Latest / The Vault: The Epstein Files / New Mexico's Lawsuit Filed Against Epstein Executors Darren Indyke And Richard Kahn (Part 2) (10/22/26)

Transcript

New Mexico's Lawsuit Filed Against Epstein Executors Darren Indyke And Richard Kahn (Part 2) (10/22/26) · The Vault: The Epstein Files

• 0:00
  Speaker 1: What's up everyone and welcome to another episode of the
• 0:03
  Speaker 1: Epstein Chronicles. In this episode, we're going to dive right
• 0:06
  Speaker 1: back into the lawsuit filed by New Mexico against Indykin Khan.
• 0:12
  Speaker 1: Factual Allegations A. Epstein's Estate and the 1953 Trust Epstein
• 0:19
  Speaker 1: was found dead on August 10, 2019, while in custody
• 0:22
  Speaker 1: in New York on federal sex trafficking charges. Two days earlier,
• 0:27
  Speaker 1: on August 8, 2019, Epstein had both amended and restated
• 0:31
  Speaker 1: the terms of the 1953 trust and also signed his
• 0:35
  Speaker 1: last will and testament. Epstein transferred all his property, real
• 0:39
  Speaker 1: and personal, wherever situated, to the 1953 trust, which contains
• 0:44
  Speaker 1: Epstein's financial assets. The 1953 trust is financially liable for
• 0:49
  Speaker 1: the acts committed by Epstein and by the Epstein Enterprise
• 0:52
  Speaker 1: description below. Probate proceedings related to Epstein's will and assets
• 0:57
  Speaker 1: are currently pending and in the U.S. Virgin Islands. As
• 1:00
  Speaker 1: of August 15, 2019, when Indykin Khan filed the petition
• 1:05
  Speaker 1: for probate of Epstein's estate, the estate was valued at $ 577, 672, 654,
• 1:09
  Speaker 1: including 10,000 shares of Cypress Incorporated, which held the title
• 1:19
  Speaker 1: Tesoro Ranch Property. The estate's value has diminished significantly. As
• 1:25
  Speaker 1: of the public accounting filed in the probate proceeding, For
• 1:27
  Speaker 1: the period ending June 30, 2026, the estate is currently
• 1:31
  Speaker 1: valued at over $ 107 million. Per the terms of the
• 1:35
  Speaker 1: 1953 trust, the balance of the estate will be distributed
• 1:40
  Speaker 1: to Epstein's beneficiaries, including bequests to Indyke and Kahn of
• 1:44
  Speaker 1: $ 50 million and $ 25 million from the estate respectively, assuming
• 1:48
  Speaker 1: availability of funds. B. Epstein's M.O. The Epstein enterprise preyed
• 1:54
  Speaker 1: on girls and young women who were vulnerable to because
• 1:58
  Speaker 1: they sought financial, educational, or career opportunities and support. Either
• 2:03
  Speaker 1: Epstein himself or enterprise associates, often Ghislaine Maxwell, would assure
• 2:07
  Speaker 1: the survivor that accepting an invitation to meet or stay
• 2:11
  Speaker 1: with Epstein would help them in this regard. Once at
• 2:14
  Speaker 1: the property and isolated from the outside world, Epstein or
• 2:17
  Speaker 1: an associate would instruct or encourage the survivor to give
• 2:21
  Speaker 1: Epstein a massage, suggesting that this was normal and that
• 2:24
  Speaker 1: she would benefit monetarily or otherwise. for the service. However,
• 2:29
  Speaker 1: once drawn in, survivors were pressured and forced to engage
• 2:33
  Speaker 1: in sexual acts. As detailed in Epstein's sex trafficking indictment,
