EFTA00145666.txt

"Plaintiff Government of the United States Virgin Islands ("Government") files this Complaint against JPMorgan Chase Bank, N.A. ("JP Morgan")"

"JPMORGAN CHASE BANK, N.A. Third-Party Plaintiff, V. JAMES EDWARD STALEY Third-Party Defendant"

"combination of such means to sexually abuse young women and underage girls"

"Epstein's pattern and practice to use the channels and instrumentalities of interstate and foreign commerce to recruit, entice, harbor, transport, pro"

"Epstein-controlled entities located in the Virgin Islands"

"Epstein—a Virgin Islands resident"

"Hyperion Air, Inc.—the Epstein-controlled company"

"In 2004, Epstein introduced Staley to Glenn Dubin"

"Epstein helped, or promised to help, Staley recruit ultrawealthy clients to JP Morgan"

"Epstein moved his accounts to Deutsche Bank from 2013 to 2018"

"and over $20,000 to a company called Phoenix Realty Home Inc."

"On July 6, 2020, the NYSDFS and Deutsche Bank entered into a Consent Order with a $150 million penalty"

"young women and/or underage girls who were sexually abused and coerced into engaging in commercial sexual acts"

"indicted Epstein's co-conspirator, Ghislaine Maxwell, for conspiracy to entice minor victims to travel to be abused by Epstein"

"Epstein's co-conspirator, Ghislaine Maxwell"

"Epstein, who resided in the Virgin Islands"

"MC2 Model Management received $1 million from Epstein in 2005"

"sentenced to 20 years in prison for conspiring with Epstein to sexually abuse minors"

"These communications show a close personal relationship and "profound" friendship between the two men"

"On January 8, 2009... Epstein wired $2,000 from his JP Morgan account to a woman with an Eastern European surname"

"On August 31, 2009, Epstein wired $3,000 from his JP Morgan account to the same Eastern European woman"

"Epstein paid more than $600,0000 to Jane Doe I, a woman who... Epstein purchased at the age of 14"

"Epstein paid more than $600,0000 to Jane Doe I"

"Staley emailed Epstein, referring to Little St. James, 'Arrived at your harbor.'"

"Epstein also transferred more than $23 million dollars to Ghislaine Maxwell between 1999 and 2002"

"Epstein paid her more than $600,000, from his accounts at JP Morgan"

"A recruiter given immunity through Epstein's non-prosecution agreement was paid more than $728,000 from Epstein's JP Morgan accounts"

"the Southern Trust Company—one of the companies Epstein owned"

"Epstein used his wealth and power to create the Epstein Enterprise"

"Epstein's lawyer, Darren K. Indyke"

"accountant, Richard Kahn"

"payments drawn from JP Morgan accounts of nearly $1.5 million to known recruiters, including to the MC2 modeling agency"

"Jeffrey Epstein was a resident of the Virgin Islands"

"the Government filed a lawsuit against Jeffrey Epstein's estate... for violation of the CICO Act"

"Epstein's commission of the forcible commercial sex acts with women and girls in the Virgin Islands"

"The Attorney General of the United States Virgin Islands... brings this parens patriae action on behalf of the Plaintiff, Government of the Virgin Isl"

"Epstein and/or his representatives appeared to be misusing JP Morgan accounts for Epstein's purported charitable organizations, including the C.O.U.Q."

"Epstein and/or his representatives appeared to be misusing JP Morgan accounts for Epstein's purported charitable organizations, including... Enhanced "

"used the C.O.U.Q. Foundation account to pay $29,464.66 to three young women, including two known victims"

"JP Morgan continued its affirmative conduct of allowing Epstein to access cash so that he could make those cash payments to his co-conspirators"

"MOTLEY RICE LLC... Attorneys for Plaintiff Government of the United States Virgin Islands"

"Carol Thomas-Jacobs (pro hac vice) Acting Attorney General of the United States Virgin Islands Virgin Islands Department of Justice"

"Jean Luc Brunel... and Jeffrey Epstein engaged in racketeering that involved luring in minor children for sexual play for money"

"His foundation account did pay donations to the Palm Beach Police Dept"

"Staley was presumably visiting Little St. James, saying: 'So when all hell breaks lo[o]se... I will come here'"

"He is also an alleged personal associate of the CEO of the Investment Bank (Jes Staley)"