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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
n the Epstein Enterprise were the following companies and non-profit organizations, all of which had accounts with JP Morgan: 2013 Butterfly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, LLC, NES,
f he survives me, Three Million Dollars ($3,000,000). 15. to VALDSON VIERA CON1RIN, if he survives mc, Five Million Dollars ($5,000,000). 16. to GHISLAINE MAXWELL, if she survives me, Ten Million Dollars ($10,000,000). 17. to ANN RODRIQUEZ, if she survives me, the amount of Five Million Dollars ($5,0
ves me, Three Million Dollars ($3,000,000). 15. to VALDSON VIERA CON1RIN, if he survives mc, Five Million Dollars ($5,000,000). 16. to GHISLAINE MAXWELL, if she survives me, Ten Million Dollars ($10,000,000). 17. to ANN RODRIQUEZ, if she survives me, the amount of Five Million Dollars ($5,000,000),
mc, Five Million Dollars ($5,000,000). 16. to GHISLAINE MAXWELL, if she survives me, Ten Million Dollars ($10,000
general partnership, trust or other entity beneficially owned by one or both of them immediately prior to my death, including, but not limited to, Coatue Enterprises, LLC, a New York limited liability company, or its successor entities. Said funds shall be distributed to RICHARD DAVID KAHN, or his heirs, success
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
n the Epstein Enterprise were the following companies and non-profit organizations, all of which had accounts with JP Morgan: 2013 Butterfly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, LLC, NES,
mc, Five Million Dollars ($5,000,000). 16. to GHISLAINE MAXWFT I, if she survives me, Ten Million Dollars
general partnership, trust or other entity beneficially owned by one or both of them immediately prior to my death, including, but not limited to, Coatue Enterprises, LLC, a New York limited liability company, or its successor entities. Said funds shall be distributed to RICHARD DAVID KAHN, or his heirs, success
L , 2015, by who has produced GJ 000398 SOW GM:00008075 EFTA_00120747 EFTA01266426
general partnership, trust or other entity beneficially owned by one or both of them immediately prior to my death, including, but not limited to, Coatue Enterprises, LLC, a New York limited liability company, or its successor entities. Said funds shall be distributed to RICHARD KAHN, or his heirs, successors or
Entities connected to both Ghislaine Maxwell and Coatue Enterprises

Jeffrey Epstein
PERSON
JPMorgan Chase
ORGANIZATIONSouthern District
LOCATION
United States
LOCATION
Marc Rich
PERSONDarren Indyke
PERSON
New York
LOCATION
Les Wexner
PERSONJane Doe
PERSONLarry Visoski
PERSON
Lesley Groff
PERSON
Prince Charles
PERSON
New York City
LOCATION
David Rodgers
PERSON
Stephen Hawking
PERSON
George Mitchell
PERSON
Palm Beach
LOCATION
U.S. Virgin Islands
LOCATION
Richard Kahn
PERSON
Alfredo Rodriguez
PERSON