Latest / The Epstein Chronicles / New Mexico's Lawsuit Filed Against Epstein Executors Darren Indyke And Richard Kahn (Part 7) (10/24/26)

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New Mexico's Lawsuit Filed Against Epstein Executors Darren Indyke And Richard Kahn (Part 7) (10/24/26) · The Epstein Chronicles

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  Speaker 1: What's up everyone and welcome to another episode of the
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  Speaker 1: Epstein Chronicles. In this episode, we're going to dive right
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  Speaker 1: back in to the New Mexico lawsuit filed against Indycan Khan.
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  Speaker 1: Count 3. Violation of New Mexico Racketeering Act. New Mexico
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  Speaker 1: Statute 30-42-4C. Criminal Solicitation. The state of New Mexico restates
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  Speaker 1: and re-alleges the foregoing paragraphs of this complaint as if
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  Speaker 1: fully set forth herein. At all times, material herein defend
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  Speaker 1: an indict in Kahn and Epstein, each directly and indirectly
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  Speaker 1: participated in or associated with the Epstein enterprise and illicit
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  Speaker 1: association in fact. The purpose of the New Mexico Racketeering
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  Speaker 1: Act is to eliminate the infiltration and illegal acquisition of
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  Speaker 1: a legitimate economic enterprise by racketeering practices and the use
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  Speaker 1: of legal and illegal enterprises to further criminal activities. Under
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  Speaker 1: the Act, racketeering means any act that's chargeable or indictable
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  Speaker 1: under the laws of New Mexico and punishable by imprisonment
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  Speaker 1: of more than a year, involving one or a set
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  Speaker 1: of enumerated offenses. One of the enumerated acts is criminal solicitation,
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  Speaker 1: as defined by N.M. Statute 30-28-3. Each defendant named herein
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  Speaker 1: is a distinct person capable of holding a legal or
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  Speaker 1: beneficial interest in property. New Mexico Statute 30-42-3B. The Epstein
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  Speaker 1: Enterprise was an enterprise within the meaning of New Mexico
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  Speaker 1: Statute 30-42-3C, which includes a group of persons associated in fact,
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  Speaker 1: though not a legal entity, and includes illicit as well
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  Speaker 1: as illicit entities. Each of these defendants have benefited directly
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  Speaker 1: or indirectly from a pattern of racketeering activity in which
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  Speaker 1: each of the defendants participated to establish and operate the enterprise.
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  Speaker 1: that engaged in a pattern and practice of criminal solicitation
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  Speaker 1: and violation of the New Mexico Racketeering Act. The Epstein
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  Speaker 1: Enterprise functioned to provide wealthy, powerful men access, opportunity, and
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  Speaker 1: privacy to engage in illicit activities involving the sexual abuse, transportation, restraining,
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  Speaker 1: or confinement of Epstein survivors. Members of the Epstein Enterprise solicited, recruited, transported, provided, isolated, maintained,
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  Speaker 1: and entice girls and young women, in the furtherance of
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  Speaker 1: the performance of sex trafficking and sexual abuse, either of
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  Speaker 1: minors or through deception, intimidation, or force. In furtherance of
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  Speaker 1: those crimes, the Epstein enterprise engaged in two or more
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  Speaker 1: occasions of conduct that constitutes criminal predicate acts, as defined
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  Speaker 1: by the Racketeering Act. As part of this pattern of
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  Speaker 1: racketeering activity, defendants Indyk and Kahn each engaged in criminal
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  Speaker 1: solicitation in violation of New Mexico law, by intending that
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  Speaker 1: another person engage in conduct constituting a felony, soliciting, commanding, requesting, inducing, employing,
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  Speaker 1: or otherwise attempting to promote or facilitate that other person's
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  Speaker 1: engagement in conduct constituting a felony, either within or without
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  Speaker 1: the State of New Mexico. Specifically, defendant Indyk and Kahn
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  Speaker 1: each managed and arranged for funds that were used to
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  Speaker 1: promote or facilitate another member of the Epstein enterprise. to recruit, solicit, entice, transport, confine, restrain,
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  Speaker 1: or obtain by any means girls and young women to
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  Speaker 1: Zorro Ranch with the intent or knowledge that force, intimidation,
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  Speaker 1: or deception would be used to inflict sexual offense on
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  Speaker 1: the victim. Recruit, solicit, entice, transport, or obtain by any
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  Speaker 1: means girls and young women under the age of 18
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  Speaker 1: years to Zorro Ranch with the intent or knowledge that
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  Speaker 1: the girls and young women would be caused to have
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  Speaker 1: sexual offense inflicted on them, and benefit financially or by
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  Speaker 1: receiving anything of value from the labor, services, or commercial
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  Speaker 1: sexual activity of girls and young women being transported, confined,
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  Speaker 1: or restrained at Zorro Ranch with knowledge of the illegal activity.
