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r as the years went on. In fact, during the criminal investigation into Epstein in 2005, Staley flew on Epstein's plane along with Sarah Kellen and Nadia Marcinkova, individuals who had bank accounts through Epstein at JP Morgan and who were publicly identified as Epstein's co-conspirators in trafficking offens
nvolvement of Epstein's alleged co-conspirators, including Lesley Groff, Sarah Kellen, and Nadia Marcinkova. Some articles reported that Kellen and Marcinkova had invoked their Fifth Amendment right against self-incrimination. 212. Additionally, press reports during this time noted allegations that Epste
w on Epstein's plane along with Sarah Kellen and Nadia Marcinkova, individuals who had bank accounts th
failed to file with the federal government the required SARs that financial institutions must file with the Financial Crimes Enforcement Network ("FinCEN") whenever there is a suspected case of money laundering or fraud. Timely filing of these reports is required by the Bank Secrecy Act and related l
ase 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 violations of Chapter 77, T
esley Grog Sarah Kellen, Adriana Ross, and Nadia Marcinkova. 412. Acting through its officers and employees
ell, Lesley Grog Sarah Kellen, Adriana Ross, and Nadia Marcinkova. 412. Acting through its officers and
s enforcement of the TVPA, JP Morgan failed to timely file with the federal government the required SARs that financial institutions must file with FinCEN whenever there is a suspected case of money laundering or fraud. Timely filing of these reports is required by the Bank Secrecy Act and related law
. 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 committed and perpetrated
ley Groff, Sarah Kellen, Adriana Ross, and Nadia Marcinkova. 378. Under 18 U.S.C. § 2, Deutsche Bank is puni
l, Lesley Groff, Sarah Kellen, Adriana Ross, and Nadia Marcinkova. 378. Under 18 U.S.C. § 2, Deutsche B
forcement of the TVPA, Deutsche Bank failed to timely file with the federal government the required SARs that financial institutions must file with FinCEN whenever there is a suspected case of money laundering or fraud. Timely filing of these reports is required by the 122 EFTA00162079 Case 1:22-cv
Entities connected to both Nadia Marcinkova and FinCEN

Jeffrey Epstein
PERSON
Sarah Kellen
PERSON
Ghislaine Maxwell
PERSONLarry Visoski
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Prince Andrew
PERSONLeon Black
PERSONJane Doe
PERSON
George W. Bush
PERSON
Marc Rich
PERSON
Bradley Edwards
PERSON
Lesley Groff
PERSON
Donald Trump
PERSON
Wilbur Ross
PERSONMaria Farmer
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSONthe Southern District
LOCATION
Joe Biden
PERSON