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les this Complaint against JPMorgan Chase Bank, N.A. ("JP Morgan") for violations of Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A
fficked and abused during different intervals between at least 2003 and July 2019, when 3 Conchita Samoff, Jeffrey Epstein Pedophile Billionaire and His Sex Den, The Daily Beast (July 22, 2010), https://www.thedailybeast.com/jeffrey-epstein-pedophile-billionaire-and-his-sex-den. 10 EFTA00145675 Case 1:22
les this Complaint against JPMorgan Chase Bank, N.A. ("JP Morgan") for violations of Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A
five Epstein-related accounts collectively worth hundreds of millions of dollars. 42. 3 Conchita Samoff, Jeffrey Epstein Pedophile Billionaire and His Sex Den, The Daily Beast (July 22, 2010), https://www.thedailybeast.com/jeffrey-epstein-pedophile-billionaire-and-his-sex-den. 10 EFTA00162261 CEtas e.
les this Complaint against JPMorgan Chase Bank, N.A. ("JP Morgan") for violations of Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A
five Epstein-related accounts collectively worth hundreds of millions of dollars. 42. 3 Conchita Samoff, Jeffrey Epstein Pedophile Billionaire and His Sex Den, The Daily Beast (July 22, 2010), https://www.thedailybeast.com/jeffrey-epstein-pedophile-billionaire-and-his-sex-den. 10 EFTA00161845 Case 1:22
Entities connected to both the Virgin Islands Criminally and His Sex Den

Glenn Dubin
PERSON
Condoleezza Rice
PERSON
Financial Trust Company
ORGANIZATIONEnhanced Education
ORGANIZATIONVirgin Islands Department of Justice
ORGANIZATIONHBRK Associates
ORGANIZATION
Hyperion
ORGANIZATIONHyperion Air
ORGANIZATIONJEGE, Inc.
ORGANIZATION
Financial Crimes Enforcement Network
ORGANIZATIONOffice of the Comptroller of the Currency
ORGANIZATIONConchita Samoff
PERSONThe Government of the Virgin Islands
ORGANIZATIONthe U.S. Department of
ORGANIZATION
Palm Beach
LOCATION
United States
LOCATIONSecond Amended Complaint
ORGANIZATIONFFIEC
ORGANIZATIONSouthern Trust Company
ORGANIZATIONCoatue Enterprises
ORGANIZATION