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sexual conduct, sex trafficking, and forced labor. 29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to many other Epstein v
tive used the C.O.U.Q. Foundation account to pay $29,464.66 to three young women, including two known victims, and over $20,000 to a company called Phoenix Realty Home Inc. Similarly, Epstein and/or his representative used the Enhanced Education fund to pay $124,232 to and $15,000 to and , a firm owned by Epstein's
reign commerce between the United 23 EFTA00162143 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 24 of 130 States and Europe, especially Eastern Europe. 88. At all times relevant to this complaint, the Epstein sex-trafficking venture was a group of two or more individuals associated in fact, even
ive used the C.O.U.Q. Foundation account to pay $29,464.66 to three young women, including two known victims, and over $20,000 to a company called Phoenix Realty Home Inc. Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., Case No. 22-cv-10904-JSR, Amended Complaint (Dkt. 16) at 16-17 (S.D.N.
sexual conduct, sex trafficking, and forced labor. 29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to marry other Epstein
tive used the C.O.U.Q. Foundation account to pay $29,464.66 to three young women, including two known victims, and over $20,000 to a company called Phoenix Realty Home Inc. Similarly, Epstein and/or his representative used the Enhanced Education fund to pay $124,232 to Leslie Wexner and $15,000 to and . a firm owned
sexual conduct, sex trafficking, and forced labor. 29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to many other Epstein v
tive used the C.O.U.Q. Foundation account to pay $29,464.66 to three young women, including two known victims, and over $20,000 to a company called Phoenix Realty Home Inc. Similarly, Epstein and/or his representative used the Enhanced Education fund to pay $124,232 to Leslie Wexner and $15,000 to and . a firm owned
Entities connected to both Eastern Europe and Phoenix Realty Home Inc.

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Jean-Luc Brunel
PERSON
New York
LOCATION
Prince Charles
PERSON
Palm Beach
LOCATION
Lesley Groff
PERSON
Palm Beach Police Department
ORGANIZATION
U.S. Virgin Islands
LOCATION
Condoleezza Rice
PERSONJane Doe
PERSONDarren Indyke
PERSONthe Southern District
LOCATION
JPMorgan Chase
ORGANIZATIONNadia Marcinkova
PERSON
Vienna
LOCATION
Les Wexner
PERSON
Jes Staley
PERSON
Washington D.C.
LOCATION