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s notification form did not disclose travel to any other countries. It was later found by law enforcement authorities that Epstein also travelled to Vienna and Monaco during that trip. 135. Similarly, the Epstein Enterprise sought to prevent DPNR from conducting routine site visits to inspect unpermi
ce Jane Doe 1, as well as other Members of the Class, to engage in commercial sex acts. 379. JP Morgan, through its employees and agents (including Staley), actively participated in the sex trafficking conspiracy and led Jane Doe I, as well as other Class Members, to believe that they would be rewarde
ex acts, through providing financial support for the Epstein sex-trafficking venture. A number of those acts were committed by JP Morgan's officer, Jes Staley, acting within the actual and apparent scope of his employment to further JP Morgan's interests. 435. Among the many overt acts intentionally comm
rentta641 PkWCW/MDEM WOmelDWO722 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 9 of 76 the property 49 Zorro Ranch Road in Stanley, New Mexico, which was transferred to it in or about December 2011, shortly after it was incorporated. 39. Defendant Maple, Inc. is a Virgin Islan
s notification form did not disclose travel to any other countries. It was later found by law enforcement authorities that Epstein also travelled to Vienna and Monaco during that trip. 135. Similarly, the Epstein Enterprise sought to prevent DPNR from conducting routine site visits to inspect unpermi
6-1 Filed 01/10/23 Page 10 of 77 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 9 of 76 the property 49 Zorro Ranch Road in Stanley, New Mexico, which was transferred to it in or about December 2011, shortly after it was incorporated. 39. Defendant Maple, Inc. is a Virgin Islan
t 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 Staley was the head of JP Morgan's Private Bank, which is a segment of JP Morgan's bus
/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 Staley was the head of JP Morgan's Private Bank, which is a segment of JP Morgan's business ded
b Neefe. During his first 22 years in Bonn, Beethoven intended to study with Wolfgang Amadeus Mozart and befriended Joseph Hayt. Beethoven moved to Vienna in 1992 and began studying with Haydn, quickly gaining a reputation as a virtuoso pianist. He lived in Vienna until his death. In about i800 his he
inburgh: W & R Chambers Ltd. p. 114. ISBN 0-550-18022-2. 6. A Thayer, Vol 1, p. 53 7. A This is discussed in depth in Solomon, chapter 1. 8. A a b Stanley, p. 7 9. A Thayer, Vol 1, p. 59 io. A Thayer, Vol 1, p. 67 a A Thayer, Vol 1, pp. 71-74 12. A Cooper (2008), p.15 13. A Cooper (2008), p. 23 14
ders required to register provide information relating to intended travel in foreign commerce. 357. On at least two occasions, Epstein traveled to Vienna and Monaco without disclosing that travel to the Virgin Islands sex offender registry. EFTA00162348 Glaffiella2a3m-MEDArlSIR firlimuneent3ffill F
ctor of each of Cypress, Inc.; Maple, Inc.; and Laurel, Inc. 179. Defendant Cypress, Inc. acquired ownership of the property 49 Zone Ranch Road in Stanley, New Mexico in or about December 2011, shortly after Cypress was formed. 180. Defendant Maple, Inc. acquired ownership of the property 9 East 71st
Entities connected to both Vienna and Jes Staley

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Prince Andrew
PERSON
Marc Rich
PERSONLeon Black
PERSONDarren Indyke
PERSON
Woody Allen
PERSON
Richard Kahn
PERSON
Ehud Barak
PERSON
Joe Biden
PERSON
Boris Nikolic
PERSON
Ghislaine Maxwell
PERSON
Harry Reid
PERSON
John F. Kennedy
PERSON
Condoleezza Rice
PERSON
George Mitchell
PERSON
United States
LOCATION
Terje Rod-Larsen
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON