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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
icking venture and conspiracy. 18 EFTA00161975 Case 1:22-cv-10018-JSR Document 42 Filed 01/13/23 Page 19 of 163 69. Epstein's relationship with James "Jes" Staley was a key alliance that enabled Epstein to run his illegal operation through JP Morgan. 70. Staley and JP Morgan built the financial infrastructur
.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
d coercion (making it clear that if she did not abide then she would suffer serious financial and reputational harm), through the end of 2013. 115. James "Jes" Staley ("Staley"), the then-head of JP Morgan's private banking division, was a regular visitor of Epstein's during that period of time, through and beyon
tioned the fitness of a prospective hire. More recently, Barclays said that UK authorities are investigating Staley's ties to sex offender, the late Jeffrey Epstein. Please comment on these two incidents involving the chief executive of Barclays and if the bank thinks his actions have an impact on the robustnes
g Staley's ties to sex offender, the late Jeffrey Epstein. Please comment on these two incidents involving
stigating Staley's ties to sex offender, the late Jeffrey Epstein. Please comment on these two incidents i
clays' culture by the bank's compliance employee. BARCLAYS CHIEF EXECUTIVE JAMES STALEY'S COMPLIANCE IMPROPRIETIES 26. Barclays new chief executive James "Jes" Staley was rebuked and personally fined for trying to unmask the authors of two anonymous letters received by Barclays that questioned the fitness of a pr
Entities connected to both Jeffrey Epstein and James "Jes" Staley

Lesley Groff
PERSON
Marc Rich
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
JPMorgan Chase
ORGANIZATION
Jes Staley
PERSON
Sarah Kellen
PERSON
Department of Justice
ORGANIZATION
Jean-Luc Brunel
PERSON
New York
LOCATIONFBI
ORGANIZATIONNadia Marcinkova
PERSON
Southern District of New York
ORGANIZATIONthe State of New York
LOCATION
FinCEN
ORGANIZATION
Eastern Europe
LOCATIONthe Federal Rules of Civil
ORGANIZATIONthe New York Stock Exchange
ORGANIZATIONJane Doe l's
PERSONThe Federal Bank Secrecy Act
ORGANIZATION