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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
lected the reality of the above assets held or the above expenses incurred by each entity. 194. The Annual Reports submitted on behalf of Cypress, Maple, and Laurel all were signed by Epstein and Defendant and Co-Executor Kahn with the representation that "ALL STATEMENTS CONTAINED IN THIS APPLICATIO
180. Defendant Maple, Inc. acquired ownership of the property 9 East 71st Street in New York, New York on or about December 23, 2011, shortly after Maple was formed. Maple acquired ownership of the property from Nine East 71st Street Corporation, which was owned by Epstein. 181. Defendant Laurel, I
d and did not include any expenses related to the Palm Beach property in the total expenses it reported to the Government. 193. Neither Cypress's, Maple's, nor Laurel's financial statements ever reflected the reality of the above assets held or the above expenses incurred by each entity. 194. The Ann
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
180. Defendant Maple, Inc. acquired ownership of the property 9 East 71st Street in New York, New York on or about December 23, 2011, shortly after Maple was formed. Maple acquired ownership of the property from Nine East 71st Street Corporation, which was owned by Epstein. 181. Defendant Laurel, I
d and did not include any expenses related to the Palm Beach property in the total expenses it reported to the Government. 193. Neither Cypress's, Maple's, nor Laurel's financial statements ever reflected the reality of the above assets held or the above expenses incurred by each entity. 194. The Ann
lected the reality of the above assets held or the above expenses incurred by each entity. 194. The Annual Reports submitted on behalf of Cypress, Maple, and Laurel all were signed by Epstein and Defendant and Co-Executor Kahn with the representation that "ALL STATEMENTS CONTAINED IN THIS APPLICATIO
4.98 7/214/2011 Interest Morgan Stanley PrivateBali MA. 24 79 15%96977 ftsbnctaa al July 31.2011 S S S F.;.,.,,:- 0/30/2011 %Detest ?down Stanley [Meese aug. NA. 21.9 15.991:6 allillaV Asa Augur. 31.2011 S 155.991.56 5 15.991.56 9/29/2011 Enterer Morgan Reeky sank MA 644 155,998.40
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opinion oldie defined value of the yen the intended use al the appraisal. • Client Name or Intended User Federal Bureau of Invest]• ation Email Stale NY 2. 10278 • Client Address 26 Federal Plaza 0 New York ' Intended Use Estimate of Market Value Property Address 9 East 71st Street ay New York
er DescrptiontAPN. Legal elc.). if applcabb Section: 1 : Block: 1386; Lot: 10 Property Righis Appraised U Fee Simple U Leasehold UOther (deseibe) Maple. Inc. Subject propmyexisfirigusa: Single-Family Masonry (A5) Use reflected in appraisal. My research U (fad Mjdid not reveal any prig sales or tra
niversality” (see above) entered the parlance of physics in the context of the statistical mechanics of phase transitions near their critical points (Stanley, 1971; Stauffer, 1985; Yeomans, 1993) and has come to refer to the finite set of transitions and quantities common to nonlinear systems arising in_ t
vations. For today’s neuroscientist with a desktop computer, an inclination to program and access to computer algebra and numerical software such as Maple, Mathematica or MatLab, operational definitions and computational empiricism can replace the theorem and proof continuity required to do old style ap
esses are not a sign of measurement error, but rather evidence consonant with the statistical physics of nonequilibrium states and phase transitions (Stanley, 1971; Stauffer, 1985; Yeomans, 1993). Very high amplitude fluctuations and multiple, up to infinite, correlation lengths are characteristic of the n
242 HOUSE_OVERSIGHT_013742 that procedures such exponentiation of a matrix can be carried out automatically using computer algebra programs such as Maple or for data processing available as computational modules in MatLab. One of the techniques for the computation of hy involves determining the logar
8. 412. Defendant Cypress misrepresented the value of its assets held during each of these years by omitting the value of the 49 Zorro Ranch Road, Stanley, New Mexico property that it EFTA00161940 Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 72 of 77 GVI v. Estate of Jeffrey Epstein GVI
e criminal predicate acts as defined by CICO, including but not limited to making fraudulent claims upon the Government. 411. Defendants Cypress, Maple, and Laurel misrepresented the values of their assets held and expenses incurred in their annual reporting to the Government of the United States V
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Entities connected to both Jes Staley and Marla Maples

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