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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
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 Islands corporation that was formed and first licensed in or about November 2011. As of December 31, 2018, Epstein was listed as Presid
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
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 Islands corporation that was formed and first licensed in or about November 2011. As of December 31, 2018, Epstein was listed as Presid
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
nc. 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 Street in New York, New York on or about December 23, 2011, shortly after Maple was formed. Maple ac
Entities connected to both Jes Staley and Defendant Maple, Inc.

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
Condoleezza Rice
PERSON
United States
LOCATION
Glenn Dubin
PERSON
U.S. Virgin Islands
LOCATION
New York
LOCATION
Prince Charles
PERSON
JPMorgan Chase
ORGANIZATION
Les Wexner
PERSONLarry Visoski
PERSON
Palm Beach
LOCATIONJane Doe
PERSON
Federal Reserve
ORGANIZATIONSouthern District
LOCATION
Apple
ORGANIZATION
Financial Trust Company
ORGANIZATION
Washington D.C.
LOCATIONHBRK Associates
ORGANIZATION