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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
The other time, Kahn described this payroll recipient which would not justify payments to her, but which appears to be true. 94. LSJE, LLC is a Virgin Islands Limited Liability Company that was organized on October 27, 2011. Defendants Indyke and Kahn were authorized signatories on the company's checking account. 95. Indyke 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
The other time, Kahn described this payroll recipient which would not justify payments to her, but which appears to be true. 94. LSJE, LLC is a Virgin Islands Limited Liability Company that was organized on October 27, 2011. Defendants Indyke and Kahn were authorized signatories on the company's checking account. 95. Indyke and
, 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
To Whom These Presents Shall Come: I, GREGORY R. FRANCIS, Lieutenant Governor of the Virgin Islands, do hereby certify that: LSJ EMPLOYEES, LLC a Virgin Islands Limited Liability Company, filed in the Office of the Lieutenant Governor on March 13, 2013, as provided for by law, Articles of Amendment to Articles of Organization, duly
, 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
To Whom These Presents Shall Come: I, GREGORY R. FRANCIS, Lieutenant Governor of the Virgin Islands, do hereby certify that: LSJ EMPLOYEES, LLC a Virgin Islands Limited Liability Company, filed in the Office of the Lieutenant Governor on March 13, 2013, as provided for by law, Articles of Amendment to Articles of Organization, duly
Entities connected to both Jes Staley and Virgin Islands Limited Liability Company

Jeffrey Epstein
PERSON
Prince Andrew
PERSONDarren Indyke
PERSON
Woody Allen
PERSON
Richard Kahn
PERSON
Ghislaine Maxwell
PERSON
Condoleezza Rice
PERSON
George Mitchell
PERSON
United States
LOCATION
George W. Bush
PERSON
U.S. Virgin Islands
LOCATION
Glenn Dubin
PERSON
New York
LOCATION
Prince Charles
PERSON
Joi Ito
PERSON
JPMorgan Chase
ORGANIZATION
Les Wexner
PERSON
Sarah Ferguson
PERSONLarry Visoski
PERSONErika Kellerhals
PERSON