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.

ESTATE OF JEFFREY E. EPSTEIN, THE 1953 JURY TRIAL DEMANDBD

TRUST, PLAN D, LLC; GREAT ST. JIM, LLC;
NAUTILUS, INC.; HYPERION AIR, LLC;
POPLAR, INC., JOHN AND JANE DOES
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DEFENDANTS, IS.
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17 I

COMPLAINT

COMES NOW, the Government ofthe United States Virgin Islands ("Govemmenf') and
files this Complaint against the above-named Defendants and in support thereof, would show unto
the Court as follows:

JURISDICTION AND PARTIES

1. The Attomey General ofthe United States Virgin Islands (herein after "Virgin
Islands )brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant
to 3V.I.C. § 114 and her statutory authority to enforce the laws ofthe Virgin Islands, and advocate
for the public interest, safety, health and well-being ofpersons in the Virgin Islands.
2. This Court has subject matter jurisdiction over this civil matter pursuant to 4 V.I.C.
§ 76 and 14 V.I.C. § 607.

3. This Court has personal jurisdiction over the parties pursuant to 5 V.I.C. §4903.