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7 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 directly committed and perpetrated viol
pstein's bestowal of financial and other benefits, including sexual services and forced labor from victims. Id.11 at 157-195. 25. In October 2012, the Southern Trust Company—one of the companies Epstein owned—applied for economic benefits from the Virgin Islands Economic Development Commission ("EDC") so the company cou
F THE 1953 TRUST; ESTATE OF JEFFREY E. EPSTEIN; THE 1953 TRUST; PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, Inc.; SOUTHERN TRUST COMPANY, INC.; CYPRESS, INC.; MAPLE, INC.; LAUREL, INC.; AND JOHN AND JANE DOES, DEFENDANTS. Case No.: ST-20-CV-14 ACTION FOR DAMAGES JURY TRIAL DEMANDED SE
rds, airplanes, and other instrumentalities of the Epstein Enterprise. 168. In fact, the main source of funds for the Epstein Enterprise came from Southern Trust. Between 2013 and 2017, Southern Trust reported approximately $184 million in revenues. 169. Defendants Kahn and Indyke directed and controlled th
at the IRS rte note« he DepostMr Nat it is no longer 'ulna to borne MNIMang ce it is exempt trot bachip Mabel: q. (3) the Elegadix is a U.S. Itn6ty (Cross out subpart 2(a) if it is not true. If StateMent $ is not true. cross out and complete an Ofirofghla Taw W4) Tho Internal Revenue Snare does not re
97 Bank yaw, Wanes Corporate Resolution I, the Jndersigned Secretary, hereby certify to FirstBank that at a meting of the Board of Directors of Southern Trust Company, Inc. ('Corporation') a corporation organted and existing under the lawl of U.S. Virgin islands duly cared and duly held on the 4 day of December
and his co-conspirators (including Lesley Groff, Sarah 48 EFTA00162005 Case 1:22-cv-10018-JSR Document 42 Filed 01/13/23 Page 49 of 163 Kellen, Adriana Ross, and Nadia Marcinkova) with immunity from federal prosecution for extensive federal sex-trafficking charges in Florida. The deal included incarcera
afficking. 210. The relationship between Deutsche Bank and Epstein officially began on August 19, 2013, when the Bank opened brokerage accounts for Southern Trust Company Inc., a self-described "database company and services" founded in the U.S. Virgin Islands in 2011, and Southern Financial LLC, a wholly owned subsidiary
ation from Epstein. The co-conspirators who benefitted financially include Attorney-1, Accountant 1, Ghislaine Maxwell, Lesley Groff, Sarah Kellen, Adriana Ross, and Nadia Marcinkova. 378. Under 18 U.S.C. § 2, Deutsche Bank is punishable as a principal under 18 U.S.C. §§ 1591(a)(1) & (a)(2) and thereby comm
ove). 486. Among the acts constituting a pattern of racketeering activity, on or about August 19, 2013, Deutsche Bank opened brokerage accounts for Southern Trust Company Inc., a self-described "database company and services" founded in the U.S. Virgin Islands in 2011, and Southern Financial LLC, a wholly owned subsidiary
Entities connected to both Adriana Ross and Southern Trust Company

Jeffrey Epstein
PERSONDarren Indyke
PERSONHyperion Air
ORGANIZATION
Richard Kahn
PERSON
U.S. Virgin Islands
LOCATIONGratitude America
ORGANIZATION
Martha Stewart
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
David Cameron
PERSONLeon Black
PERSON
Financial Trust Company
ORGANIZATION
Stewart Oldfield
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSONDeutsche Bank Securities Inc.
ORGANIZATION
Alfredo Rodriguez
PERSON
Les Wexner
PERSON
John Brennan
PERSON