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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
SF2 Ceonomati85(11. FIRIck001/1/30123 Paggel8 of 123 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 7 of 76 30. Defendant, Poplar, Inc., is a corporation established and organized under the laws of the Virgin Islands. Poplar, Inc. was incorporated on November 22, 2011. Epstein was p
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
cond Amended Complaint Page 7 of 76 30. Defendant. Poplar. Inc.. is a corporation established and organized under the laws of the Virgin Islands. Poplar, Inc. was incorporated on November 22, 2011. Epstein was president and director of Poplar, Inc., and its purpose was described in corporate filings as "h
Islands co ration which holds title to New York, NY 10021 10,000 shares of Cypress, Inc., a U.S. Virgin Islands Co oration which holds tide to Stanley, New Mexico 87056 10,000 shares of Laurel, Inc., a U.S. Virgin Islands • - title to a eac r, H on a 999 shares of SCI JEP, a French Company w
subject to appraisal/valuation $ 194,986,301.00 $ 55,931,000.00 $ 17,246,208.00 $ 12,380,209.00 Paris, France $ 8,672,823.00 10,000 shares of Poplar, Inc., a U.S. Virgin Islands Corporation, which holds title to Great St.lames Island $ 22,498,600.00 10,000 shares of Nautilus, Inc., a U.S. Virgin Isl
terest in the property, leases, rights, permits, improvements and fixtures comprising and pertaining to Zorro Ranch, located at 49 Zorro Ranch Road, Stanley, New Mexico. My interest consists of 10,000 shares of common stock of Cypress, Inc., a United States Virgin Islands CONFICVENTIAL SONY_GM00007687
and pertaining to the island known as Great St. James, located in the U.S. Virgin Islands. My interest consists of 10,000 shares of common stock of Poplar, Inc. a United States Virgin Islands corporation, which holds all of the membership interests of Great St. Jim, LLC, a United States Virgin Islands limit
erest in the property, leases, tights, permits, improvements and fixtures comprising and pertaining to Zorro Ranch, located at 49 Zorro Ranch Road, Stanley, New Mexico. My interest consists of 10,000 shares of common stock of Cypress, Inc., a United States Virgin Islands corporation, which holds legal t
the U.S. Virgin Islands. My interest consists of 10,000 shares of common stock of 10 CONFIDENTIAL SONY_GM_00007757 EFTA_00120429 EFTA01266213 Poplar, Inc. a United States Virgin Islands corporation, which holds all of the membership interests of Great St. Jim, LLC, a United States Virgin Islands limite
terest in the property, leases, rights, permits, improvements and fixtures comprising and pertaining to Zorro Ranch, located at 49 Zorro Ranch Road, Stanley, New Mexico. My interest consists of 10,000 shares of common stock of Cypress, Inc., a United States Virgin Islands corporation, which holds legal
and pertaining to the island known as Great St. James, located in the U.S. Virgin Islands. My interest consists of 10,000 shares of common stock of Poplar, Inc. a United States Virgin Islands corporation, which holds all of the membership interests of Great St. Jim, LLC, a United States Virgin Islands limite
erest in the property, leases, rights, permits, improvements and fixtures comprising and pertaining to Zorro Ranch, located at 49 Zorro Ranch Road, Stanley, New Mexico. My interest consists of 10,000 shares of common stock of Cypress, Inc., a United States Virgin Islands corporation, which holds legal t
known as Great St James, located in the U.S. Virgin Islands. My interest consists of 10,000 shares of common stock of 10 GJ 00010 EFTA00099312 Poplar, Inc. a United States Virgin Islands corporation, which holds all of the membership interests of Great St. Jim, LLC, a United States Virgin Islands limite
Entities connected to both Jes Staley and Poplar, Inc.

Jeffrey Epstein
PERSON
Lesley Groff
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
Ghislaine Maxwell
PERSON
Boris Nikolic
PERSON
George Mitchell
PERSON
Condoleezza Rice
PERSON
Lawrence Krauss
PERSON
United States
LOCATION
U.S. Virgin Islands
LOCATIONBrice Gordon
PERSON
David Mitchell
PERSON
Glenn Dubin
PERSON
New York
LOCATION
Prince Charles
PERSON
Joi Ito
PERSON
JPMorgan Chase
ORGANIZATION
Les Wexner
PERSONLarry Visoski
PERSON