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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
t. John, and Water Island, and more than 40 surrounding islands and Cays, some of which are privately owned. Among these privately owned islands are Little St. James and Great St. James. 5. Jeffrey E. Epstein ("Epstein") was a resident of the Virgin Islands and he maintained a residence on Little St. Jam
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
t. John, and Water Island, and more than 40 surrounding islands and Cays, some of which are privately owned. Among these privately owned islands are Little St. James and Great St. James. 5. Jeffrey E. Epstein ("Epstein") was a resident of the Virgin Islands and he maintained a residence on Little St. Jam
he property in general, the whole -- Q. Yes, please, the whole property. A. The whole property. You started entering the ranch off of Highway 41 in Stanley, New Mexico. So you drove down a dirt road approximately a half mile and you would enter an area which the ranch called the Ranch Central, and that
he Court, and the parties please. Q. Mr. , do you recognize this? A. Yes, I do. Q. What is it? A. That is an aerial view of the main property on Little St. James Island. Q. Is this a fair and accurate depiction of a portion of SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068617 156 LBUV
I do. Q. What is it? A. That is a photo of Little St. James Island. Q. Is this a fair and accurate depiction of an aerial view of the entirety of Little St. James Island? A. Yes, it is. MS. COMEY: Your Honor, the government offers this in evidence. MR. EVERDELL: No objection. THE COURT: Government's
en units in an apartment building near the Arc de Triomphe at 22 Avenue Foch in Paris France1259) a 7,500-acre (3o km2) ranch named Zorro Ranch near Stanley, New Mexico, purchased in 1993;1261)1264)(265] a private island near Saint Thomas in the U.S. Virgin Islands called Little Saint Jamecwhich include
nth from 1992 to 1995.2 He also previously owned a mansion outside Columbus, Ohio, near Wwmer's home from 1992 to 1998 Epstein's private island of Little St. https://en.wikipedia.orgrwiki/Jethey_Epstein 19/60 EFTA00263125 5/22/22, 1:31 PM Jeffrey Epstein - Wiltipedia which he purchased from his ment
Entities connected to both Jes Staley and Little St.

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
Condoleezza Rice
PERSON
George Mitchell
PERSON
Alan Dershowitz
PERSON
Zorro Ranch
LOCATION
United States
LOCATION
Bradley Edwards
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Donald Trump
PERSON
U.S. Virgin Islands
LOCATION
Jean-Luc Brunel
PERSON