Epstein Secrets

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

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

s in Florida state court, in exchange for a federal Non-Prosecution Agreement ("NPA") providing him 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

ding him 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 incl

ed the allegations 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

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

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

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

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