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rgan Chase & Co., No. 1:22-cv-10019 (S.D.N.Y. Nov. 24, 2022), because both actions arise from a common nucleus of operative fact involving Defendant JP Morgan's alleged participation, directly or indirectly, in Epstein's sex-trafficking venture by facilitating payments to women and girls, channeling funds t
personal jurisdiction over Defendant. 12. Pursuant to Local Civil Rule 1.6(a), the undersigned believe that this action is related to Doe I v. JP Morgan Chase & Co., No. 1:22-cv-10019 (S.D.N.Y. Nov. 24, 2022), because both actions arise from a common nucleus of operative fact involving Defendant JP Morgan's all
I would count Epstein's assets as a probable outflow for '08 ($120mm or so?) as I can't imagine it will stay (pending Dimon review)." III. Head of JP Morgan's Private Bank Had Close Personal Relationship With Epstein 52. Former senior executive, Jes Staley ("Staley"), developed a close relationship with Epstein when
tivity."2 When a bank detects suspicious activity, it is required to report that information within 30 days to the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN"). The reporting requirement ensures that the government is able to monitor and act when alerted to potential illegal conduct. 18. Appen
cluding, without limitation, physical, psychological. financial, and reputational harm. This harm was a direct, proximate, and foreseeable result of JP Morgan's attempt in violation of 18 U.S.C. § 1594(a). 466. By virtue of these violations of 18 U.S.C. § 1594(a), JP Morgan is liable to Jane Doe 1 and the o
personal jurisdiction over Defendant. 12. Pursuant to Local Civil Rule 1.6(a), the undersigned believe that this action is related to Doe I v. JP Morgan Chase & Co., No. 1:22-cv-10019 (S.D.N.Y. Nov. 24, 2022), because both actions arise from a common nucleus of operative fact involving Defendant JP Morgan's all
uentn16.41 PI 01/8223 6'. 12 at 123 49. 50. EFTA00162263 Cayese. 22-IkeW1BEEE4SEIR Deaactuozentrtaa PIES 01/82/23 313laff 123 III. Head of JP Morgan's Private Bank Had Close Personal Relationship With Epstein 52. Former senior executive, Jes Staley ("Staley"), developed a close relationship with Epstein when
tivity."2 When a bank detects suspicious activity, it is required to report that information within 30 days to the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN"). The reporting requirement ensures that the government is able to monitor and act FFIEC Bank Secrecy AcUAnti-Money Laundering Examinatio
rgan Chase & Co., No. 1:22-cv-10019 (S.D.N.Y. Nov. 24, 2022), because both actions arise from a common nucleus of operative fact involving Defendant JP Morgan's alleged participation, directly or indirectly, in Epstein's sex-trafficking venture by facilitating payments to women and girls, channeling funds t
personal jurisdiction over Defendant. 12. Pursuant to Local Civil Rule 1.6(a), the undersigned believe that this action is related to Doe I v. JP Morgan Chase & Co., No. 1:22-cv-10019 (S.D.N.Y. Nov. 24, 2022), because both actions arise from a common nucleus of operative fact involving Defendant JP Morgan's all
iled 01/10/23 Page 12 of 34 49. a. b. 50. 5I. I2 EFTA00161847 Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 13 of 34 III. Head of JP Morgan's Private Bank Had Close Personal Relationship With Epstein 52. Former senior executive, Jes Staley ("Staley"), developed a close relationship with Epstein when
tivity."' When a bank detects suspicious activity, it is required to report that information within 30 days to the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN"). The reporting requirement ensures that the government is able to monitor and act FFIEC Bank Secrecy Act/Anti-Money Laundering Examinati
he ease with which criminals have exploited them." Reuters (9/20) reports the documents indicate that top global banks including HSBC Holdings Plc, WMorgan Chase & Co, Deutsche Bank AG, Standard Chartered Plc, and Bank of New York Mellon Corp "moved large sums of allegedly illicit funds over a period of nearly two
." The documents include "leaked suspicious activity reports (SARs) filed by banks and other financial firms with the U.S. Department of Treasury's Financial Crimes Enforcement Network (FinCen)." These SARs "were obtained by BuzzFeed News and shared with the International Consortium of Investigative Journalists (ICIJ) and other me
Entities connected to both JPMorgan Chase and Financial Crimes Enforcement Network

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONDarren Indyke
PERSONMaria Farmer
PERSON
Richard Kahn
PERSON
Financial Trust Company
ORGANIZATION
Eric Trump
PERSONBarrett
PERSON
George W. Bush
PERSON
Federal Reserve
ORGANIZATIONMartin Weinberg
PERSONLeon Black
PERSON
United States
LOCATION
Deutsche Bank
ORGANIZATION
Nelson
PERSON
U.S. Virgin Islands
LOCATION
Condoleezza Rice
PERSON
Prince Charles
PERSON
Prince Andrew
PERSON
Julie K. Brown
PERSON