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

d coercion (making it clear that if she did not abide then she would suffer serious financial and reputational harm), through the end of 2013. 115. James "Jes" Staley ("Staley"), the then-head of JP Morgan's private banking division, was a regular visitor of Epstein's during that period of time, through and beyon

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,

icking venture and conspiracy. 18 EFTA00161975 Case 1:22-cv-10018-JSR Document 42 Filed 01/13/23 Page 19 of 163 69. Epstein's relationship with James "Jes" Staley was a key alliance that enabled Epstein to run his illegal operation through JP Morgan. 70. Staley and JP Morgan built the financial infrastructur

Bank reported $4.2 million going through Barclays accounts in Monaco and Botswana, and through correspondent banking accounts with Barclays Bank in New York, according to a look-back SARs filed with FinCEN. These funds have been identified as part of the bribery of Olympics officials. 46. Why was Barcla

clays' culture by the bank's compliance employee. BARCLAYS CHIEF EXECUTIVE JAMES STALEY'S COMPLIANCE IMPROPRIETIES 26. Barclays new chief executive James "Jes" Staley was rebuked and personally fined for trying to unmask the authors of two anonymous letters received by Barclays that questioned the fitness of a pr