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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
such other relief as the Court deems appropriate. JURY DEMAND The Government demands a jury trial on all issues so triable. Dated: April 3, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Isl Linda Singer Linda Singer (pro hac vice) Mimi Liu (pro hac vice) David I. Ackerman Paige Boggs (pro hac vice)
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
h other relief as the Court deems appropriate. JURY DEMAND The Government demands a jury trial on all issues so triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David 1. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washingto
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
h other relief as the Court deems appropriate. JURY DEMAND The Government demands a jury trial on all issues so triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David I. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washingto
Entities connected to both JPMorgan Chase and CAROL THOMAS-JACOBS

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
Financial Trust Company
ORGANIZATION
Federal Reserve
ORGANIZATION
United States
LOCATION
Deutsche Bank
ORGANIZATION
U.S. Virgin Islands
LOCATION
Condoleezza Rice
PERSON
Prince Charles
PERSONHBRK Associates
ORGANIZATIONJEGE, Inc.
ORGANIZATION
Jes Staley
PERSONLarry Visoski
PERSON
New York
LOCATION
Les Wexner
PERSONSouthern Trust Company
ORGANIZATION
Glenn Dubin
PERSON
Palm Beach
LOCATION