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  Speaker 1: Indyk and Kahn each threw a pattern of criminal activity,
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  Speaker 1: acquired and maintained for himself directly or indirectly, an interest
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  Speaker 1: in or control of the Epstein Enterprise or real property.
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  Speaker 1: In Deich and Kahn, each benefited directly and indirectly from
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  Speaker 1: the pattern of criminal activity conducted by Epstein's enterprise. The
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  Speaker 1: Epstein enterprise derived substantial benefit from the criminal solicitation described above,
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  Speaker 1: through which Epstein's network of influential people and personal fortune
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  Speaker 1: were maintained and expanded. The pattern of criminal solicitation was
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  Speaker 1: not isolated, but was related to and conducted through the
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  Speaker 1: affairs of the Epstein enterprise in willful violation of of
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  Speaker 1: the Racketeering Act. Each of these defendants' wrongful actions and
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  Speaker 1: inactions directly and proximately caused injury to the girls and
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  Speaker 1: young women who were trafficked, abused, coerced, held against their will,
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  Speaker 1: and solicited through the Epstein Enterprise. In addition, the state
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  Speaker 1: brings this count pursuant to New Mexico Statute 30-42-6B on
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  Speaker 1: behalf of the people injured by the pattern of racketeering
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  Speaker 1: activity in New Mexico and to prevent, restrain, and remedy
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  Speaker 1: the racketeering activity and its effects. The State of New
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  Speaker 1: Mexico restates and re-alleges the foregoing paragraphs of this complaint,
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  Speaker 1: as if fully set forth herein, in Dike and Kahn
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  Speaker 1: each agreed by words or acts with Epstein, Maxwell, and
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  Speaker 1: other members of the Epstein Enterprise to conduct or participate
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  Speaker 1: directly or indirectly in the affairs of of the Enterprise
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  Speaker 1: through a pattern of racketeering activity, including kidnapping and criminal
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  Speaker 1: solicitation described in other allegations in the complaint. Endike and
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  Speaker 1: Kahn each knew that the Enterprise's purpose included recruiting, transporting, intimidating, misleading,
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  Speaker 1: and sexually abusing girls and young women, and each intended
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  Speaker 1: that Epstein's Enterprise members would commit predicate acts in furtherance
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  Speaker 1: of that purpose. In furtherance of that agreement, Indyk and
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  Speaker 1: Kahn each perform the acts described in the complaint, including
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  Speaker 1: making cash available from Epstein's accounts used to pay girls
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  Speaker 1: and young women and structuring cash withdrawals to avoid currency
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  Speaker 1: transaction reporting. Under New Mexico Statute 30-42-4D, a conspirator need
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  Speaker 1: not personally have committed or agreed to commit two predicate acts,
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  Speaker 1: and each conspirator is responsible for criminal acts of co-conspirators
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  Speaker 1: committed in furtherance of the conspiracy. each of the defendants
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  Speaker 1: in Daikin-Kan and Epstein's estate, individual wrongful actions and inactions
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  Speaker 1: directly and proximately caused injury to the girls and young
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  Speaker 1: women who were trafficked, abused, coerced, held against their will,
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  Speaker 1: and solicited through the Epstein enterprise. In addition, the state
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  Speaker 1: brings the count pursuant to New Mexico Statute 30-42-6B on
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  Speaker 1: behalf of people injured by the conspiracy to commit racketeering
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  Speaker 1: activity in New Mexico and to prevent, restrain, and remedy
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  Speaker 1: the the racketeering activity and its effects. Count number five,
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  Speaker 1: equitable recovery under principles of restitution and unjust enrichment. The
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  Speaker 1: state of New Mexico restates and re-alleges the foregoing paragraph
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  Speaker 1: of this complaint as if fully set forth herein. As
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  Speaker 1: direct and proximate result, the defendant in Dyken Kahn and
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  Speaker 1: Epstein's participation in the Epstein enterprise, which is engaged in
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  Speaker 1: sex trafficking of underage girls and young women, each of
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  Speaker 1: these defendants has been unjustly enriched. By virtue of positions
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  Speaker 1: defendant Indyke and Kahn held in corporate entities registered and
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  Speaker 1: doing business in New Mexico, they benefited from the laws
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  Speaker 1: and regulations governing the creation and operation of such entities
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  Speaker 1: and granting the privilege to engage in business within the state.
