Epstein Secrets

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

-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

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

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

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

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)