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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
them were officers or directors of Butterfly Trust; of companies holding Epstein's real property (as laid out below); and of ; FT Real Estate Inc.; Gratitude America, Inc.; J. Epstein Virgin Islands Foundation, Inc.; Jeepers, Inc.; Mort, Inc.; Nautilus, Inc.; and Zorro Development Corporation; among others. 81. Alo
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
them were officers or directors of Butterfly Trust; of companies holding Epstein's real property (as laid out below); and of ; FT Real Estate Inc.; Gratitude America, Inc.; J. Epstein Virgin Islands Foundation, Inc.; Jeepers, Inc.; Mort, Inc.; Nautilus, Inc.; and Zorro Development Corporation: among others. 81. Alo
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
ERICA LTD 29.GRATITUDE AMERICA LTD has been linked to Jeffrey EPSTEIN in open source reporting. 30.In April 2018 Deutsche Bank account AC veld by GRATITUDE AMERICA LTD sent EUR 15,000.00 to a Lithuanian Vilniaus Bankas AB account AC held by NPO BALETO TEATFtAS. EFTA01721772 31.In October 2018 Deutsche Bank acco
had drawn the attention of top executives of JPMorgan, where he was a client. One of the executives told the newly named head of its private bank, Jes Staley, to get to know Mr. Epstein, according to a person familiar with the matter. Mr. Epstein was a master at introducing an eclectic mix of wealthy, con
n was a master at introducing an eclectic mix of wealthy, connected people to each other, and he started connecting a string of acquaintances to Mr. Staley and recommending JPMorgan's private bank—something he would do for another seven years—a person close to the relationship said. Mr. Epstein connect
. The spokeswoman said his name mistakenly appeared on the filings until 2012, when it was noticed and subsequent filings were corrected. In 2015, Gratitude America Ltd., a Virgin Islands-based foundation associated with Mr. Epstein, received a $10 million cash gift from a Black-related entity, according to charity f
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
y Epstein VI Foundation, also made a number of charitable donations through his three private charities: Epstein Interest, the COUQ Foundation, and Gratitude American Ltd. According to federal tax filings, Epstein donated $30 million between 1998 and 2018, through these three charities.(279) Following his death, a num
prime minister. Howard also lost his own seat of Bennelong at the election to Maxine Wks!, becoming only the second prime minister to do so, after Stanley. Brace in 1929. Following this loss, Howard retired from politics. The Honourable John Howard 9M 69 Howard in 2001 25th Prime Miter of Australi
y Epstein VI Foundation, also made a number of charitable donations through his three private charities: Epstein Interest, the COUQ Foundation, and Gratitude American Ltd. According to federal tax filings, Epstein donated $3o million between 1998 and 2018, through these three charities.(279] Following his death, a nu
Entities connected to both Jes Staley and Gratitude America

Jeffrey Epstein
PERSON
Lesley Groff
PERSONDarren Indyke
PERSON
Prince Andrew
PERSON
Marc Rich
PERSONLeon Black
PERSON
Richard Kahn
PERSON
Woody Allen
PERSON
Ehud Barak
PERSONSouthern Trust Company
ORGANIZATION
Ghislaine Maxwell
PERSON
Joe Biden
PERSON
George Mitchell
PERSON
Condoleezza Rice
PERSON
Alan Dershowitz
PERSONZorro Management LLC
ORGANIZATIONHyperion Air
ORGANIZATION
Lawrence Krauss
PERSON
Robert Gates
PERSON
United States
LOCATION