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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
ed in carrying out, facilitating and concealing Epstein's crimes, hence Little St. James became an instrumentality of those crimes. 28. Defendant, Great St. Jim, LLC, is a limited liability company established and organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26,
s president of Poplar, Inc. and expressly authorizes the incorporators to conduct "transactions related to permitting matters submitted on behalf of Great St. Jim, LLC." 32. Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim, LLC, and the signature appears to be Epstein's. T
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
s president of Poplar, Inc. and expressly authorizes the incorporators to conduct "transactions related to permitting matters submitted on behalf of Great St. Jim, LLC." 32. Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim, LLC, and the signature appears to be Epstein's. T
ed in carrying out, facilitating and concealing Epstein's crimes, hence Little St. James became an instrumentality of those crimes. 28. Defendant, Great St. Jim, LLC, is a limited liability company established and organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26,
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
onsists 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 limited liability company, which holds legal title to said property, rights, permits, improvements and fixture
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
Y_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 limited liability company, which holds legal title to said property, rights, permits, improvements and fixture
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
onsists 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 limited liability company, which holds legal title to said property, rights, permits, improvements and fixtures
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
ommon 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 limited liability company, which holds legal title to said property, rights, permits, improvements and fixture
Entities connected to both Jes Staley and Great St. James

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Prince Andrew
PERSON
Marc Rich
PERSONDarren Indyke
PERSON
Woody Allen
PERSON
Richard Kahn
PERSON
Ghislaine Maxwell
PERSON
Boris Nikolic
PERSON
Condoleezza Rice
PERSON
George Mitchell
PERSON
Lawrence Krauss
PERSON
United States
LOCATION
Larry Summers
PERSON
George W. Bush
PERSON
U.S. Virgin Islands
LOCATIONBrice Gordon
PERSON
David Mitchell
PERSON
Glenn Dubin
PERSON
New York
LOCATION