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180. Defendant Maple, Inc. acquired ownership of the property 9 East 71st Street in New York, New York on or about December 23, 2011, shortly after Maple was formed. Maple acquired ownership of the property from Nine East 71st Street Corporation, which was owned by Epstein. 181. Defendant Laurel, I
d and did not include any expenses related to the Palm Beach property in the total expenses it reported to the Government. 193. Neither Cypress's, Maple's, nor Laurel's financial statements ever reflected the reality of the above assets held or the above expenses incurred by each entity. 194. The Ann
lected the reality of the above assets held or the above expenses incurred by each entity. 194. The Annual Reports submitted on behalf of Cypress, Maple, and Laurel all were signed by Epstein and Defendant and Co-Executor Kahn with the representation that "ALL STATEMENTS CONTAINED IN THIS APPLICATIO
GREED. 10 EFTA00162372 O2taaa22222ettleD29214SERRCiThitarmanit+261I2 Plagttelnothfl .113 /s/ Linda Singer LINDA SINGER Admitted Pro Hac Vice Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 232-5504 [email protected] Dated: January 9, 2023 SO ORDERED. Dated: New
lected the reality of the above assets held or the above expenses incurred by each entity. 194. The Annual Reports submitted on behalf of Cypress, Maple, and Laurel all were signed by Epstein and Defendant and Co-Executor Kahn with the representation that "ALL STATEMENTS CONTAINED IN THIS APPLICATIO
180. Defendant Maple, Inc. acquired ownership of the property 9 East 71st Street in New York, New York on or about December 23, 2011, shortly after Maple was formed. Maple acquired ownership of the property from Nine East 71st Street Corporation, which was owned by Epstein. 181. Defendant Laurel, I
d and did not include any expenses related to the Palm Beach property in the total expenses it reported to the Government. 193. Neither Cypress's, Maple's, nor Laurel's financial statements ever reflected the reality of the above assets held or the above expenses incurred by each entity. 194. The Ann
o triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David I. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 849-4962 [email protected] CAROL THOMAS-JACOBS (NYS Bar #2941300) Admit
e criminal predicate acts as defined by CICO, including but not limited to making fraudulent claims upon the Government. 411. Defendants Cypress, Maple, and Laurel misrepresented the values of their assets held and expenses incurred in their annual reporting to the Government of the United States V
10 EFTA00161956 Gbase11222€6140002143$33R MeauneettlE62 F(rli£dcDQ11DP.VZ3 Flaajgethottill /s/ Linda Singer LINDA SINGER Admitted Pro Hac Vice Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 232-5504 [email protected] Dated: January 9, 2023 SO ORDERED. Dated: New
Entities connected to both Marla Maples and Motley Rice

Jeffrey Epstein
PERSON
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Donald Trump
PERSON
Condoleezza Rice
PERSON
New York City
LOCATIONDarren Indyke
PERSON
U.S. Virgin Islands
LOCATION
Prince Charles
PERSON
Apple
ORGANIZATION
New York
LOCATION
Richard Kahn
PERSON
Julie K. Brown
PERSONthe Consumer Financial Protection Bureau
ORGANIZATION
Department of Justice
ORGANIZATIONAce Greenberg
PERSON
Virginia Giuffre
PERSON
Paul Ryan
PERSON