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

o JP Morgan. 67. Epstein and/or his associates also made significant cash withdrawals and 95 foreign remittances with no known payee. For example, Hyperion Air, Inc.—the Epstein-controlled company that owned Epstein's private jet—issued over $547,000 in checks payable to cash purportedly for "fuel expenses

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

o JP Morgan. 67. Epstein and/or his associates also made significant cash withdrawals and 95 foreign remittances with no known payee. For example, Hyperion Air, Inc.—the Epstein-controlled company that owned Epstein's private jet—issued over $547,000 in checks payable to cash purportedly for "fuel expenses

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

o JP Morgan. 67. Epstein and/or his associates also made significant cash withdrawals and 95 foreign remittances with no known payee. For example, Hyperion Air, Inc.—the Epstein-controlled company that owned Epstein's private jet—issued over $547,000 in checks payable to cash purportedly for "fuel expenses

clear that if she did not abide then she would suffer serious financial and reputational harm), through the end of 2013. 115. James "Jes" Staley ("Staley"), the then-head of JP Morgan's private banking division, was a regular visitor of Epstein's during that period of time, through and beyond 2013, a

e an intentional decision to keep Epstein on as a client. 217. JP Morgan, including its CEO Jamie Dimon and the highest levels of the bank, knew of Jes Staley's personal involvement with Epstein and yet still allowed Staley to remain a decision maker for JP Morgan on Epstein accounts. 218. Even before the s

g to JP Morgan. Epstein and/or his associates also made significant cash withdrawals and 95 foreign remittances with no known payee. For example, Hyperion Air, Inc.—the Epstein- controlled company that owned Epstein's private jet— issued over $547,000 in checks payable to cash purportedly for "fuel expense

, 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

.00 11 ■ Zorro Management, LLC -0- 12 • Neptune, LLC -0- 13 ■ NES, LLC -0- 14 • Plan D, LLC10 17,000,000.00 15 • JEGE, LLC -0- 16 ■ Hyperion Air, LLCII 4,200,000.00 17 • Thomas World Air, LLC 25,000.00 18 • LSJ Emergency, LLC -0- 19 ■ Southern Financial, LLC12 176,961,338.00 20 ■

, 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

.00 11 ■ Zorro Management, LLC -0- 12 • Neptune, LLC -0- 13 ■ NES, LLC -0- 14 • Plan D, LLC10 17,000,000.00 15 • JEGE, LLC -0- 16 ■ Hyperion Air, LLCII 4,200,000.00 17 • Thomas World Air, LLC 25,000.00 18 • LSJ Emergency, LLC -0- 19 ■ Southern Financial, LLC12 176,961,338.00 20 ■