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  Speaker 1: The court should find that defendants have been unjustifiably enriched
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  Speaker 1: and order defendants to disgorge all money received as a
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  Speaker 1: result of their unlawful business practice. The court should also
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  Speaker 1: order restitution based on defendant Indyk and Kahn's individual participation
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  Speaker 1: in racketeering activities and trafficking venture. Punitive Damages The purpose
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  Speaker 1: of punitive damages in the common law is to punish
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  Speaker 1: a defendant for conduct that is malicious, wanton, oppressive, or
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  Speaker 1: fraudulent to deter others from engaging in such conduct in
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  Speaker 1: the future. This complaint describes intentional conduct so egregious, persistent,
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  Speaker 1: and injurious that it shocks the conscience. and defends a
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  Speaker 1: civilized society. Punitive damages are especially important in the case
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  Speaker 1: of persons or companies that have so much money, asset,
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  Speaker 1: and power that mere fines, penalties, and economic damages are
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  Speaker 1: simply not sufficient. At all times material herein, defendant Indyk
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  Speaker 1: and Kahn and Epstein engage repeatedly in wrongful acts that
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  Speaker 1: were intentional and outrageous. The state gives notice that it
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  Speaker 1: intends to pursue the possibility of punitive damages in any
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  Speaker 1: jury verdict. Prayer for Relief. Wherefore, the State of New Mexico,
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  Speaker 1: by and through its Attorney General, respectfully requests that the
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  Speaker 1: Court grant the following relief. Enter a judgment in favor
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  Speaker 1: of the State and against defendants on all counts. Declare
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  Speaker 1: that defendants, in Dykin-Kahn and Epstein, through the Epstein Enterprise,
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  Speaker 1: have engaged in a pattern of criminal activity in violation
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  Speaker 1: of the Racketeering Act. Pursuant to the New Mexico Statute 30-4261,
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  Speaker 1: order defendants to divest themselves of of any real property
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  Speaker 1: or other interest in the Epstein Enterprise in favor of
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  Speaker 1: the State of New Mexico on behalf of persons injured
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  Speaker 1: by the Epstein Enterprise. Pursuant to New Mexico Statute 3042-62
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  Speaker 1: impose reasonable restrictions on the future activities. or investments of
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  Speaker 1: all defendants named herein. Pursuant to New Mexico Statute 30-42-64,
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  Speaker 1: award three times the damages to those injured by defendants racketeering.
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  Speaker 1: Pursuant to New Mexico Statute 30-42-6D-5, order the payment of
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  Speaker 1: all costs and expenses of the State of New Mexico
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  Speaker 1: in connection with the investigation and prosecution of the activity
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  Speaker 1: complained of herein, including attorney fees and costs. Pursuant to U.S.
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  Speaker 1: Code 18 Section 1595, award appropriate relief including compensatory and
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  Speaker 1: punitive damages to those injured by defendants, disgorgement to those
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  Speaker 1: injured by defendants, restitution attorney fees, and other equitable relief
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  Speaker 1: as appropriate, pursuant to New Mexico Statute 30-42-6C and U.S.
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  Speaker 1: Code 18 Section 1595D, issue an order preventing the co-executors
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  Speaker 1: of defendant Epstein's estate from making distributions from the Epstein
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  Speaker 1: estate during the pendency of this litigation, and to maintain
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  Speaker 1: the status quo while the State of New Mexico's claims
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  Speaker 1: are heard. Award such equitable relief is including disgorgement of
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  Speaker 1: all ill-gotten gains in favor of those injured by defendants,
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  Speaker 1: as may be just and proper and appropriate to protect
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  Speaker 1: the rights of survivors and innocent persons in the interest
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  Speaker 1: of justice, assess and award a judgment in favor of
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  Speaker 1: the state and against defendants for attorney fees and costs
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  Speaker 1: in pre- and post-judgment interests, and award any and all
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  Speaker 1: other relief this court deems appropriate, the state demands a
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  Speaker 1: jury trial on all issues so triable. This was dated
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  Speaker 1: October 21st, 2026, and it was signed by Raul Torres.
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  Speaker 1: All the information that goes with this episode can be
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  Speaker 1: found in the description box.