Here's what I got from pasting redacted sections into google docs with the file Kahpi mentioned
In November 2017, Indyke signed a Foundation check made payable to the
immigration lawyer in New York who was involved in one or more forced marriages arranged
among Epstein’s victims to secure a victim’s immigration status. The check’s memo line
references the former Russian model’s last name.87. These payments were inconsistent with the charitable
Defendants Indyke and Kahn participated with Epstein in coercing his sex
trafficking victims, in at least three cases, to enter into arranged and forced marriages in order to
obtain immigration status for the foreign women so that they could continue to be available to
Epstein for his abuse – a doubly-deep assault on their will and dignity. Defendant Kahn
provided a letter of reference for at least one immigration application and tax services to the
spouses, and Defendant Indyke paid the immigration lawyer who applied for citizenship for the
women and threatened at least one who indicated that she would seek a divorce. They used
their professional skills and authority to carry out this abhorrent scheme.
79. Indyke and Kahn were, in short, the indispensable captains of Epstein’s criminal
enterprise, roles for which they were richly rewarded.
80. Defendants Kahn and Indyke controlled and directed the activities of the other
entities and personal bank accounts of Epstein accounts after they were funded. One, and
frequently both, of them were officers or directors of Butterfly Trust; of companies holding
Epstein’s real property (as laid out below); and of Financial Strategy Group, Ltd.; Financial
Trust, Inc.; FT Real Estate Inc.; Gratitude America, Inc.; Hyperion Air, Inc.; J. Epstein Virgin
-Islands Foundation, Inc.; Jeepers, Inc.; Mort, Inc.; Nautilus, Inc.; and Zorro Development
Corporation; among others.
81. Along with their officer and director roles, Defendants Kahn and/or Indyke also
had signatory authority over virtually all of the accounts held by the Epstein Enterprise entities,
As of October 23, 2007, Indyke was listed as President of the Foundation. He
■ also was a signatory on the Foundation’s checking accounts.
85. Between September 2015 and June 2019, Indyke signed Foundation account
checks for over $400,000 made payable to young female models and actresses, including a
former Russian model who received over $380,000 through monthly payments of $8,333 made
over a period of more than three and a half years until the middle of 2019.
GVI v. Estate of Jeffrey Epstein
GVI’s Second Amended Complaint
86. In November 2017, Indyke signed a Foundation check made payable to the
immigration lawyer in New York who was involved in one or more forced marriages arranged
among Epstein’s victims to secure a victim’s immigration status. The check’s memo line
references the former Russian model’s last name.87. These payments were inconsistent with the charitable purpose of the Foundation
and designed to serve the private benefit and criminal activities of Epstein and the Epstein
88. Earlier in 2017, Indyke signed a Foundation check for $160,000 to resolve a fine
Epstein had incurred for construction on Great St. James Island that violated Virgin Islands
environmental regulations and attempted to make the payment appear to be a charitable
donation. Over two years later, the Estate had to repay this amount to the Foundation after
questions were raised to Epstein’s lawyer about the propriety of the Foundation payment.
89. With help from Indyke and Kahn, Epstein established and operated separate
businesses through which he could pay victims and recruiters, and, upon information and belief,
which he used to maintain their immigration status.
90. JSC Interiors, LLC is a New York Limited Liability Company, the Articles of
Organization of which were filed in November 2014. The Articles list JSC, who was forced and
• coerced to have sex with Epstein, as the company’s sole owner. JSC was manipulated,
• exploited, and controlled by the Epstein Enterprise.
91. According to JSC’s operating agreement, Kahn was to be the initial Manager of
the company, with full and complete authority, power, and discretion to do all things necessary
or convenient to manage, control, and carry out the business. Kahn also had signatory authority
GVI v. Estate of Jeffrey Epstein
GVI’s Second Amended Complaint
92. One of JSC’s bank accounts was funded entirely with money transferred from
Epstein’s personal bank accounts.
93. JSC’s payroll was paid to two persons, one of whom was the listed sole owner.
Kahn gave conflicting reports to JSC’s bank about the second person on the company’s payroll
and the reasons for its payments to her. Once, he described her as an interior designer, which
would justify the payments in light of JSC’s purported line of business, but which appears to
have been false. The other time, Kahn described this payroll recipient as a dentist, which would
-not justify JSC Interiors’ payments to her, but which appears to be true.
94. LSJE, LLC is a Virgin Islands Limited Liability Company that was organized on
October 27, 2011. Defendants Indyke and Kahn were authorized signatories on the company’s
95. Indyke and Kahn signed company checks for combined value of almost
Indyke made wire transfers from another of Epstein’s personal accounts with a
different bank totaling almost $50,000 between November 2016 and July 2019 (just before
-Epstein’s arrest) to women with Eastern European surnames, including one known to have
recruited young women and girls for Epstein.
