GVI v. Estate of Jeffrey Epstein

GVI’s Second Amended Complaint

Page 40 of 76

200. Defendants used Epstein’s businesses and ostensibly charitable foundations in

the Virgin Islands to make payments to the victims who were trafficked and sexually abused

while concealing these payments from detection by law enforcement authorities.

201. Defendants also prevented Epstein Enterprise entity employees from cooperating

with law enforcement by requiring them to sign confidentiality and non-disclosure agreements.

202. Defendants also actively obstructed law enforcement by denying investigators

access to Little St. James beyond its boat dock.

203. 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 their fraud on the Government in obtaining unearned

tax benefits by providing false testimony and submitting false and inaccurate reporting to the

Economic Development Commission to prevent detection of Defendant Southern Trust

Company’s non-compliance with requirements concerning the nature of its business and the

residency of the persons it employed.

207. The discovery of the nature, scope, and magnitude of Defendants’ unlawful

conduct and could not have been acquired earlier through the exercise of reasonable diligence.