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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
addition, Epstein and/or his representatives appeared to be misusing JP Morgan accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
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
CGLacs e. 22-1kod.-CIfia91143BRDOnntuantataa PDS EIC1O12/23 Page 11B aff ain accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
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
EFTA00161851 Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 17 of 34 accounts for Epstein's purported charitable organizations, including the C.O.U.Q. Foundation and Enhanced Education. Epstein made payments from these accounts with no clear nexus to the organization's charitable purpose. For example, Epstei
Entities connected to both JPMorgan Chase and the C.O.U.Q. Foundation

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONDarren Indyke
PERSON
Marc Rich
PERSON
Richard Kahn
PERSON
Financial Trust Company
ORGANIZATIONMAX FOUNDATION
ORGANIZATION
Federal Reserve
ORGANIZATION
Lesley Groff
PERSONLeon Black
PERSON
United States
LOCATION
Deutsche Bank
ORGANIZATION
Bella Klein
PERSONJack Goldberger
PERSON
U.S. Virgin Islands
LOCATION
Condoleezza Rice
PERSON
Prince Charles
PERSON
Stephen Hawking
PERSON
Bill Richardson
PERSON
Bradley Edwards
PERSON