMINISTRATOR OF THE 1953 TRUST;
RICHARD D. KAHN, in his individual capacity and
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; GREAT ST. JIM, LLC;
NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR,
Inc.; SOUTHERN TRUST COMPANY, INC.;
CYPRESS, INC.; MAPLE, INC.; LAUREL, INC.;
AND JOHN AND JANE DOES,
DEFENDANTS.
__________________________________________
SECOND AMENDED COMPLAINT
COMES NOW, the Government of the United States Virgin Islands ("Government") and
files this Second Amended Complaint containing information that has become known through
further investigation and third-party discovery 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
GVI v. Estate of Jeffrey Epstein
GVI’s Second Amended Complaint
Page 2 of 76
to 3 V.I.C.
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