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questioned as part of a lawsuit filed by Jane Doe, who alleges she was 14 when Epstein and his former girlfriend, British socialite EFTA00163121 Ghislaine Maxwell, began to groom and sexually abuse her in 1994. (Doe is suing Indyke and Kahn in their capacity as co-executors, and Maxwell individually.) Maxwel
FTA00163121 Ghislaine Maxwell, began to groom and sexually abuse her in 1994. (Doe is suing Indyke and Kahn in their capacity as co-executors, and Maxwell individually.) Maxwell, who is in a federal prison in Brooklyn awaiting trial for her alleged role in Epstein's teen sex ring, could also sit for
mer girlfriend, British socialite EFTA00163121 Ghislaine Maxwell, began to groom and sexually abuse her in
now to what extent he knew about Mr. Epstein and Ms. Maxwell's criminal enterprise. We would like to know if
ent for this article, has been an executive with Epstein's shadowy nonprofits since at least 2007. That year, Kahn replaced Maxwell as treasurer of the C.O.U.Q. Foundation and held the role until the charity dissolved five years later. C.O.U.Q. contributed $46 million in stock and other assets to Wexner's YLK Charita
questioned as part of a lawsuit filed by Jane Doe, who alleges she was 14 when Epstein and his former girlfriend, British socialite EFTA01654939 Ghislaine Maxwell, began to groom and sexually abuse her in 1994. (Doe is suing Indyke and Kahn in their capacity as co-executors, and Maxwell individually.) Maxwel
FTA01654939 Ghislaine Maxwell, began to groom and sexually abuse her in 1994. (Doe is suing Indyke and Kahn in their capacity as co-executors, and Maxwell individually.) Maxwell, who is in a federal prison in Brooklyn awaiting trial for her alleged role in Epstein's teen sex ring, could also sit for
mer girlfriend, British socialite EFTA01654939 Ghislaine Maxwell, began to groom and sexually abuse her in
now to what extent he knew about Mr. Epstein and Ms. Maxwell's criminal enterprise. We would like to know if
ent for this article, has been an executive with Epstein's shadowy nonprofits since at least 2007. That year, Kahn replaced Maxwell as treasurer of the C.O.U.Q. Foundation and held the role until the charity dissolved five years later. C.O.U.Q. contributed $46 million in stock and other assets to Wexner's YLK Charita
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
CGLacs e. 22-1kod.-CIfia91143BRDOnntuantataa PDS EIC1O12/23 Page 11B aff ain accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
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
rties located in Ne York. Paris, Florida. New \lexico. and the U.S. Virgin Islands. I I. During the course of their relationship. including while Maxwell was in Epstein's employ. Epstein promised Maxwell that he would support her financially. EFTA00094891 CIVIL CASE NO.: Page 3 of 10 12. Epstein
THOMAS AND ST. JOHN CIVIL CASE NO.: 012P'41-156. GHISLAINE MAXWELL, Plaintiff, vs. ESTATE OF JEFFREY E. E
s for NES. LLC. and never received a response. P. Maxwell was also employed by several of Epstein's other entities, including. but not limited to, the C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC, JEGE Inc.. and LSJ, LLC. 53. Upon information and belief, the corporate organizational documents or these othe
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
addition, Epstein and/or his representatives appeared to be misusing JP Morgan accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
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
rties located in Nc•.. York. Paris. Florida. New Mexico and the U.S. Virgin Islands. I I. During the course of their relationship. including while Maxwell was in Epstein's employ. Epstein promised Maxwell that he %%cold support her financially. SDNY_GM_00324058 EFTA_00196892 EFTA01306529 CIVIL CAS
THOMAS AND ST. JOHN CIVIL CASE NO.: 6P3D-41-156 GHISLAINE MAXWELL, Plaintiff, vs. ESTATE OF JEFFREY E. E
for NES. LLC. and never received a response. 52. Maxwell was also employed by several of Epstein's other entities, including. but not limited to, the C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC. JEGE Inc., and LSJ. LLC. 53. Upon inronnation and belief. the corporate organizational documents or these othe
good parent. During his adulthood, Jeffrey has had two long-term relationships: the first with Eva Andersson from 1981 to 1990, and the second with Ghislaine Maxwell from 1991 to 2000. (These will be treated in greater detail below.) Jeffrey currently maintains residences in New York City; West Palm Beach, Flori
s, Jeffrey entered into another significant relationship with Ghislaine Maxwell, then 29, beginning 6 Public Records Request No. 19-372 in 1991. Ghislaine reported that she had come to New York City at a very dark time of her life. Her father, Robert Maxwell, a well-known publisher, had been found dead
from 1981 to 1990, and the second with Ghislaine Maxwell from 1991 to 2000. (These will be treated in gre
oteworthy aspect of Jeffrey's giving: to the extent that it is possible, Jeffrey wants his 2 The Jeffrey Epstein Virgin Islands Foundation, Inc. and the C.O.U.Q. Foundation. 8 Public Records Request No. 19-372 gifts to be anonymous. Where this is not possible, he nonetheless does not seek the spotlight and makes it
Entities connected to both Ghislaine Maxwell and the C.O.U.Q. Foundation

Jeffrey Epstein
PERSON
JPMorgan Chase
ORGANIZATIONSouthern District
LOCATION
United States
LOCATION
Marc Rich
PERSONLeon Black
PERSON
Bradley Edwards
PERSONDarren Indyke
PERSON
New York
LOCATION
Les Wexner
PERSONJane Doe
PERSONLarry Visoski
PERSON
Lesley Groff
PERSON
Prince Charles
PERSON
Stephen Hawking
PERSON
Sarah Kellen
PERSON
Palm Beach
LOCATION
Richard Kahn
PERSON
U.S. Virgin Islands
LOCATION
Condoleezza Rice
PERSON