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; GREAT 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 authorityto enforce the laws ofthe Virgin Islands, and advocate

for the public interest, safety, healthand well-being of persons in the Virgin Islands.