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ews reports contained in JP Morgan's due diligence reports-Epstein purchased at the age of 14. Like other women who received payments from Epstein, Jane Doe 1 listed Epstein's apartments on 66th Street in New York City as her address, which should have been a red flag to JP Morgan. 67. Epstein and/or his
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
uropean surnames who were publicly and internally identified as Epstein recruiters and/or victims. For example, Epstein paid more than $600,0000 to Jane Doe 1, a woman who—according to news reports contained in JP Morgan's due diligence reports-Epstein purchased at the age of 14. Like other women who recei
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
ife. Neither man has a public social media account, and both shun press interviews. But both could soon be questioned as part of a lawsuit filed by Jane Doe, who alleges she was 14 when Epstein and his former girlfriend, British socialite EFTA00163121 Ghislaine Maxwell, began to groom and sexually abu
ent for this article, has been an executive with Epstein's shadowy nonprofits since at least 2007. That year, Kahn replaced Maxwell as treasurer of the C.O.U.Q. Foundation and held the role until the charity dissolved five years later. C.O.U.Q. contributed $46 million in stock and other assets to Wexner's YLK Charita
ife. Neither man has a public social media account, and both shun press interviews. But both could soon be questioned as part of a lawsuit filed by Jane Doe, who alleges she was 14 when Epstein and his former girlfriend, British socialite EFTA01654939 Ghislaine Maxwell, began to groom and sexually abu
ent for this article, has been an executive with Epstein's shadowy nonprofits since at least 2007. That year, Kahn replaced Maxwell as treasurer of the C.O.U.Q. Foundation and held the role until the charity dissolved five years later. C.O.U.Q. contributed $46 million in stock and other assets to Wexner's YLK Charita
of 18 U.S.C. §§ 1591(a)(1) & (a)(2) by aiding, abetting, and inducing Epstein's and his conspirators sex-trafficking venture and sex trafficking of Jane Doe 1, as well as other Class Members. As a consequence, Jane Doe 1, as well as other members of the Class, are victims of JP Morgan's criminally aiding,
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
Entities connected to both Jane Doe and the C.O.U.Q. Foundation

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONLeon Black
PERSONSouthern District
LOCATION
Sarah Kellen
PERSON
Palm Beach
LOCATION
New York
LOCATION
Marc Rich
PERSON
U.S. Virgin Islands
LOCATION
Southern District of New York
ORGANIZATIONDarren Indyke
PERSON
Les Wexner
PERSON
Bill Richardson
PERSON
Lesley Groff
PERSON
Stephen Hawking
PERSONLarry Visoski
PERSON
Prince Charles
PERSON