EFTA00161836Set 9
2023-01-10122p31,654w
through which recruiters and victims were paid and was
indispensable to the operation and concealment of the Epstein trafficking enterprise. Financial
institutions can connect—or choke—human trafficking networks ... documents reviewed and interviews conducted by
the Government, JP Morgan knowingly facilitated, sustained, and concealed the human trafficking
network operated by Jeffrey Epstein from his home and base ... Document 16 Filed 01/10/23 Page 3 of 34
regulations, JP Morgan facilitated
and concealed wire and cash transactions that raised suspicion of—and were in fact part of—a
criminal
https://www.justice.gov/epstein/files/DataSet%209/EFTA00161836.pdf
EFTA00073205Set 9
2020-09-0155p15,254w
known to the
Government of the Virgin Islands, through which he carried out and concealed his criminal
conduct.
18. Epstein regularly created new entities in the territory and transferred properties ... them in order to preserve and shield Epstein's assets and to facilitate and conceal
the unlawful acts described in this Complaint.
19. These entities held properties, including Little ... escaping the abuse.
26. Thus, Nautilus, Inc. participated in carrying out, facilitating and concealing
Epstein's crimes, hence Little St. James became an instrumentality of those crimes.
27. Defendant, Great
https://www.justice.gov/epstein/files/DataSet%209/EFTA00073205.pdf
EFTA00018778Set 8
2020-09-0155p15,251w
known to the
Government of the Virgin Islands, through which he carried out and concealed his criminal
conduct.
18. Epstein regularly created new entities in the territory and transferred properties ... them in order to preserve and shield Epstein's assets and to facilitate and conceal
the unlawful acts described in this Complaint.
19. These entities held properties, including Little ... escaping the abuse.
26. Thus, Nautilus, Inc. participated in carrying out, facilitating and concealing
Epstein's crimes, hence Little St. James became an instrumentality of those crimes.
27. Defendant, Great
https://www.justice.gov/epstein/files/DataSet%208/EFTA00018778.pdf
EFTA00811809Set 9
2018-08-2251p13,267w
Hoffenberg ("Hoffenberg"). Epstein used The Financial Trust Company,
XYZ Corp., and ABC, Inc. to conceal his ill-gotten gains, obtained from his participation in a
Defendant Epstein is sued herein ... following Hoffenberg's conviction and the several related civil
lawsuits, Defendants' involvement was purposefully concealed and not revealed until Hoffenberg's
2 In United States of America v. Steven Hoffenberg ... funds borrowed by
using insurance company bonds as collateral.
34. Defendant Epstein and Hoffenberg concealed their unsavory activities through many
deceptive actions, including but not limited to, routing all securities
https://www.justice.gov/epstein/files/DataSet%209/EFTA00811809.pdf
EFTA00809690Set 9
2018-08-2251p13,224w
Hoffenberg ("Hoffenberg"). Epstein used The Financial Trust Company,
XYZ Corp., and ABC, Inc. to conceal his ill-gotten gains, obtained from his participation in a
Defendant Epstein is sued herein ... following Hoffenberg's conviction and the several related civil
lawsuits, Defendants' involvement was purposefully concealed and not revealed until Hoffenberg's
2 In United States ofAmerica v. Steven Hoffenberg ... funds borrowed by
using insurance company bonds as collateral.
34. Defendant Epstein and Hoffenberg concealed their unsavory activities through many
deceptive actions, including but not limited to, routing all securities
https://www.justice.gov/epstein/files/DataSet%209/EFTA00809690.pdf
EFTA00086802Set 9
2019-08-1049p12,929w
Government of the Virgin Islands, through which he carried out and concealed his criminal
conduct.
16. Epstein regularly created new entities in the territory and transferred properties and
funds between ... them in order to preserve and shield Epstein's assets and to facilitate and conceal
the unlawful acts described in this Complaint.
17. These entities held properties, including Little ... escaping the abuse.
24. Thus, Nautilus, Inc. participated in carrying out, facilitating and concealing
Epstein's crimes, hence Little St. James became an instrumentality of those crimes.
25. Defendant, Great
https://www.justice.gov/epstein/files/DataSet%209/EFTA00086802.pdf
EFTA00104291Set 9
2020-01-1549p13,383w
Government of the Virgin Islands, through which he carried out and concealed his criminal
conduct.
16. Epstein regularly created new entities in the territory and transferred properties and
funds between ... them in order to preserve and shield Epstein's assets and to facilitate and conceal
the unlawful acts described in this Complaint.
17. These entities held properties, including Little ... escaping the abuse.
24. Thus, Nautilus, Inc. participated in carrying out, facilitating and concealing
Epstein's crimes, hence Little St. James became an instrumentality of those crimes.
25. Defendant, Great
https://www.justice.gov/epstein/files/DataSet%209/EFTA00104291.pdf
EFTA00597318Set 9
2017-08-1133p10,597w
essence, however, this case remains a simple one. The Government cannot contest that it
concealed from the victims a non-prosecution agreement (NPA) that it reached with a sex
offender ... claims concerning the
Government violating their CVRA rights. Undisputed facts show the Government's
concealment of the NPA. And, in the particular circumstances of this case, that concealment
clearly violated ... Attorney, Wilfredo Ferrer. She explained to
him how the NPA had been concealed from her. Id. at 46,1 154.
