Epstein Secrets

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

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

anking relaticosh0 with Deutsche Bank (e.g. external legal counsel, dent referral sourte, supplier of goods cc wrvicesp: YesLJ rrn No Fa Describe Nadia of Entity's Primary Basisess and lavestnieat Activities Nature of the business: Consult and Invest dent funds and gain revenue based on fees and re

lease maitre other des and/or Indicate elahmship between parties) Molder (Fill) Owner 1 2] D "' I'D LLC O O O O O O O O O 2 J 2 Southern Trust Inc. K Company, r--I l—i O • O • O O 50 O O • 3 2 D The ',acme Trust O O O O • O O so O O O O 2 Jeffrey Epstein O O O 0 E

odied: Describe the chain from the direct owner of the entity to the ultimate beneficial owner of not tie same pawns,. This entity is owned 50/50 by Southern Trust Company Inc owned by Jeffrey Epstein and The Pierre Trust in which Caroline Lang Is the grantor. Etienne Binant is the manager of the company. Jeffrey and Caroli

ribe the Chain from the direct owner of the entity to the ultknate beneficial owner "not me same persons). Jeffrey Epstein is the sole shareholder of Southern Trust To the best of your knowledge, is the eMIty party to a nonbanking relaticosh0 with Deutsche Bank (e.g. external legal counsel, dent referral sourte

s underlying the NPA and to varying degrees detailed the involvement of Epstein's alleged co-conspirators, including Lesley Groff, Sarah Kellen, and Nadia Marcinkova. 195. The names of these women and other alleged co-conspirators were 49 EFTA00162006 Case 1:22-cv-10018-JSR Document 42 Filed 01/13/23 Page 50

3 Page 49 of 163 Kellen, Adriana Ross, and Nadia Marcinkova) with immunity from federal prosecution for exte

1/13/23 Page 49 of 163 Kellen, Adriana Ross, and Nadia Marcinkova) with immunity from federal prosecuti

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

. 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

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

hold marketable securities and rash 519 - Custody account to hold FX cash deposits 410Wata atria/ Male Paconows tat= Vassabst Ms» atted-bille Nadia. latta2.a WPM) Mara 1/121011 I =OM! I IMMO, Regards. Brad Bradley Gitlin Vice President Deutsche Bank Wealth Management 345 Park Avenue,

should be removed from the system. • "Purpose of the account- required for all the below accounts. GCIS 483883 Purpose - For private investments. Southern Test is a private consulting company provides financial and tax advice to clients. 965 — DB AG pmferted account — High yielding interest account for cash