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ter." 127. Before Staley, Epstein relied heavily on the massive wealth bestowed upon him primarily by one individual, Leslie (Les) Herbert Wexner ("Wexner"), to give him the appearance of grand importance while relying on his then-madame, Maxwell, to find and groom young women to be abused. 128. It h
Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 36 of 130 Epstein's international sex trafficking operation, most notably Ghislaine Maxwell, Les Wexner, Jean Luc Brunel, and Jes Staley, acting through and on behalf of JP Morgan. 139. In later years, Deutsche Bank swapped in for JP Morgan and provid
ive used the C.O.U.Q. Foundation account to pay $29,464.66 to three young women, including two known victims, and over $20,000 to a company called Phoenix Realty Home Inc. Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., Case No. 22-cv-10904-JSR, Amended Complaint (Dkt. 16) at 16-17 (S.D.N.
20,000 to a company called Phoenix Realty Home Inc. Similarly, Epstein and/or his representative used the Enhanced Education fund to pay $124,232 to Leslie Wexner and $15,000 to and . a firm owned by Epstein's reportedly prior girlfriend. 69. Each of these red flags was serious; together, they suggest a p
Enhanced Education fund to pay $124,232 to Leslie Wexner and $15,000 to and . a firm owned by Epstein's
tive used the C.O.U.Q. Foundation account to pay $29,464.66 to three young women, including two known victims, and over $20,000 to a company called Phoenix Realty Home Inc. Similarly, Epstein and/or his representative used the Enhanced Education fund to pay $124,232 to Leslie Wexner and $15,000 to and . a firm owned
20,000 to a company called Phoenix Realty Home Inc. Similarly, Epstein and/or his representative used the Enhanced Education fund to pay $124,232 to Leslie Wexner and $15,000 to and . a firm owned by Epstein's reportedly prior girlfriend. 69. Each of these red flags was serious; together, they suggest a p
Enhanced Education fund to pay $124,232 to Leslie Wexner and $15,000 to and . a firm owned by Epstein's
tive used the C.O.U.Q. Foundation account to pay $29,464.66 to three young women, including two known victims, and over $20,000 to a company called Phoenix Realty Home Inc. Similarly, Epstein and/or his representative used the Enhanced Education fund to pay $124,232 to Leslie Wexner and $15,000 to and . a firm owned
Entities connected to both Les Wexner and Phoenix Realty Home Inc.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
U.S. Virgin Islands
LOCATIONDarren Indyke
PERSON
Financial Trust Company
ORGANIZATION
New York
LOCATIONJane Doe
PERSON
United States
LOCATION
Palm Beach
LOCATION
Jean-Luc Brunel
PERSONLarry Visoski
PERSON
Richard Kahn
PERSONthe Southern District
LOCATION
Glenn Dubin
PERSONSouthern Trust Company
ORGANIZATION
Lesley Groff
PERSON
Prince Charles
PERSON
Jes Staley
PERSON
JPMorgan Chase
ORGANIZATIONHarry Beller
PERSON