Case 1:19-cv-08673-KPF-DCF Document 52-1 Filed 02/14/20 Page 1 of 49 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. AND ST. JOHN GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, Case No.: PLAINTIFF, ACTION FOR DAMAGES V. ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, INC., JOHN AND JANE DOES JURY TRIAL DEMANDy3 DEFENDANTS, COMPLAINT COMES NOW, the Government of the United States Virgin Islands ("Government") 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 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 authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of persons 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. EFTA02751158