Epstein Secrets

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

conspiracy's knowledge extended to the names of Epstein's victims, because Epstein and his co-conspirators knew the names of the victims, including Jane Doe l's name. JP Morgan, through its officer Jes Staley, also new many of the names of the victims. 445. JP Morgan conspired to violate 18 U.S.C. § 1591(a)

e and willing to seriously harm any of his victims. 35. While Epstein's abuse began in the early 1990s with the use of his paramour turned madame, Ghislaine Maxwell ("Maxwell"), Epstein's appetite for 10 EFTA00162130 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 11 of 130 sexually abusing young wome

iously harm any of his victims. 35. While Epstein's abuse began in the early 1990s with the use of his paramour turned madame, Ghislaine Maxwell ("Maxwell"), Epstein's appetite for 10 EFTA00162130 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 11 of 130 sexually abusing young women and girl

990s with the use of his paramour turned madame, Ghislaine Maxwell ("Maxwell"), Epstein's appetite for 10

Filed 01/13/23 Page 5 of 130 continue to possess—tremendous wealth and power and have demonstrated a clear ability to cause her serious harm. 10. Jane Doe l's safety, right to privacy, and security outweigh the public interest in her identification. 11. Jane Doe l's legitimate concerns outweigh any preju

ment 42 Filed 01/13/23 Page 15 of 163 49. While Epstein's first sexual abuse occurred in the early 1990s with the complicity of his then-paramour, Ghislaine Maxwell, Epstein's appetite for sexual abusing young women and girls grew over the years. His sex-trafficking and abuse had crystalized in a well- organize

contributed to Epstein's abuse of sex trafficking victims, helping Epstein to recruit, groom, and ultimately abuse his victims. See United States v. Maxwell, Case No. 1:20-cr-00330 (S.D.N.Y.). 126. On December 29, 2021, Maxwell was found guilty in this Court on five federal sex-trafficking counts in th

1990s with the complicity of his then-paramour, Ghislaine Maxwell, Epstein's appetite for sexual abusing y

-trafficking venture had—and continue to possess-tremendous wealth and power and have demonstrated a clear ability to cause her serious harm. 10. Jane Doe l's safety, right to privacy, and security outweigh the public interest in her identification. 11. Jane Doe l's legitimate concerns outweigh any preju