Epstein Secrets

fficking conspiracy and led Jane Doe I, as well as other Class Members, to believe that they would be rewarded if they cooperated and acquiesced to Epstein's coercive demands. 380. JP Morgan's affirmative conduct was committed knowingly, and in reckless disregard of the facts, that Epstein would use ca

e 2 at m 3 Fraud and Deceptive Business Practices Act. 3. This action stems from an enforcement action the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey Epstein ("Epstein"), under the Virgin Islands' Criminally Influenced and C

was that, although the Bank properly classified Mr. Epstein as high-risk, the Bank failed to scrutinize the a

ction the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and var

ction the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and vari

t (July 22, 2010), https://www.thedailybeast.com/jeffrey-epstein-pedophile-billionaire-and-his-sex-den. 10 EFTA0

conspiracy's knowledge extended to the names of Epstein's victims, because Epstein and his co-conspirators knew the names of the victims, including Jane Doe l's name. JP Morgan, through its officer Jes Staley, also new many of the names of the victims. 445. JP Morgan conspired to violate 18 U.S.C. § 1591(a)

(Ex. C.) During the interview, Jane Doe 2 again denied being involved in or a victim of any criminal activity and made statements meant to exculpate Jeffrey Epstein. (See id.) Jane Doe 2 also informed me and the FBI agents who were present that she "hope[d] . . . nothing happens to [Epstein] because he's an awes

Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 4 of 176 individuals who had been identified as potential victims of Epstein, but whom the investigative team had not yet interviewed and had not necessarily determined were in fact victims of a federal offense or came under

acuum. We have read many infiruntriatory remarks the Town of Palm Bewail Police Chief has made to the media about the state court's handling of the Jeffrey. Epstein investigation. The polkachief s remarks frighten both myself and my client. Tam aware that the town police have prepared dc•cuments to char

aid. 14 15 16 you write that? 17 A. Yes. 18 Q. 19 A. 20 informed that it was a deposition. 21 22 about what happened when you went to Jeff Epstein's house Q. You wrote in this exhibit, "I got some stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't Referring to this deposition, didn't you?

ey Epstein, including "[Jane Doe 2] never touched Mr. Epstein in a sexual way and Mr. Epstein never touched [J

2008, informing Jane Doc 1 and Jane Doe 2 that the case was still under investigation and that it could be a lengthy process (Ex. J) were accurate. Jane Doe l's re- interview was part of that continued investigation, so no one was deceived. The process was not lengthier only because Epstein ultimately entere

ereinafter referred to collected as "Deutsche Bank"), participating in and financially benefitting from their direct and intentional involvement in Jeffrey Epstein's sex-trafficking venture by providing the financial lifeblood and infrastructure for the venture's continued operation. Deutsche Bank knowingly bene

ank knowingly benefited and received things of value for assisting, supporting, facilitating, and otherwise providing the most critical tool for the Jeffrey Epstein sex-trafficking organization to successfully rape, sexually assault, and coercively sex traffic Plaintiff and the numerous other members of

ngly benefited and received things of value for assisting, supporting, facilitating, and otherwise providing the most critical tool for the Jeffrey Epstein sex-trafficking organization to successfully rape, sexually assault, and coercively sex traffic Plaintiff and the numerous other members of the clas

pliance, Americas, reiterated the ARRC's decision in an email to other executives, stating that ARRC had agreed to "continue business as usual with Jeff Epstein" based upon Packard's "due diligence [bar] visit with him." Deutsche Bank knew, and was acting in reckless disregard of the fact, that Epstein's 65

f Florida found that some of the victims "went to Mr. Epstein's house only once, some went there as much as 10

-trafficking venture had—and continue to possess-tremendous wealth and power and have demonstrated a clear ability to cause her serious harm. 10. Jane Doe l's safety, right to privacy, and security outweigh the public interest in her identification. 11. Jane Doe l's legitimate concerns outweigh any preju

of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen

ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00040739 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit

re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls

ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori

a standard CVRA victim notification letter.' The notification letter promised that the Justice Department would make its "best efforts" to protect Jane Doe l's rights, including "the reasonable right to confer with the attorney for the United States in the case" and " to be reasonably heard at any public pr

of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen

ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00081333 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit

re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls

ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori

a standard CVRA victim notification letter.' The notification letter promised that the Justice Department would make its "best efforts" to protect Jane Doe l's rights, including "the reasonable right to confer with the attorney for the United States in the case" and " to be reasonably heard at any public pr

of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen

ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00083566 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit

re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls

ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori

a standard CVRA victim notification letter.' The notification letter promised that the Justice Department would make its "best efforts" to protect Jane Doe l's rights, including "the reasonable right to confer with the attorney for the United States in the case" and " to be reasonably heard at any public pr

of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen

ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00098414 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit

re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls

ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori

a standard CVRA victim notification letter.' The notification letter promised that the Justice Department would make its "best efforts" to protect Jane Doe l's rights, including "the reasonable right to confer with the attorney for the United States in the case" and " to be reasonably heard at any public pr

EGE OF LAW Wilfredo A. Ferrer U.S. Attorney for the Southern District of Florida U.S. Attorney's Office 99 N.E. 4th Street Miami, FL 33132 Re: Jeffrey Epstein's Sexual Assault Victims in Jane Does 1 & 2 v. United States Dear Mr. Ferrer: My co-counsel, Brad Edwards, and I are writing with a simple request: T

Since 2007, this has been the position of your Office. Indeed, in 2007-08, your Office extracted hundreds of thousands of dollars in payments from Epstein based on representations that these girls were "victims" of his crimes. Recently, however, attorneys in your Office have suggested that these girls

Office 99 N.E. 4th Street Miami, FL 33132 Re: Jeffrey Epstein's Sexual Assault Victims in Jane Does 1 &

tein to determine whether a decision to prosecute Mr. Epstein for federal criminal violations would contradict

ut her concerns regarding the handling of the Epstein case. Without going into the details of that meeting, it was certainly our understanding - and Jane Doe l's - that you were going to try help her and do something about her situation. She asked you during that meeting if there was any further information

of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen

ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00794122 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit

re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls

ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori

a standard CVRA victim notification letter.' The notification letter promised that the Justice Department would make its "best efforts" to protect Jane Doe l's rights, including "the reasonable right to confer with the attorney for the United States in the case" and " to be reasonably heard at any public pr

.Y. CPLR §214-j. The suit arises from Defendant JP Morgan Chase Bank, N.A.'s (hereinafter "JP Morgan") participation and intentional involvement in Jeffrey Epstein's widespread and well-publicized sex-trafficking operation, as well as the direct financial benefits it received therefrom. JP Morgan knew that it wa

ficking operation, as well as the direct financial benefits it received therefrom. JP Morgan knew that it was providing the financial lifeblood for Epstein's 1 EFTA00162121 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 2 of 130 international sex-trafficking organization from 1998 through Au

n") participation and intentional involvement in Jeffrey Epstein's widespread and well-publicized sex-traf

horities found that some of the victims "went to Mr. Epstein's house only once, some went there as much as 10

Filed 01/13/23 Page 5 of 130 continue to possess—tremendous wealth and power and have demonstrated a clear ability to cause her serious harm. 10. Jane Doe l's safety, right to privacy, and security outweigh the public interest in her identification. 11. Jane Doe l's legitimate concerns outweigh any preju