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stein. The co-conspirators who benefitted 107 EFTA00162227 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 108 of 130 financially include Ghislaine Maxwell, Lesley Grog Sarah Kellen, Adriana Ross, and Nadia Marcinkova. 412. Acting through its officers and employees (including Staley), JP Morgan itself
co-conspirator, Ghislaine Maxwell, for conspiracy to entice minor victims to travel to be abused by Epstein. The federal criminal investigation of Maxwell included investigation of possible 122 EFTA00162242 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 123 of 130 violations of the TVPA. 4
led 01/13/23 Page 108 of 130 financially include Ghislaine Maxwell, Lesley Grog Sarah Kellen, Adriana Ross,
ndicted Epstein (and unnamed "associates") for violating the TVPA. Later, on about June 29, 2020, the same Office indicted Epstein's co-conspirator, Ghislaine Maxwell, for conspiracy to entice minor victims to travel to be abused by Epstein. The federal criminal investigation of Maxwell included investigation of p
ations 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 V.I.C. §§ 301 to 336, and in support thereof alleges
EFTA00073262 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 4 of 14 • (a) All currently sealed documents filed in support of Defendant Ghislaine Maxwell's motion for summary judgment (ECF No. 540 to 543, inclusive); • (b) All currently sealed documents filed in support of Plaintiff Virginia L. Giuffr
ruary 11, 2020). Access to other judicial documents in this action has already been granted to intervening private parties in interest, see Brown v. Maxwell, 929 F.3d 41 (2d Cir. 2019), and also is the subject of ongoing litigation before this Court. See, e.g., ECF No. 1096-1108. The 1 EFTA00073260 C
F NEW YORK Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP
orney General to prosecute a civil action against any persons engaged in a pattern of criminal activity through association with any enterprise. 14 V.I.C. §§ 605, 607. The USVI alleges in its CICO action that decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking enterprise in the Virgin
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN CIVIL CASE NO.: ‘51t 3DS . )56 GHISLAINE MAXWELL, Plaintiff, vs. ESTATE OF JEFFREY E. EPSTEIN. DARREN K. INDYKE, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY E. EPSTEIN, RICHAR
ESTATE OF JEFFREY E. EPSTEIN, and NES, LLC. a New York Limited Liability Company. Defendants. 18f103 ):101213dflS COMPLAINT Plaintiff GHISLAINE MAXWELL (-Maxwell.), through her undersigned attorneys. by ‘‘a) of her Complaint against Defendants is STA OF JEI FREY I.. LPSTLIN (the "Estate"). DARREN
suit, proceeding, or investigation relating to Epstein, his affiliated businesses, and his alleged victims. PARTIES AND JURISDICTION 2. Plaintiff Ghislaine Maxwell is an adult citizen of the United States. 3. Jeffrey E. Epstein was a resident of the Virgin Islands. The Estate of Jeffrey E. Epstein was created
ompany organized under the laws of the State of New York on or about August 13. 1993. 7. This Court ha jurisdiction over this matter pursuant to 4 V.I.C. § 76. 8. Pursuant to 4 V.I.C. § 78, venue properly lies in the United States Virgin Islands. and in the Division of St. Thomas and St. John. FACT
EFTA00077313 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 4 of 14 • (a) All currently sealed documents filed in support of Defendant Ghislaine Maxwell's motion for summary judgment (ECF No. 540 to 543, inclusive); • (b) All currently sealed documents filed in support of Plaintiff opposition to Def
ruary 11, 2020). Access to other judicial documents in this action has already been granted to intervening private parties in interest, see Brown v. Maxwell, 929 F.3d 41 (2d Cir. 2019), and also is the subject of ongoing litigation before this Court. See, e.g., ECF No. 1096-1108. The EFTA00077311 Case
T SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-LAP
orney General to prosecute a civil action against any persons engaged in a pattern of criminal activity through association with any enterprise. 14 V.I.C. §§ 605, 607. The USVI alleges in its CICO action that decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking enterprise in the Virgin
or payment for services as a procurer." 49. In August 2011, when conducting a Know-Your-Customer review, JP Morgan flagged an account relating to Ghislaine Maxwell—Epstein's former companion who recently was sentenced to 20 years in prison for conspiring with Epstein to sexually abuse minors. Maxwell wanted to
Ghislaine Maxwell—Epstein's former companion who recently was sentenced to 20 years in prison for conspiring with Epstein to sexually abuse minors. Maxwell wanted to set up an account for her "personal recruitment consulting business." In an internal email, JP Morgan's AML Director asked: "What does sh
review, JP Morgan flagged an account relating to Ghislaine Maxwell—Epstein's former companion who recently w
ations 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 V.I.C. §§ 301 to 336, and in support thereof alleges
irst or massage guests? 18 A. Different times. There were -- mostly they 19 was his massage. Mostly he would get massages. 20 Q. Would Ms. Maxwell be in the room with him 21 while he was getting the massage? 22 A. We don't know. Apparently we saw her going 23 upstairs, because it was --
e. Mostly he would get massages. 20 Q. Would Ms. Maxwell be in the room with him 21 while he was getting
ous unintended result of a plea to felony aggravated assault is the possible registration in his place of residency. The Virgin Islands statute, 14 V.I.C. § 1722 et seq., is very broad, imposing a duty to register upon a "person convicted ... on or after July 1, 1994 of a criminal offense against a m
r Horizon oil spill, Deputy Administrator of the GM Ignition Switch Compensation Program and Deputy
he approval of any claim by the Program Administrator will be deemed to have the effect of a claim "examined and approved" within the meaning of 15 V.I.C. § 394, and, as already indicated, the Co- Executors would have no authority to reject or modify the Program Administrator's determination of any com
r Horizon oil spill, Deputy Administrator of the GM Ignition Switch Compensation Program and Deputy
he approval of any claim by the Program Administrator will be deemed to have the effect of a claim "examined and approved" within the meaning of 15 V.I.C. § 394, and, as already indicated, the Co- Executors would have no authority to reject or modify the Program Administrator's determination of any com
or bearewitallsensig se0an• THIS LICENSE MUST BE PROMINENTLY DISPLAYED AT PLACE OF BUSINESS -s-oscrsimettit-drermuttrry -- • r-w--c• - - SONY _ GM _00013323 03 CCCC 03 QIL 0 u_ 0 CONFIDENTIAL EFTA_00 123966 EFTA01269170 O CHASE CORPORATE RESOLUTIONS and CORPORATE AUTHORIZATION AND
SING AND CONSUMER AFFAIRS UCENSING DIVISION HEREBY LIMES %NOM That, in accordance with the applicable provisions of Title 3 Chapter 16 and Tile 27 V.I.C. mauling to the licensing of businesses and occupations, and compliance having been made wrth the provisions of 10 V.I.C. Sec. 41 relating to the Ci
r Horizon oil spill, Deputy Administrator of the GM Ignition Switch Compensation Program and Deputy
Trust, and numerous Epstein business affiliates and associates for violation of the Criminally Influenced and Corrupt Organization Act ("CICO"). 14 V.I.C. § 600 et seq., and civil conspiracy, seeking forfeiture and divestment of assets in favor of the Government, civil penalties, damages, and other re
Entities connected to both Ghislaine Maxwell and V.I.C.

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
JPMorgan Chase
ORGANIZATIONSouthern District
LOCATION
United States
LOCATION
George W. Bush
PERSON
NEW YORK NY
LOCATION
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Eric Trump
PERSON
Julie K. Brown
PERSONDarren Indyke
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSON