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ge 2 of 34 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
n 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 Corrupt Organizations Act ("CICO Act"), see Government of the U.S. Virgin Islands v. Indyke e
exual activity, and/or attempted to do the same. EFTA00161929 Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 61 of 77 GVI v. Estate of Jeffrey Epstein GV1's Second Amended Complaint Page 60 of 76 338. The Epstein Enterprise kept, maintained, and/or permitted his property at Little St. James to be used
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
h other relief as the Court deems appropriate. JURY DEMAND The Government demands a jury trial on all issues so triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David I. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washingto
s Consumer 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
n 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 Corrupt Organizations Act ("CICO Act"), see Government of the U.S. Virgin Islands v. Indyke e
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
was that, although the Bank properly classified Mr. Epstein as high-risk, the Bank failed to scrutinize the a
such other relief as the Court deems appropriate. JURY DEMAND The Government demands a jury trial on all issues so triable. Dated: April 3, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Isl Linda Singer Linda Singer (pro hac vice) Mimi Liu (pro hac vice) David I. Ackerman Paige Boggs (pro hac vice)
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
h other relief as the Court deems appropriate. JURY DEMAND The Government demands a jury trial on all issues so triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David 1. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washingto
Entities connected to both Jeffrey Epstein and CAROL THOMAS-JACOBS

Richard Kahn
PERSONDarren Indyke
PERSONLarry Visoski
PERSON
Ghislaine Maxwell
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LOCATION
JPMorgan Chase
ORGANIZATION
Condoleezza Rice
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Glenn Dubin
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Jes Staley
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PERSONSouthern District
LOCATIONJane Doe
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LOCATIONSouthern Trust Company
ORGANIZATIONHBRK Associates
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Palm Beach
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Les Wexner
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