• 2:37
  Speaker 1: a common pattern or practice was as follows. Epstein would
• 2:41
  Speaker 1: typically be naked while the girl or young woman giving
• 2:44
  Speaker 1: him a massage was nude or only partially clothed. During
• 2:48
  Speaker 1: the massage, Epstein would masturbate and sexually abuse her, with
• 2:52
  Speaker 1: the abuse at times escalating to rape. These massages and
• 2:56
  Speaker 1: assaults could be as frequent as three times a day,
• 2:59
  Speaker 1: with Epstein receiving a massage from or sexually assaulting the
• 3:03
  Speaker 1: same or different girls or young women over the course
• 3:06
  Speaker 1: of a single day. Following these encounters, Epstein would often
• 3:09
  Speaker 1: pay the girl or young woman who provided the massage
• 3:12
  Speaker 1: a few hundred dollars. Epstein would also pay a few
• 3:15
  Speaker 1: hundred dollars to a girl or young woman who recruited
• 3:19
  Speaker 1: additional friends and who would require massages from these new
• 3:22
  Speaker 1: girls or young women and also sexually assault them. To
• 3:26
  Speaker 1: pay for these massages and new recruits, Epstein required a
• 3:29
  Speaker 1: steady stream of cash, which Indyk and Kahn made available
• 3:33
  Speaker 1: from Epstein's accounts. Indeed, between 2002 and 2013, Epstein or
• 3:39
  Speaker 1: others acting on his behalf withdrew over $ 6 million in
• 3:43
  Speaker 1: cash from his bank accounts, an average amount of $ 1, 700
• 3:46
  Speaker 1: per day. Even between 2013 and 2017, after Epstein had
• 3:47
  Speaker 1: pled guilty for sexual offense, and registered as a sex offender,
• 3:56
  Speaker 1: Indyk alone withdrew over $ 200, 000 per year, an average of
• 4:01
  Speaker 1: over $ 500 per day, in cash from Epstein's accounts at
• 4:04
  Speaker 1: a single bank. Indyk repeatedly asked bankers at Deutsche Bank
• 4:09
  Speaker 1: how he could withdraw cash from Epstein's accounts without triggering
• 4:12
  Speaker 1: an alert with the government, leading the bank to formally
• 4:15
  Speaker 1: exit its relationship with Epstein in December of 2018. C.
• 4:18
  Speaker 1: The Epstein Enterprise From at least 1997 through Epstein's death
• 4:25
  Speaker 1: in August of 2019, the Epstein Enterprise was an ongoing association,
• 4:30
  Speaker 1: in fact, comprised of Epstein, Maxwell, Indyk, Kahn, Jean-Luc Brunel,
• 4:35
  Speaker 1: Epstein's personal assistants, household staff at the Zorro Ranch, and
• 4:39
  Speaker 1: other Epstein properties, pilots, and others who facilitated or knowingly
• 4:44
  Speaker 1: participated in the targeting, recruitment, transportation, confinement, and sexual exploitation
• 4:50
  Speaker 1: of vulnerable girls and young women who for Epstein's personal gratification,
• 4:54
  Speaker 1: and trafficking by him to other wealthy, influential men. The
• 4:59
  Speaker 1: identities of many of those wealthy, influential men remain unknown today.
• 5:04
  Speaker 1: The enterprise was ongoing, association in fact, with a common
• 5:08
  Speaker 1: purpose and a division of labor, and its members functioned
• 5:11
  Speaker 1: as a continuing unit from at least 1997 through August 2019.
