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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
00 in checks payable to cash purportedly for "fuel expenses when traveling to foreign countries." Additionally, between January 2012 and June 2013, Hyperion converted more than $120,000 into foreign currency. Many of these cash withdrawals either exceeded the $10,000 reporting threshold or were seemingly
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
00 in checks payable to cash purportedly for "fuel expenses when traveling to foreign countries." Additionally, between January 2012 and June 2013, Hyperion converted more than $120,000 into foreign currency. Many of these cash withdrawals either exceeded the $10,000 reporting threshold or were seemingly
t is also allegedly investigating his involvement in this activity." • "He is also an alleged personal associate of the CEO of the Investment Bank (Jes Staley)" • "AML Operations went to a [Private Bank] risk meeting late last week requesting that we exit this relationship." • "whether Epstein if furth
ding 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 Staley was the head of JP Morgan's Private Bank, which is a segment of JP Morgan's business ded
00 in checks payable to cash purportedly for "fuel expenses when traveling to foreign countries." Additionally, between January 2012 and June 2013, Hyperion converted more than $120,000 into foreign currency. Many of these cash withdrawals either exceeded the $10,000 reporting threshold or were seemingly
INVESTIGATION Date of transcription 02/13/2007 date of birth Social Security Account Number b6 es A New Mexico was interviewed at ZORRO b7C RANCH, Stanley, New Mexico. After being advised of the identity of the interviewing agents, and the nature of the igeereiev,. provided the following information: |
copy of FD-302° interview of [ __—S—C—C]. and agent's original notes. Details: An interview off was conducted on 02/08/2007 at 49 Zorro Ranch Road, Stanley, New Mexico. Results of the interview are contained in the enclosed FD-302. Pending further direction from Miami, Santa Fe RA considers this lead co
NCORPORATED, and can fly up to 26 passengers. The Gulfstream, tail number N909JE, is owned and operated by another of EPSTEIN's subsidiary companies, HYPERION AIR, INCORPORATED, and can fly up to 12 passengers. [___] believes EPSTEIN has separate entities for each plane for liability reasons. [__|]stated th
clear that if she did not abide then she would suffer serious financial and reputational harm), through the end of 2013. 115. James "Jes" Staley ("Staley"), the then-head of JP Morgan's private banking division, was a regular visitor of Epstein's during that period of time, through and beyond 2013, a
e an intentional decision to keep Epstein on as a client. 217. JP Morgan, including its CEO Jamie Dimon and the highest levels of the bank, knew of Jes Staley's personal involvement with Epstein and yet still allowed Staley to remain a decision maker for JP Morgan on Epstein accounts. 218. Even before the s
0 in checks payable to cash purportedly for "fuel expenses when traveling to foreign countries." Additionally, between January 2012 and June 2013, Hyperion converted more than $120,000 into foreign currency. Many of these cash withdrawals either exceeded the $10,000 reporting threshold or were seeming
LEAD(s): Set Lead 1: (Action) ALBUOUEROUE AT SANTA FE , NM • Interview , ranch manager for Jeffrey Epstein's, Zorro Ranc , orro Ranch Road, Stanley, New Mexico. Set Lead 2: (Action) SAN JUAN AT ST. THOMAS, U.S.V.I. rview IIIIIIIIIIIIII, cellul leohone number of , residence e ep one number
a EFTA01688812 FD-302 (Rev. 10-6-95) • FEDERAL BUREAU OF INVESTIGATION nftormmthow 02/13/2007 date of birth Social Security Acco tntu r of Stanley, New Mexico wasinterviewed at t e gues ouse o ORRO RANCH, Stanley, New Mexico. After being advised of the identity of the interviewing agents, an
RPORATED, and can fly up to 26 passengers. The Gulf stream, tail number N909JE, is owned and operated by another of EPSTEIN's subsidiary companies, HYPERION AIR, INCORPORATED, and can fly up to 12 passengers. ROGERS believes EPSTEIN has separate entities for each plane for liability reasons. ROGERS sta
6/2006 • LEAD(s): Set Lead 1: (Action) ALBUOUEROUE AT SANTA FE , NM Interview Bryce Gordon, ranch manager for Jeffrey Epstein's, Zorro Ranch, Stanley, New Mexico. Set Lead 2: (Action) SAN JUAN AT ST. THOMAS, U.S.V.I. Interview Miles Alexander, cellular telephone number of residence telephone n
ORPORATED, and can fly up to 26 passengers. The Gulfstream, tail number N909JE, is owned and operated by another of EPSTEIN's subsidiary companies, HYPERION AIR, INCORPORATED, and can fly up to 12 passengers. ROGERS believes EPSTEIN has separate entities for each plane for liability reasons. ROGERS sta
t a -- 17 0. -- and the date is 2/21/05. 18 A. Right. 19 0. Which is ten days after the previous. It's 20 going -- 21 A. I don't know who the Stanleys are. 22 0. And it's going from the island. 21 A. To -- 24 0. Palm Beach, 25 A. Palm Beach. I don't know who the 9 10 11 12 13 14 15
orro Trust? 14 A. No. 15 O. Are you familiar with some of Epstein's 16 companies? 17 MR. PIKE: Form. 18 A. No. I mean, other than JEGE and Hyperion 19 and Air Ghislaine. 20 Q. What's Air Ghislaine? 21 A. That's the helicopters - that's what 22 they're under. 23 Q. He named it after Ghi
Entities connected to both Jes Staley and Hyperion

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Marc Rich
PERSON
Prince Andrew
PERSONDarren Indyke
PERSONLeon Black
PERSON
Richard Kahn
PERSON
Woody Allen
PERSON
Ehud Barak
PERSON
Ghislaine Maxwell
PERSON
Joe Biden
PERSON
Condoleezza Rice
PERSON
George Mitchell
PERSON
John F. Kennedy
PERSON
Alan Dershowitz
PERSON
Lawrence Krauss
PERSON
Tom Pritzker
PERSON
United States
LOCATION
George W. Bush
PERSON
Robert Gates
PERSON