GVI v. Estate of Jeffrey Epstein
GVI’s Second Amended Complaint
110. From another of Epstein’s personal accounts with another different bank, for
which Indyke had signatory authority, someone acting on Epstein’s behalf made a total of 21
separate withdrawals each in the amount of $1,000 on every but one business day from April 9,
111. Payments from this account totaling almost $60,000 were transferred by wire to
young women mostly at foreign beneficiary banks in February and March 2016.
112. Upon information and belief, based on their authority for the accounts, their
interactions with the relevant banks, and records indicating that they made or approved the
transactions, these payments could have only been made with the knowledge and/or at the
direction of Indyke and Kahn.
113. The sheer complexity of the infrastructure that Epstein set up and maintained
with the participation of Kahn and Indyke suggest their unlawful purpose. Based on the
Government’s current knowledge, Epstein, with Kahn and Indyke, held and managed at least
140 different bank accounts for Epstein and Epstein-owned entities, many of which existed only
to transfer payments to other entities and accounts.
114. Kahn and Indyke profited substantially from their relationship with Epstein.
The amount of their payments is further evidence of the illicit nature of the work they
115. From 2011 to 2019, Epstein and Epstein-owned entities paid over $16 million
- net to Defendant/Co-Executor Indyke, and over $10 million net to Defendant/Co-Executor
■ Kahn. This includes loans that are still outstanding to Indyke- and Kahn-related entities. Based
on records obtained so far, tax forms provided by Epstein entities did not report nearly the full
compensation to Indyke and Kahn.
Financial records more recently obtained show that the employee described
above whom Kahn represented to be, alternatively, an interior designer and a dentist, was also a GVI v. Estate of Jeffrey Epstein
GVI’s Second Amended Complaint
paid employee of Southern Trust Company, which did not actually or even pretend to perform
either interior design or dentistry services, in 2019.
164. During several time periods, Southern Trust Company a
For instance, Cypress’s Balance Sheet as of December 31, 2018 did not reflect
any assets other than cash of $18,824. Further, Cypress reported only $301 in expenses for the
year ended December 31, 2018, despite it paying $106,394.60 in Santa Fe property taxes on
185. Similarly, in 2017, Cypress reported as its only asset cash in the amount of
$29,736 and expenses of $150, despite it paying $55,770.41 and $113,679.56 in Santa Fe
property taxes during 2017.
186. Similarly, for the tax years 2011 through 2016, Cypress did not include the value
of the New Mexico property in the total assets it reported and did not include any expenses
related to the New Mexico property in the total expenses it reported to the Government.
187. Likewise, Maple’s balance sheet as of December 31, 2018 did not reflect any
assets other than cash of $21,265. Further, Maple reported only $300 in expenses for the year
ended December 31, 2018, despite it paying $336,471.87 in New York City property taxes
-GVI v. Estate of Jeffrey Epstein
GVI’s Second Amended Complaint
188. Similarly, in 2017, Maple reported as its only asset cash in the amount of
$18,281 and expenses of $150, despite it paying $327,497.48 and $6,487.04 in New York City
property taxes during 2017.
189. Similarly, for the tax years 2011 through 2016, Maple did not include the value
Similarly, for the tax years 2011 through 2016, Maple did not include the value
of the New York property in the total assets it reported and did not include any expenses related
to the New York property in the total expenses it reported to the Government.
190. Likewise, Laurel’s balance sheet as of December 31, 2018 did not reflect any
assets other than cash in the amount of $20,155. Further, Laurel reported only $300 in expenses
for the year ended December 31, 2018, despite it paying $196,673.56 in Palm Beach property
taxes on November 6, 2018.
191. Similarly, in 2017, Laurel reported as its only asset cash in the amount of
$37,129 and expenses of $150, despite it paying $191,941.52 in Palm Beach property taxes on
192. Similarly, for the tax years 2011 through 2016, Laurel did not include the value
Defendants also attempted to conceal their criminal sex trafficking and abuse
conduct by paying large sums of money to participant-witnesses, including by paying for their
attorneys’ fees and case costs in litigation related to this conduct.
204. Epstein also threatened harm to victims and helped release damaging stories
about them to damage their credibility when they tried to go public with their stories of being
trafficked and sexually abused.
205. Epstein also instructed one or more Epstein Enterprise participant-witnesses to
destroy evidence relevant to ongoing court proceedings involving Defendants’ criminal sex
trafficking and abuse conduct.
206. Defendants also concealed
Every time someone gives more information, I could fully kiss you. Thank you thank you THANK you.