At no time while it negotiated and executed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00597318.pdf
EFTA00104216Set 9
2019-08-1049p12,907w
Government of the Virgin Islands, through which he carried out and concealed his criminal
conduct.
16. Epstein regularly created new entities in the territory and transferred properties and
funds between ... them in order to preserve and shield Epstein's assets and to facilitate and conceal
the unlawful acts described in this Complaint.
17. These entities held properties, including Little ... escaping the abuse.
24. Thus, Nautilus, Inc. participated in carrying out, facilitating and concealing
Epstein's crimes, hence Little St. James became an instrumentality of those crimes.
25. Defendant, Great
https://www.justice.gov/epstein/files/DataSet%209/EFTA00104216.pdf
EFTA00074744Set 9
2019-08-15118p27,690w
complaint lays out in detail,
Epstein and his associates went to great length to conceal their conduct. Compl. 70-89.
5
EFTA00074762
•
Additionally, the Program implicitly assumes that Claimants have ... share evidence with law enforcement, thus positioning the Fund as a
potential means to conceal criminal activity.
e. The Epstein Fund Presents Unavoidable Conflicts of Interest
The Motion fails ... Government of the Virgin Islands, through which he carried out and concealed his criminal
conduct.
16. Epstein regularly created new entities in the territory and transferred properties and
funds between
https://www.justice.gov/epstein/files/DataSet%209/EFTA00074744.pdf
EFTA01125419Set 9
2012-01-03101p22,011w
defraud the United States of certain taxes due and owing, among
other things, concealing from the Internal Revenue Service
("IRS") undeclared accounts owned by U.S. taxpayers at Wegelin
and other ... funds from Switzerland to U.S. taxpayer-
clients in a manner that facilitated the continued concealment of
these undeclared accounts from the IRS. The high volume of other
transactions and other ... with the foreign correspondent financial
institution's customer, criminals and terrorists can
more easily conceal the source and use of illicit
funds. Consequently, each U.S. bank, including all
overseas branches
https://www.justice.gov/epstein/files/DataSet%209/EFTA01125419.pdf
EFTA00178057Set 9
2011-05-0290p23,378w
equally troublingly, the Government did not treat the victims with fairness when it
concealed the existence of this agreement from the victims for many months. Accordingly, the
Court should hold ... violated these CVRA rights of Jane Doe #1 and Jane Doe #2 by deliberately
concealing from them its negotiation and agreement to a non-prosecution agreement barring the
15
EFTA00178071 ... confer), #8 (Jane Doe #2 told
the same thing), #I9 (Government wanted to conceal non-prosecution agreement to avoid public
6 The Government asserts that the victims only "became interested
https://www.justice.gov/epstein/files/DataSet%209/EFTA00178057.pdf
EFTA01433867Set 10
2018-08-2029p7,744w
Hoffenberg ("Hoffenberg"). Epstein used The
Financial Trust Company,
XYZ Corp., and ABC, Inc. to conceal his ill-gotten gains, obtained from his
participation in a
INITIAL COMPLAINT
ECF CASE
Case ... following Hoffenberg's conviction and the
several related civil
lawsuits, Defendants' involvement was purposefully concealed and not
revealed until Hoffenberg's
2
In United States of America v. Steven Hoffenberg ... funds borrowed by
using insurance company bonds as collateral.
34.
Defendant Epstein and Hoffenberg concealed their unsavory activities through
many
deceptive actions, including but not limited to, routing all securities
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01433867.pdf
EFTA00796015Set 9
2018-08-2126p7,735w
Hoffenberg ("Hoffenberg"). Epstein used The Financial Trust Company,
XYZ Corp., and ABC, Inc. to conceal his ill-gotten gains, obtained from his participation in a
Defendant Epstein is sued herein ... following Hoffenberg's conviction and the several related civil
lawsuits, Defendants' involvement was purposefully concealed and not revealed until Hoffenberg's
In United States of America v. Steven Hoffenberg ... funds borrowed by
using insurance company bonds as collateral.
34. Defendant Epstein and Hoffenberg concealed their unsavory activities through many
deceptive actions, including but not limited to, routing all securities
https://www.justice.gov/epstein/files/DataSet%209/EFTA00796015.pdf
EFTA00145666Set 9
2023-04-1242p11,653w
through which recruiters and victims were paid and was
indispensable to the operation and concealment of the Epstein trafficking enterprise. Financial
institutions can connect—or choke—human trafficking networks ... documents reviewed and interviews conducted by
the Government, JP Morgan knowingly facilitated, sustained, and concealed the human trafficking
network operated by Jeffrey Epstein from his home and base ... indirectly, by failing to comply with federal banking
regulations, JP Morgan facilitated
and concealed wire and cash transactions that raised suspicion of—and were in fact part of—a
criminal
https://www.justice.gov/epstein/files/DataSet%209/EFTA00145666.pdf
EFTA00591605Set 9
2016-02-1057p17,296w
state court plea in June of 2008, the Office—doing Epstein's bidding—assiduously
concealed the NPA's existence from the victims. While this indulgent deal was incredible ... undisputed facts show that for nine months, the Government and Epstein conspired
to conceal the NPA from the victims to prevent them from voicing any objection, and to avoid ... secret
from the victims and, indeed, had sought assurances to that effect.'
NEGOTIATIONS ABOUT CONCEALING THE NPA FROM THE VICTIMS
49. After the NPA was signed, Epstein's counsel
https://www.justice.gov/epstein/files/DataSet%209/EFTA00591605.pdf