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29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to many other Epstein victims in order to maintain their immigration status and the
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
29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to marry other Epstein victims in order to maintain their immigration status and th
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
29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to many other Epstein victims in order to maintain their immigration status and the
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
Entities connected to both Second Amended Complaint and the C.O.U.Q. Foundation

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
Richard Kahn
PERSONJack Goldberger
PERSON
United States
LOCATION
New York
LOCATION
Les Wexner
PERSON
Bill Richardson
PERSONJEGE, Inc.
ORGANIZATION
U.S. Virgin Islands
LOCATION
Marc Rich
PERSON
Prince Charles
PERSON
Stephen Hawking
PERSON
Glenn Dubin
PERSON
Financial Trust Company
ORGANIZATION
JPMorgan Chase
ORGANIZATION
Palm Beach
LOCATION