Epstein Secrets

ates also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to MI, Lesley Groff, or ." (DE 407 at ¶ 40.) The NPA also provided that: "The parties anticipate that this agreement will not be made part of any public record. If the

pstein, including but not limited to MI, Lesley Groff, or ." (DE 407 at ¶ 40.) The NPA also provided t

a standard CVRA victim notification letter.' The notification letter promised that the Justice Department would make its "best efforts" to protect Jane Doe l's rights, including "the reasonable right to confer with the attorney for the United States in the case" and " to be reasonably heard at any public pr

reports outlined 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. Some articles reported that Kellen and Marcinkova had invoked their Fifth Amendment right against self-incrimi

stein's alleged co-conspirators, including Lesley Groff, Sarah Kellen, and Nadia Marcinkova. Some articl

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

accounts for an Epstein-related trust named "The Butterfly Trust." The Butterfly Trust included a number of beneficiaries, including, among others, Lesley Groff, Sarah Kellen, and Nadia Marcinkova, and a number of women with Eastern European surnames. When Deutsche Bank personnel asked Epstein and Epstein's

ing him and his co-conspirators (including Lesley Groff, Sarah 48 EFTA00162005 Case 1:22-cv-10018-JSR

-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

irators who 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 com

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)