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

ations of Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges

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

ations of Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges

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

ations of Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges

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

of this Honorable Court. 9) Although Petitioners are not residents of the Virgin Islands, they are qualified to serve as Executors pursuant to 15 V.I.C. § 235(c) because they otherwise qualify under 15 V.I.C. § 235(a) and they have appointed the law firm of Kellerhals Ferguson Kroblin PLLC, which ha

, and an updated value will be provided upon completion. 17 Cypress, Inc. holds cash on hand and title to the real property known as Zorro Ranch in Stanley, New Mexico and all appurtenant rights, which for purposes of this inventory has been valued at the underlying real property's most recent tax asse

FOR DENIAL, SUBSEQUENT REVOCATION OF REGISTRATION, OR OTHER FINES AND PENALTIES PURSUANT TO THE FRAUDULENT CLAIMS STATUTE AS SET FORTH IN 14 V.I.C. § 843. Ms. Erika Kellerhals Yes Submitted By ERIKA KELLERHAIS EFTA00076521 Particulars of Annual Report Filing 2019 MICHELLE'S TRANSPORTATION

, and an updated value will be provided upon completion. 17 Cypress, Inc. holds cash on hand and title to the real property known as Zorro Ranch in Stanley, New Mexico and all appurtenant rights, which for purposes of this inventory has been valued at the underlying real property's most recent tax asse

FOR DENIAL, SUBSEQUENT REVOCATION OF REGISTRATION, OR OTHER FINES AND PENALTIES PURSUANT TO TIIE FRAUDULENT CLAIMS STATUTE AS SET FORTH IN 14 V.I.C. § 843. Ms. Erika Kellerhals Yes Submitted By ERIKA KELLERHALS EFTA00076922 Particulars of Annual Report Filing 2019 MICHELLE'S TRANSPORTATION

ctor of each of Cypress, Inc.; Maple, Inc.; and Laurel, Inc. 179. Defendant Cypress, Inc. acquired ownership of the property 49 Zone Ranch Road in Stanley, New Mexico in or about December 2011, shortly after Cypress was formed. 180. Defendant Maple, Inc. acquired ownership of the property 9 East 71st

ceased. COUNT ONE Human Trafficking — Trafficking an Individual Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"), 14 V.I.C. § 600 et seq. and 14 V.I.0 § 133 216. The Government restates and realleges paragraphs 1 to 215 of this Complaint as if fully set forth herein. 2

8. 412. Defendant Cypress misrepresented the value of its assets held during each of these years by omitting the value of the 49 Zorro Ranch Road, Stanley, New Mexico property that it EFTA00161940 Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 72 of 77 GVI v. Estate of Jeffrey Epstein GVI

s engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. COUNT TWENTY-TWO Civil Conspiracy 382. The Government restates and realleges paragraphs 1 to 381 of this Complaint as if fully set