Epstein Secrets

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

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

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

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)

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

-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