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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
the human trafficking allegations with Epstein. 63. In July 2013—several months after Staley left JP Morgan to join another financial institution—JP Morgan's Compliance Officer terminated JP Morgan's relationship with Epstein. 15 EFTA00145680 Case 1:22-cv-10904-JSR Document 119 Filed 04/12/23 Page 16 of 42 64. At the t
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
the human trafficking allegations with Epstein. 63. In July 2013—several months after Staley left JP Morgan to join another financial institution—JP Morgan's Compliance Officer terminated JP Morgan's relationship with Epstein. 64. At the time of Epstein's death in 2019, Staley was the Chief Executive Officer of Barclays;
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
the human trafficking allegations with Epstein. 63. In July 2013—several months after Staley left JP Morgan to join another financial institution—JP Morgan's Compliance Officer terminated JP Morgan's relationship with Epstein. 64. At the time of Epstein's death in 2019, Staley was the Chief Executive Officer of Barclays;
Entities connected to both the C.O.U.Q. Foundation and JP Morgan's Compliance Officer

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
Ghislaine Maxwell
PERSON
New York
LOCATIONJane Doe
PERSONJEGE, Inc.
ORGANIZATION
Les Wexner
PERSON
Glenn Dubin
PERSON
Eastern Europe
LOCATIONHyperion Air
ORGANIZATIONLarry Visoski
PERSON
Financial Trust Company
ORGANIZATIONHBRK Associates
ORGANIZATIONThe Government of the Virgin Islands
ORGANIZATIONthe Epstein Estate
ORGANIZATION
Financial Crimes Enforcement Network
ORGANIZATIONSecond Amended Complaint
ORGANIZATIONFFIEC
ORGANIZATIONOffice of the Comptroller of the Currency
ORGANIZATION