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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
t Laurel, Inc. acquired ownership of the property 358 Brillo Way in Palm Beach, Florida in or about December 2011, shortly after Cyrpess was formed. Laurel acquired ownership of the property from Epstein personally. EFTA00161906 Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 38 of 77 GVI v
g.” I argued that strength was one area where we wouldn’t have to worry. “No way, in a campaign, he’ Il end up coming over looking stronger than me.” Stanley seemed not entirely convinced. Both in “strength” and other ways, I think my background did prove an advantage. The 35 years I’d spent in the milita
um. We began working with all of them well before the no-confidence vote in the Knesset. Philip had a wonderfully British understatement and reserve. Stanley, with his eyeglasses and demeanor too, came over as slightly professorial. With Bob, it didn’t take long to understand why he was such a gifted speec
wasn’t. I was trying to find the least diplomatically damaging way to navigate the period until the President’s return. I couldn’t see showing up at Laurel at every mealtime, mingling and joking with the Americans and Palestinians, but refusing to enter into any form of negotiations. That would compound
ng." I argued that strength was one area where we wouldn't have to worry. "No way, in a campaign, he'll end up coming over looking stronger than me." Stanley seemed not entirely convinced. Both in "strength" and other ways, I think my background did prove an advantage. The 35 years I'd spent in the militar
um. We began working with all of them well before the no-confidence vote in the Knesset. Philip had a wonderfully British understatement and reserve. Stanley, with his eyeglasses and demeanor too, came over as slightly professorial. With Bob, it didn't take long to understand why he was such a gifted speec
wasn't. I was trying to find the least diplomatically damaging way to navigate the period until the President's return. I couldn't see showing up at Laurel at every mealtime, mingling and joking with the Americans and Palestinians, but refusing to enter into any form of negotiations. That would compound
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
s expenses incurred during each of these years by omitting the annual amounts of property taxes it paid for the New York property. 414. Defendant Laurel misrepresented the value of its assets held during each of these years by omitting the value of the 358 Brillo Way, Palm Beach, Florida property tha
t Laurel, Inc. acquired ownership of the property 358 Brillo Way in Palm Beach, Florida in or about December 2011, shortly after Cyrpess was formed. Laurel acquired ownership of the property from Epstein personally. EFTA00162322 daelnazati-lThh1BER fiamiumetttafill FFilleildraB1233 Flgaffe fatal/2/3
8. 412. Defendant Cypress misrepresented the value of its assets held during each of these years by omitting the value of the 49 Zorro Ranch Road, Stanley, New Mexico property that it EFTA00161940 Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 72 of 77 GVI v. Estate of Jeffrey Epstein GVI
s expenses incurred during each of these years by omitting the annual amounts of property taxes it paid for the New York property. 414. Defendant Laurel misrepresented the value of its assets held during each of these years by omitting the value of the 358 Brillo Way, Palm Beach, Florida property tha
predicate acts as defined by CICO, including but not limited to making fraudulent claims upon the Government. 411. Defendants Cypress, Maple, and Laurel misrepresented the values of their assets held and expenses incurred in their annual reporting to the Government of the United States Virgin Island
, 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
E UNITED STATES VIRGIN ISLANDS THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT, WITH Laurel ICSDec 2018009/09/20197:33 PM Ms. Erika KELLERHALS Esq Attorney in Fact President Jeffrey EPSTEIN 07/31/2019 Richard KAHN Treasurer 07/31/201
Entities connected to both Jes Staley and Laurel

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Prince Andrew
PERSON
Marc Rich
PERSONLeon Black
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
Woody Allen
PERSON
Ehud Barak
PERSON
Ghislaine Maxwell
PERSON
Joe Biden
PERSON
Harry Reid
PERSON
George Mitchell
PERSON
Condoleezza Rice
PERSON
John F. Kennedy
PERSON
Robert Gates
PERSON
United States
LOCATION
Peter Mandelson
PERSON
George W. Bush
PERSON
Stephen Hawking
PERSON