• 5:17
  Speaker 1: As indicated above, the Epstein enterprise included members who were
• 5:20
  Speaker 1: not named, as defendants in this action. Epstein led the
• 5:25
  Speaker 1: enterprise and made its principal decisions even though no formal
• 5:28
  Speaker 1: corporate structure existed. These decisions included which girls and young
• 5:32
  Speaker 1: women would be transported to him or other prominent men,
• 5:36
  Speaker 1: what properties they'd be transported to, how survivors would be transported, paid, controlled,
• 5:42
  Speaker 1: and silenced, and whether to engineer corporate entities and relationships
• 5:46
  Speaker 1: or financial transactions to facilitate the abuse and trafficking. The
• 5:52
  Speaker 1: informal members of the Epstein Enterprise performed functions within parameters
• 5:56
  Speaker 1: set by Epstein. Enterprise members identified girls and young women
• 6:00
  Speaker 1: who could be targeted by Epstein, helped make them more
• 6:03
  Speaker 1: receptive to his advances, and delivered false promises of educational, career,
• 6:08
  Speaker 1: or financial assistance as ordered or approved by Epstein. Maxwell
• 6:14
  Speaker 1: served as one of the Enterprise's principal recruiters and facilitators
• 6:18
  Speaker 1: and together with Epstein participated directly in in the abuse
• 6:21
  Speaker 1: of survivors at Zorro Ranch and other properties. Travel coordinators
• 6:26
  Speaker 1: arranged commercial and private flights to Zorro Ranch and other properties.
• 6:31
  Speaker 1: Household staff and personal assistants maintained the properties where survivors
• 6:35
  Speaker 1: were isolated and abused. Indyke and Kahn each made cash
• 6:39
  Speaker 1: available from Epstein's accounts so he could pay survivors and
• 6:43
  Speaker 1: from these accounts, also arranged direct payments to or purchases
• 6:47
  Speaker 1: of goods, and services for survivors. Enterprise members at times
• 6:54
  Speaker 1: used the terms massage and work as code for sexual abuse.
• 6:59
  Speaker 1: In Daikin-Kan, we're in the middle of the functioning of
• 7:02
  Speaker 1: the Epstein enterprise and provided more than ordinary legal and
• 7:05
  Speaker 1: accounting services, though their professional services each helped manage the
• 7:10
  Speaker 1: money that fueled the enterprise's operations and the Epstein-related corporate
• 7:14
  Speaker 1: entities used to shield the transactions from outside scrutiny and suspicion.
• 7:20
  Speaker 1: Indyk served as Epstein's personal attorney from approximately 1995 or
• 7:25
  Speaker 1: 1996 until Epstein's death. He served as an officer and
• 7:29
  Speaker 1: director of several Epstein-related entities, including Cypress Incorporated and Zorro
• 7:35
  Speaker 1: Development Corporation. He handled the transfer of the title to
• 7:38
  Speaker 1: Zorro Ranch to Cypress Incorporated by special warranty deed dated
• 7:43
  Speaker 1: December 19, 2011, and he provided corporate financial management for
• 7:48
  Speaker 1: Zorro Ranch and Epstein's other properties. Kahn served as Epstein's
• 7:52
  Speaker 1: accountant for approximately 2005 or 2006 until Epstein's death. He
• 7:58
  Speaker 1: served as treasurer and director of Cypress Incorporated, was a
• 8:01
  Speaker 1: member of HBRK Associates, a financial administrative hub for Epstein's properties,
• 8:07
  Speaker 1: and was involved in the daily financial and personal decisions
• 8:10
  Speaker 1: for Epstein's residential properties, including Zorro Ranch. Publicly available material
• 8:16
  Speaker 1: is suggests that there was no legitimate source for Epstein's
• 8:19
  Speaker 1: income and wealth, and that his wealth over time was
• 8:23
  Speaker 1: amassed through a series of fraud, lies, and schemes, a
• 8:26
  Speaker 1: fact that would have been known to Indyk and Kahn,
• 8:29
  Speaker 1: and would have further confirmed that Epstein's enterprise purpose, activities,
• 8:32
  Speaker 1: and revenue were tied to sex trafficking. Indyk and Kahn
• 8:36
  Speaker 1: were compensated for these roles. Indyk and Kahn also performed
• 8:41
