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ated the laws against sex trafficking. This action is also timely because the conspiracy continued until recently. This action is also timely under New York's Adult Survivor's Act, N.Y. CPLR § 214-j. II. PARTIES 7. Jane Doe 1 is a U.S. citizen and was at all relevant times a resident of and domiciled in
as 2012, a JP Morgan subsidiary company assisted with transporting certain Epstein sex-trafficking victims by private jet from Florida to Epstein in New York. 177. Ultimately, JP Morgan financially benefited by earning millions of dollars for its participation in the Epstein sex-trafficking venture. 178
19-JSR Document 36 Filed 01/13/23 Page 72 of 130 and the identities of the individual Class members are ascertainable through records maintained by the Epstein Estate and JP Morgan, including but not limited to JP Morgan's records for Epstein-related accounts (e.g., account ledgers reflecting payments from Epstei
he itemized receipts for the 2016 and 2018 donations, Kahn's occupation is listed as "attorney." He's never been registered, however, as a lawyer in New York state. EFTA00163136
e the federal judge overseeing the case and indicated Indyke would be deposed "in both his personal capacity and as a co- EFTA00163123 executor of the Epstein Estate," and would "offer extremely relevant testimony" relating to her claims. "Indeed, we have reason to believe he has firsthand knowledge of Jeffrey
ttached hereto, appoints Petitioners as Executors of the Estate. 3) The Decedent, Jeffrey E. Epstein, died testate on August 10, 2019 in New York, New York, and was domiciled in and a resident of St. Thomas, Virgin Islands at the time of his death, as supported by the copy of Certificate of Death attach
e order." V.I. R. CIV. P. Rule 24(b)(2). Specifically, the Government is a rightful participant in any program designed to distribute the assets of the Epstein Estate because of its interest in the assets and disposition of the 2 In full, Rule 24 (a)(2) reads: -On a timely motion, the court must permit anyone to i
akoff at the United States District Court for the Southern District of New York, Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York, NY, 10007 to determine whether: (1) the proposed settlement (the "Settlement") of the above captioned case ("Litigation") as set forth in the Stipu
voted years of her career to advocating on behalf of survivors of Jeffrey Epstein, including in cases against Prince Andrew, Ghislaine Maxwell, and the Epstein Estate. Ms. McCawley was recognized by Forbes Magazine for her "iron clad interrogation skills" during the deposition of Ghislaine Maxwell. Her work contri
he itemized receipts for the 2016 and 2018 donations, Kahn's occupation is listed as "attorney." He's never been registered, however, as a lawyer in New York state. EFTA01654954
e the federal judge overseeing the case and indicated Indyke would be deposed "in both his personal capacity and as a co- EFTA01654941 executor of the Epstein Estate," and would "offer extremely relevant testimony" relating to her claims. "Indeed, we have reason to believe he has firsthand knowledge of Jeffrey
dyke and Kahn signed company checks for combined value of almost $300,000 made out personally to young women or to, again, the immigration lawyer in New York who was involved in one or more forced marriages arranged among Epstein's victims to secure a victim's immigration status. 96. Upon information an
of Epstein's Enterprise, including the receiving and sending money to other entities they held. 117. Since they were appointed as Co-Executors of the Epstein Estate in 2019, Defendants Indyke and Kahn have approved the release of Estate funds to pay for the legal fees and costs of persons who—like the Co-Execut
dyke and Kahn signed company checks for combined value of almost $300,000 made out personally to young women or to, again, the immigration lawyer in New York who was involved in one or more forced marriages arranged among Epstein's victims to secure a victim's immigration status. 96. Upon information an
of Epstein's Enterprise, including the receiving and sending money to other entities they held. 117. Since they were appointed as Co-Executors of the Epstein Estate in 2019, Defendants Indyke and Kahn have approved the release of Estate funds to pay for the legal fees and costs of persons who—like the Co-Execut
Entities connected to both New York and the Epstein Estate

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONLeon Black
PERSON
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSONDarren Indyke
PERSON
U.S. Virgin Islands
LOCATION
Prince Charles
PERSON
Bradley Edwards
PERSON
Palm Beach
LOCATION
Lesley Groff
PERSONMaria Farmer
PERSON
Les Wexner
PERSON