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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
Criminal Activities 1. Defendant Southern Trust Company, Inc. 157. In October 2012, the Southern Trust Company applied for economic benefits from the Economic Development Commission ("EDC"). The EDC is a subsidiary of the Virgin Islands Economic Development Authority ("EDA"), a semi-autonomous governmental instrumentality creat
o not include relatives, present employer or employees or bank references. James E. Staley Andrew Farkas 25. Provide three (3) bank references: J.P. Morgan Chase & Co. First Bank [signature page to follow] EFTA00128871 Dated and signed this 20th day of March 2013 at New York. I hereby certify under penalty of p
the Virgin Islands in 1999 when he opened Financial Trust Company, Inc. ("FTC"). FTC was a successful Virgin Islands business and a beneficiary of the Economic Development Commission ("EDC"). Mr. Epstein is also the sole shareholder of Southern Trust Company, Inc. ("SIC") which has been recommended for benefits from the EDC and
o not include relatives, present employer or employees or bank references. James E. Staley Andrew Farkas 25. Provide three (3) bank references: J.P. Morgan Chase & Co. First Bank [signature page to follow] EFTA00294457 Dated and signed this 20th day of March 2013 at New York. I hereby certify under penalty of p
ands EFTA00294453 in 1999 when he opened Financial Trust Company, Inc. ("FTC"). FTC was a successful Virgin Islands business and a beneficiary of the Economic Development Commission CEDC"). Mr. Epstein is also the sole shareholder of Southern Trust Company, Inc. ("STC) which has been recommended for benefits from the EDC and is
Entities connected to both JPMorgan Chase and the Economic Development Commission

Jeffrey Epstein
PERSONDarren Indyke
PERSONMaria Farmer
PERSON
Richard Kahn
PERSON
Financial Trust Company
ORGANIZATION
U.S. Virgin Islands
LOCATION
Prince Andrew
PERSON
Samantha Power
PERSONFirst Bank
ORGANIZATION
Jes Staley
PERSONLarry Visoski
PERSONSouthern Trust Company
ORGANIZATIONJane Doe
PERSON
Red Hook
LOCATIONHyperion Air
ORGANIZATION
Charlotte
LOCATION
Little St. James
ORGANIZATION
Vienna
LOCATION
Keystone
ORGANIZATIONV.I.C.
ORGANIZATION