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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
the context of the heightened scrutiny that should have occurred in the monitoring of a high-risk customer." 81. The NYSDFS also found fault with Deutsche Bank's failure to obtain answers regarding Epstein's use of his accounts to pay women with Eastern European surnames: "In a May 2018 email, a compliance o
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
the context of the heightened scrutiny that should have occurred in the monitoring of a high-risk customer." 81. The NYSDFS also found fault with Deutsche Bank's failure to obtain answers regarding Epstein's use of his accounts to pay women with Eastern European surnames: "In a May 2018 email, a compliance o
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
the context of the heightened scrutiny that should have occurred in the monitoring of a high-risk customer." 81. The NYSDFS also found fault with Deutsche Bank's failure to obtain answers regarding Epstein's use of his accounts to pay women with Eastern European surnames: "In a May 2018 email, a compliance o
Japan USA South Africa United Kingdom India World Economic Forum Annual Meeting EFTA_R1_02011032 EFTA02686158 Lynn St Amour Rupert Stadler Jes Staley President and Chief Executive Officer Chairman of the Management Board Chief Executive Officer, Investment Bank Steven P. Stanbrook Chief Operati
EFTA02686158 Lynn St Amour Rupert Stadler Jes Staley President and Chief Executive Officer Chairman
f Senior Business Editor Managing Partner President and Chief Executive Officer Chairman and Representative Director Artist. USA Vice-Chairman. Deutsche Bank Group Managing Director and Chief Executive Officer James E. Robison Professor of Business Administration Director-General Associate Professor of Fin
inancial services regulator, the Financial Conduct Authority (FCA), contacted NCA in November 2019 to indicate that they had reason to believe that Jes STALEY (Barclays Bank) and Jeffrey EPSTEIN held a close personal relationship. FCA has already engaged the US DOJ in regards the STALEY/EPSTEIN relationsh
ndicate that they had reason to believe that Jes STALEY (Barclays Bank) and Jeffrey EPSTEIN held a close
anking Account ID owned by Jeffrey EPSTEIN to a Tatra Banka AS (Slovakia) account e y 19.In December 2013 a payment of EUR 1 000.00 was sent from Deutsche Bank (DB) Private Banking Account ID owned by Jeffrey EPSTEIN to a Societe Generale Alsacienne e anque (France) account held by 20.In January 2014,
Time Difference 5 Hours Ahead ITINERARY James E. Staley London MONDAY, OCTOBER 24, 2011 6:00 PM Transfer from JFK ReaR Limo, Tel: 2.es It: 8:40 PM Depart NY JFK Airport British Airways 116 TUESD
me Difference 5 Hours Ahead ITINERARY James E. Staley London MONDAY, OCTOBER 24, 2011 6:00 PM Trans
ian Marchiony coordinating) 2:30 PM Transfer from 10 Aldermanbur Deutsche Bank/10 Aldermanbury Graham Hawes, Mobile: 3:00 I'M Anshu ain Head of IB Deutsche Bank Tel: 5:00 I'M - 7:00 I'M MD Issues Forum (with Daniel Pinto da Emilio Saracho) Hotel FRIDAY, OCTOBER 28, 2011 The Berkele Tel: 7:30 AM Trans
Cask.* Ratting Lineal Cade/ Dully Newt Luars 1/30/3)12 1297016;) &worn' .Orel! liX0)1000.1).Swupraymou al $207$9197 1/30/3)12 Interval:1.1mgal, Stanley /Sunkn 13923 1/30/3)12 Interest: Slorgan !eanley Private !UM M 1074 1/30/3)12 IMenni:1.1oran Stanley Plunk." 16964 1/30/3)12 Intent: Nlorpwi
interest New York Tax Free Bonds 40,70625 2,971.70201 10/11/2011 DST C34b0111 LP (0/4210,41461 V3001 2,977,93201 10/30/2011 140,040.310w in Stanley Ban- 111134 10/30/2011 laleratAlawin Slinky Priwnerwra 1101 10/31/2011 00044 Propenkwat Dividend 749,15940 37-0,111.61 Balance *sof Octraba
EFTA00283525 The MBZ 19% Trust (GST Exempt) Cash Account Activity - As of December 31, 2012 Dale Description Morgan Stinky IP Ntotpaa Ouse Deutsche Sank US Treasury Bills ES Government Ending Agencies Balance 8/1/2013 8/14/1012 8/16/1012 8/30/1012 8/30/2012 8/30/2012 9/V/2012 9/V/2012 1
3 69. Epstein's relationship with James "Jes" Staley was a key alliance that enabled Epstein to run his illegal operation through JP Morgan. 70. Staley and JP Morgan built the financial infrastructure that allowed for Epstein's sex trafficking operation to become what it was. They had a business re
co-conspirators Lesley Groff, Sarah Kellen, and Nadia Marcinkova. The existence of co-conspirators as beneficiaries of the trust further established Deutsche Bank's actual and constructive knowledge that payments through the Trust would be used to further or coverup criminal activity and to endanger more young w
Entities connected to both Jes Staley and Deutsche Bank

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Lesley Groff
PERSON
Julie K. Brown
PERSON
Paul Morris
PERSON
Marc Rich
PERSON
Prince Andrew
PERSON
Richard Kahn
PERSONLeon Black
PERSON
United States
LOCATIONAmanda Kirby
PERSON
Martha Stewart
PERSON
Ghislaine Maxwell
PERSON
Woody Allen
PERSON
Ehud Barak
PERSONDeutsche Bank Trust Company Americas
ORGANIZATION
Prince Charles
PERSON
Lawrence Krauss
PERSON
JPMorgan Chase
ORGANIZATION
Condoleezza Rice
PERSON