Epstein Secrets

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

n in 2013. C. JP Morgan's Role in the Sex-Trafficking Venture 1. Banking laws and regulations exist to prevent funding of criminal ventures. 116. The Federal Bank Secrecy Act ("BSA") requires financial institutions 30 EFTA00162150 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 31 of 130 to have adequate anti-m

e Bank joined while it was on-going. Deutsche Bank ratified the earlier-committed acts of the conspiracy. This action is also timely under RICO and New York's Adult Survivors Act. 4 EFTA00161961 Case 1:22-cv-10018-JSR Document 42 Filed 01/13/23 Page 5 of 163 II. PARTIES 7. Jane Doe 1 is a United Stat

n addition to coercing commercial sex acts from his victims, Epstein also committed intentional torts and sexual offenses against them as defined in New York Penal Law § 130, as described in greater detail below. 117. From around 1998 through about July 2019, Epstein's sex-trafficking venture recruited,

al behavior in participating in Epstein's sex-trafficking venture. 2. Banking Regulations Exist to Help Prevent Funding of Criminal Ventures. 178. The Federal Bank Secrecy Act ("BSA") requires financial institutions to have adequate anti-money laundering ("AML") policies and systems in place. New York state law requires f

r that month, on January 22, 2015, in preparation for the ARRC meeting, EXECUTIVE-1 and RELATIONSHIP MANAGER-1 met in person with Mr. Epstein at his New York home. During the meeting, EXECUTIVE-1 asked Mr. Epstein about the veracity of the recent allegations and appeared to be satisfied by Mr. Epstein's r

institutions act as a critical line of defense against illegal financial transactions in an ever changing and interconnected financial network. 2. The Federal Bank Secrecy Act ("BSA") requires financial institutions to have adequate anti-money laundering ("AML") policies and systems in place. New York State law requires f