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onship grew closer 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
ailed the involvement 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 allegati
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
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 directly committed and pe
ally include Ghislaine Maxwell, Lesley Grog Sarah Kellen, Adriana Ross, and Nadia Marcinkova. 412. Actin
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
other compensation 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) an
untant 1, Ghislaine Maxwell, Lesley Groff, Sarah Kellen, Adriana Ross, and Nadia Marcinkova. 378. Under
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 Sarah Kellen and FinCEN

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Marc Rich
PERSONLarry Visoski
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
United States
LOCATIONLeon Black
PERSON
Richard Kahn
PERSON
George W. Bush
PERSONDarren Indyke
PERSON
Salt Lake City
LOCATION
Virginia Giuffre
PERSON
Donald Trump
PERSONMaria Farmer
PERSON
Bill Clinton
PERSON