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Maxwell was also employed by several of Epstein's other entities, including. but not limited to, the C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC. JEGE Inc., and LSJ. LLC. 53. Upon inronnation and belief. the corporate organizational documents or these other ewhics .. . i.i..C: c.ith iTs
for NES. LLC. and never received a response. 52. Maxwell was also employed by several of Epstein's other entities, including. but not limited to, the C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC. JEGE Inc., and LSJ. LLC. 53. Upon inronnation and belief. the corporate organizational documents or these othe
ly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, LLC, NES, LLC, Plan D, LLC, Southern Financial, LLC, and Southern Trust Company. 28. Epstein used his wealth and power to create the Epstei
addition, Epstein and/or his representatives appeared to be misusing JP Morgan accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
Maxwell was also employed by several of Epstein's other entities, including. but not limited to, the C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC, JEGE Inc.. and LSJ, LLC. 53. Upon information and belief, the corporate organizational documents or these other entities pro% riy!,.. of indcz
s for NES. LLC. and never received a response. P. Maxwell was also employed by several of Epstein's other entities, including. but not limited to, the C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC, JEGE Inc.. and LSJ, LLC. 53. Upon information and belief, the corporate organizational documents or these othe
ly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, LLC, NES, LLC, Plan D, LLC, Southern Financial, LLC, and Southern Trust Company. 28. Epstein used his wealth and power to create the Epstei
CGLacs e. 22-1kod.-CIfia91143BRDOnntuantataa PDS EIC1O12/23 Page 11B aff ain accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
ly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, LLC, NES, LLC, Plan D, LLC, Southern Financial, LLC, and Southern Trust Company. 28. Epstein used his wealth and power to create the Epstei
EFTA00161851 Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 17 of 34 accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
Entities connected to both JEGE, Inc. and the C.O.U.Q. Foundation

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
JPMorgan Chase
ORGANIZATION
United States
LOCATIONLarry Visoski
PERSON
Richard Kahn
PERSONLeon Black
PERSON
Hyperion
ORGANIZATIONJane Doe
PERSON
Financial Trust Company
ORGANIZATIONJack Goldberger
PERSONSouthern Trust Company
ORGANIZATIONNew York Strategy Group
ORGANIZATIONHyperion Air
ORGANIZATION
Les Wexner
PERSON
Prince Charles
PERSON
Marc Rich
PERSONSouthern District
LOCATION
U.S. Virgin Islands
LOCATION