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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
EL, INC.; AND JOHN AND JANE DOES, DEFENDANTS. Case No.: ST-20-CV-14 ACTION FOR DAMAGES JURY TRIAL DEMANDED SECOND AMENDED COMPLAINT COMES NOW, the Government of the United States Virgin Islands ("Government") and files this Second Amended Complaint containing information that has become known through further investigation and third-party d
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
EL, INC.; AND JOHN AND JANE DOES, DEFENDANTS. Case No.: ST-20-CV-14 ACTION FOR DAMAGES JURY TRIAL DEMANDED SECOND AMENDED COMPLAINT COMES NOW, the Government of the United States Virgin Islands ("Government") and files this Second Amended Complaint containing information that has become known through further investigation and third-party d
rd-Party Plaintiff, ) ) V. ) ) JAMES EDWARD STALEY ) ) Third-Party Defendant. ) ) STIPULATED
EOMATERIALS AND PHOTOGRAPHS FOR THE PRESENCE OF POTENTIAL CHILD SEX ABUSE MATERIALS AND FOR DISCLOSURE OF THOSE MATERIALS Plaintiffs Jane Doe 1 and the Government of the United States Virgin Islands ("Government"), by their respective counsel, move pursuant to Federal Rules of Civil Procedure 26(c), and the authority of the Court to administer
rd-Party Plaintiff, ) ) V. ) ) JAMES EDWARD STALEY ) ) Third-Party Defendant. ) ) Case Numbe
EOMATERIALS AND PHOTOGRAPHS FOR THE PRESENCE OF POTENTIAL CHILD SEX ABUSE MATERIALS AND FOR DISCLOSURE OF THOSE MATERIALS Plaintiffs Jane Doe 1 and the Government of the United States Virgin Islands ("Government"), by their respective counsel, move pursuant to Federal Rules of Civil Procedure 26(c), and the authority of the Court to administer
Entities connected to both Jes Staley and the Government of the United States Virgin Islands

Jeffrey Epstein
PERSON
Prince Andrew
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
Ghislaine Maxwell
PERSON
Condoleezza Rice
PERSON
United States
LOCATION
Bradley Edwards
PERSON
George W. Bush
PERSON
U.S. Virgin Islands
LOCATION
Glenn Dubin
PERSON
New York
LOCATION
Prince Charles
PERSON
JPMorgan Chase
ORGANIZATION
Les Wexner
PERSONLarry Visoski
PERSON
Sarah Ferguson
PERSON
David Boies
PERSON
Palm Beach
LOCATIONFBI
ORGANIZATION