  Speaker 1: the enterprise's financial functions. They arranged payments to survivors to
• 8:45
  Speaker 1: purchase their silence, and leave them indebted to Epstein, handled
• 8:48
  Speaker 1: costs for expenses connected to the abuse, monitored survivors' spending,
• 8:53
  Speaker 1: and prepared tax returns for some survivors. The enterprise operated
• 8:57
  Speaker 1: through corporate entities that Epstein owned and controlled and managed,
• 9:01
  Speaker 1: including Zorro Trust, Zorro Development Corporation, Darren K. Indyke PLLC,
• 9:06
  Speaker 1: HBRK Associates, Little St. James LLC, Cypress Incorporated, and Zorro
• 9:12
  Speaker 1: Management LLC. These entities were Vehicles, for Epstein's affairs, separate
• 9:17
  Speaker 1: from Epstein's enterprise itself. They held titles to properties, paid
• 9:21
  Speaker 1: staff and contractors, held bank accounts, used for payments connected
• 9:25
  Speaker 1: to the enterprise, and moved funds and properties among one
• 9:28
  Speaker 1: another to shield assets and control Epstein's activities. Zorro Trust
• 9:33
  Speaker 1: was founded as an Ohio-based trust on March 1, 1993,
• 9:37
  Speaker 1: and served as the original holding entity for Zorro Ranch
• 9:41
  Speaker 1: upon its purchase, with Epstein as a trustee. Thorough Development
• 9:45
  Speaker 1: Corporation is or was a foreign profit corporation registered in
• 9:49
  Speaker 1: New Mexico, but incorporated in Delaware. Indyke served as its
• 9:53
  Speaker 1: secretary and was a signatory on its bank account between
• 9:56
  Speaker 1: December 20, 2016 and July 8, 2009. corporation was created to
• 10:02
  Speaker 1: manage and operate Zorro Ranch. It was registered at the
• 10:06
  Speaker 1: ranch's address, 49 Zorro Ranch Road, Stanley, New Mexico, 87056,
• 10:10
  Speaker 1: and employed or contracted with individuals who worked at or
• 10:15
  Speaker 1: for Zorro Ranch. Zorro Ranch Development Court made payments to
• 10:20
  Speaker 1: New Mexico massage therapist Jane Doe II, who provided Epstein
• 10:24
  Speaker 1: massages at Zorro Ranch and was sexually assaulted by Epstein there.
• 10:29
  Speaker 1: Darren K. Indyke, PLLC, is or was a professional limited
• 10:32
  Speaker 1: liability company established by Indyke, through which he provided overall
• 10:37
  Speaker 1: corporate financial management of Epstein's properties, including Zorro Ranch. HBRK
• 10:42
  Speaker 1: Associates is or was a legal entity comprised of Epstein's accountants,
• 10:47
  Speaker 1: Kahn and Harry Beller, HBRK served as a financial and
• 10:51
  Speaker 1: administrative hub for Epstein's properties, including Zorro Ranch, and Epstein
• 10:56
  Speaker 1: was its sole client. Cypress Incorporated is or was a
• 11:00
  Speaker 1: Virgin Islands corporation that held title to Zorro Ranch at
• 11:03
  Speaker 1: the time of Epstein's death. Epstein served as its president
• 11:07
  Speaker 1: and director. Indyke served as its vice president, secretary, and director,
• 11:12
  Speaker 1: and Kahn served as its treasurer and director. Cypress Incorporated
• 11:16
  Speaker 1: also leased adjacent state lands. Zorro Management LLC is or
• 11:20
  Speaker 1: was an entity registered in the U.S. Virgin Islands with
• 11:24
  Speaker 1: an associated Deutsche Bank account on which Epstein and Indyk
• 11:27
  Speaker 1: were signatories. The enterprise continued for more than two decades,
• 11:32
  Speaker 1: from at least 1997 through August of 2019. Flight records
• 11:37
  Speaker 1: reflect that girls and young women traveled to Zorro Ranch
• 11:40
  Speaker 1: between 1997 and 2018, either with Epstein or through arrangements
• 11:45
  Speaker 1: made by the enterprise. Epstein regularly created new entities, often
• 11:50
  Speaker 1: with Indyk or Khan as officers or directors, and transferred
• 11:53
  Speaker 1: properties and funds among them to shield assets and conceal
• 11:57
  Speaker 1: the Enterprise's activities. These changes in entity did not alter
• 12:02
  Speaker 1: the Enterprise's purpose or function. Epstein continued to direct its affairs,
• 12:07
  Speaker 1: and Indyk and Khan continued to perform their roles throughout.
