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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
Criminal Activities 1. Defendant Southern Trust Company, Inc. 157. In October 2012, the Southern Trust Company applied for economic benefits from the Economic Development Commission ("EDC"). The EDC is a subsidiary of the Virgin Islands Economic Development Authority ("EDA"), a semi-autonomous governmental instrumentality creat
2) references of persons who have known you for (5) five years or more. Do not include relatives, present employer or employees or bank references. James E. Staley Andrew Farkas 25. Provide three (3) bank references: J.P. Morgan Chase & Co. First Bank [signature page to follow] EFTA00128871 Dated and si
ployer or employees or bank references. James E. Staley Andrew Farkas 25. Provide three (3) bank refer
the Virgin Islands in 1999 when he opened Financial Trust Company, Inc. ("FTC"). FTC was a successful Virgin Islands business and a beneficiary of the Economic Development Commission ("EDC"). Mr. Epstein is also the sole shareholder of Southern Trust Company, Inc. ("SIC") which has been recommended for benefits from the EDC and
ployer or employees or bank references. James E. Staley Andrew Farkas 25. Provide three (3) bank refer
2) references of persons who have known you for (5) five years or more. Do not include relatives, present employer or employees or bank references. James E. Staley Andrew Farkas 25. Provide three (3) bank references: J.P. Morgan Chase & Co. First Bank [signature page to follow] EFTA00294457 Dated and si
ands EFTA00294453 in 1999 when he opened Financial Trust Company, Inc. ("FTC"). FTC was a successful Virgin Islands business and a beneficiary of the Economic Development Commission CEDC"). Mr. Epstein is also the sole shareholder of Southern Trust Company, Inc. ("STC) which has been recommended for benefits from the EDC and is
Entities connected to both Jes Staley and the Economic Development Commission

Jeffrey Epstein
PERSON
Prince Andrew
PERSONDarren Indyke
PERSON
Richard Kahn
PERSONAndrew Farkas
PERSON
U.S. Virgin Islands
LOCATIONMaria Farmer
PERSON
JPMorgan Chase
ORGANIZATION
Samantha Power
PERSONLarry Visoski
PERSONErika Kellerhals
PERSONJane Doe
PERSON
Financial Trust Company
ORGANIZATIONSouthern Trust Company
ORGANIZATIONNautilus, Inc.
ORGANIZATION
Charlotte
LOCATION
Little St. James
ORGANIZATION
Monaco
LOCATIONOffice for the Southern District of Florida
ORGANIZATIONV.I.C.
ORGANIZATION