Epstein Secrets

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

g 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. Along with their officer and director roles, Defendants Kahn and

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

g 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. Along with their officer and director roles, Defendants Kahn and

rning Jeffrey Epstein's involvement in J.P. Morgan's investment in Highbridge Capital Management, including but not limited to Your introduction to Jes Staley. 8. All documents concerning this arbitration. 9. All documents concerning the Settlement Agreement and Release. 10. All documents concerning t

ding but not limited to Your introduction to Jes Staley. 8. All documents concerning this arbitration.

nd the basis of the claim of privilege asserted. DEFINITIONS 1. "Third-Party Claimants" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeepers, Inc. and includes all their directors, officers, employees, representatives, agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyo

Epstein's involvement in J.P. Morgan's investment in Highbridge Capital Management, including but not limited to the introduction of Glenn Dubin to Jes Staley. 8. All documents concerning this arbitration. 9. All documents concerning the Settlement Agreement and Release. 10. All documents concerning t

imited to the introduction of Glenn Dubin to Jes Staley. 8. All documents concerning this arbitration.

nd the basis of the claim of privilege asserted. DEFINITIONS 1. "Third-Party Claimants" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeepers, Inc. and includes all their directors, officers, employees, representatives, agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyo

Epstein's involvement in J.P. Morgan's investment in Highbridge Capital Management, including but not limited to the introduction of Glenn Dubin to Jes Staley. 8. All documents concerning this arbitration. 9. All documents concerning the Settlement Agreement and Release. 10. All documents concerning t

imited to the introduction of Glenn Dubin to Jes Staley. 8. All documents concerning this arbitration.

nd the basis of the claim of privilege asserted. DEFINITIONS 1. "Third-Party Claimants" means Jeffrey Epstein, Financial Trust Company, Inc. and Jeepers, Inc. and includes all their directors, officers, employees, representatives, agents, parents, subsidiaries, predecessors, affiliates, divisions, and anyo

Epstein's involvement in J.P. Morgan's investment in Highbridge Capital Management, including but not limited to the introduction of Glenn Dubin to Jes Staley. Response: Respondents object because this request is overly broad, vague, burdensome, designed to harass Respondents and/or third parties and not

imited to the introduction of Glenn Dubin to Jes Staley. Response: Respondents object because this requ

Respondents' Response to the First Set Of Document Requests By Third-Party Respondents Zwirn Entities Respondents Financial Trust Company, Inc. and Jeepers, Inc. (collectively referred to as "Respondents") hereby respond to Petitioner's First Set of Documents Requests as follows: OBJECTIONS TO DEFINITIONS AN

million in Highbridge and made other investments based on Mr. Dubin's recommendations. In 2004, Mr. Epstein brought Highbridge to the attention of Jes Staley, then the CEO of J.P. Morgan Asset Management, and helped 6 EFTA00613913 facilitate J.P. Morgan's purchase of Highbridge. The deal made Mr. Dubin

stein brought Highbridge to the attention of Jes Staley, then the CEO of J.P. Morgan Asset Management, an

ether, the "Zwim Respondents") submit this pre-hearing brief in opposition to the claims by Third-Party Claimants Financial Trust Company, Inc. and Jeepers, Inc. (together, "FTC"). Preliminary Statement At no time did Daniel Zwim promise Jeffrey Epstein that FTC could immediately withdraw $80 million of its

e also owns a villa in Palm Beach, Florida, an apartment in Paris, France and a 10,000-acre ranch including a 26,700-square-foot hilltop mansion in Stanley, New Mexico, south of Santa Fe. CONFIDENTIAL — PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0001564 EFTA_00015038 EFTA00165816

cial Truk Company, Inc., 2 corporation organized and existing under the laws of the United States Virgin Islands ("FTC'), is the sole shareholder of Jeepers, Inc., a corporation organized and existing.under the laws of the United States Virgin islands ("Jeepers!), which has elected to be taxed as a qualified