• 12:11
  Speaker 1: The Enterprise derived substantial benefit from its activities by using
• 12:14
  Speaker 1: survivors to cultivate, and retain relationships with wealthy, powerful, and
• 12:19
  Speaker 1: influential business associates. It provided those associates with access, opportunity,
• 12:24
  Speaker 1: and privacy to engage in illicit activity involving the abuse, transportation, restraint,
• 12:29
  Speaker 1: and confinement of survivors. For example, in or about 2011
• 12:34
  Speaker 1: or 2012, Epstein instructed a survivor to provide a massage
• 12:39
  Speaker 1: to Jess Daly, then head of JPMC's private bank and
• 12:42
  Speaker 1: asset management division. who helped keep Epstein's accounts active despite
• 12:46
  Speaker 1: internal concerns about illicit activity and shared non-public information with Epstein.
• 12:52
  Speaker 1: During the massage, Staley forced the survivor to touch his
• 12:55
  Speaker 1: genitals and then raped her. Defendant Indyk and Kahn are
• 13:00
  Speaker 1: distinct from Enterprise, which also consisted of Epstein-Maxwell personal assistants, recruiters,
• 13:05
  Speaker 1: staff pilots, and other individuals and used corporate entities as
• 13:09
  Speaker 1: vehicles for its affairs. Indyk knowingly associated with the Enterprise.
• 13:15
  Speaker 1: He held positions and performed functions that gave him some
• 13:18
  Speaker 1: part in directing the Enterprise's affairs and conducted or participated
• 13:22
  Speaker 1: directly or indirectly in those affairs through the pattern of
• 13:26
  Speaker 1: racketeering activity alleged in this complaint. Furthermore, Indyk acted with
• 13:30
  Speaker 1: specific intent of conducting the Enterprise affairs. Khan knowingly associated
• 13:36
  Speaker 1: with the Enterprise. He held a position, performed functions that
• 13:40
  Speaker 1: gave him some part in directing the Epstein Enterprises Affairs,
• 13:43
  Speaker 1: and conducted or participated directly or indirectly in those affairs
• 13:47
  Speaker 1: through the pattern of racketeering activity alleged C-INFRA. Kahn acted
• 13:52
  Speaker 1: with the specific intent to conduct the Enterprises Affairs. Members
• 13:57
  Speaker 1: of the Epstein Enterprises knowingly used means of force, threats
• 14:00
  Speaker 1: of force, fraud, and coercion to subject girls and young
• 14:03
  Speaker 1: women to engage in sex acts at his New Mexico ranch.
• 14:08
  Speaker 1: The harm to survivors and was both foreseeable and deeply damaging.
• 14:13
  Speaker 1: During his deposition under oath regarding his activities, Epstein repeatedly
• 14:16
  Speaker 1: invoked his Fifth Amendment privilege against self-incrimination when asked questions
• 14:21
  Speaker 1: regarding whether he had engaged in sexual acts with underage
• 14:24
  Speaker 1: females and procured underage females for prostitution. Evidence of Epstein's
• 14:29
  Speaker 1: trafficking and sexual abuse with the assistance of the Epstein
• 14:33
  Speaker 1: enterprise is nonetheless clear. Alright folks, we're going to wrap
• 14:36
  Speaker 1: up right here. And in the next episode dealing with
• 14:39
  Speaker 1: the topic, we're going to pick up with D, Zorro Ranch.
• 14:42
  Speaker 1: All the information that goes with this episode can be
• 14:45
  Speaker 1: found in the description box.