Jpmorgan Sex Trafficking Suit

Case 1:22-cv-10019 Document 1 Filed 11/24/22 Page 1 of 75
UNITED STATES DISTRICT COURT FOR THE

SOUTHERN DISTRICT OF NEW YORK
Jane Doe 1, individually and on)

behalf of all others similarly ) CLASS ACTION COMPLAINT
situated )
)
Plaintiffs, ) JURY TRIAL DEMANDED
)
)
v. ) Case Number:
)
JP Morgan Chase & Co. )
)
Defendant. )
_______________________________/
INDIVIDUAL AND CLASS ACTION COMPLAINT
Plaintiff Jane Doe 1 files this individual and civil class action complaint for
damages and other relief under (among other provisions of law) the United States
federal anti-sex trafficking statute, 18 U.S.C. §§ 1591-95, et seq.—the Trafficking
Victim Protection Act (“TVPA”)—and for intentional and negligent acts and
omissions under the New York Adult Survivors Act, N.Y. CPLR §214-j. The suit
arises from Defendant, JP Morgan Chase & Co. (hereinafter “JP Morgan”),
financially benefitting from participating in Jeffrey Epstein’s sex trafficking by
providing the requisite financial support for the continued operation of Epstein’s
international sex trafficking organization from 1998 through August 2013.
JP Morgan knowingly and intentionally benefited and received things of value
for assisting, supporting, facilitating, and otherwise providing the most critical
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service for the Jeffrey Epstein sex trafficking organization to successfully rape,
sexually assault, and coercively sex traffic Plaintiff Jane Doe 1 and the numerous
other members of the Class proposed below (the “Class”). JP Morgan knew that
Epstein was regularly committing violations of New York Penal Law Art. 130,
including, and especially, New York Penal Law §§ 130.20, 130.35, 130.50, 130.52,
and 130.66, and acted in a negligent manner so as to enable Epstein to commit such
offenses against countless young women.
JP Morgan also knew that Epstein would use means of force, threats of force,
fraud, abuse of legal process, exploitation of power disparity, and a variety of other
forms of coercion to cause young women and girls to engage in commercial sex acts.
Knowing that they would earn millions of dollars from facilitating Epstein’s sex
abuse and trafficking, JP Morgan chose profits over following the law. Specifically,
JP Morgan chose facilitating a sexual abuse and sex trafficking operation for many
years, including through the criminal investigation and incarceration of Jeffrey
Epstein, in order to churn profits.
Plaintiff makes the following allegations on information and belief and
believes that substantial additional evidentiary support will exist for the allegations
set forth herein after a reasonable opportunity for discovery:
I. JURISDICTION, VENUE, AND TIMELINESS
1. This action is brought pursuant to various federal and state statues,
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including the federal TVPA, 18 U.S.C. § 1589 through § 1595. This Court has
federal question subject-matter jurisdiction pursuant to 28 U.S.C. § 1331, because
Jane Doe 1—individually and on behalf of the other Class members—proceeds
under the federal TVPA statute.
2. This Court also has supplemental jurisdiction over the state law
claims recounted below pursuant to 28 U.S.C. § 1367(a), because all claims alleged
herein are part of a uniform pattern and practice and form part of the same case or
controversy.
3. This Court is “an appropriate district court of the United States” in
accordance with 18 U.S.C. § 1595, in which to bring this action. Venue is proper in
this District under 28 U.S.C. § 1391(b)(2), because Epstein, his co-conspirators, and
JP Morgan all conducted substantial activities in this District and knowingly aided
and abetted, facilitated, and directly participated in Epstein’s illegal venture through
actions that originated in this District. In addition, Epstein sexually abused and
trafficked Jane Doe 1 and members of the Class is this District.
4. Often these acts of sexual abuse and commercial sex acts, committed
by Jeffrey Epstein and certain select friends of his, took place in Jeffrey Epstein’s
New York mansion, located within this District at 9 East 71st Street in New York
City. Epstein also used his New York mansion to harbor his victims and as a base
from which to transport them to other locations outside of New York.
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5. A substantial part of the acts, events, and omissions giving rise to this
cause of action occurred in this District.
6. This action has been timely filed pursuant to 18 U.S.C. § 1595(c)(1),
which provides that a plaintiff shall have ten years after the cause of action arose to
file suit against any person who knowingly benefits, financially or by receiving
anything of value from participation in a venture which that person knew or should
have known violated the laws against sex trafficking. This action is also timely
under New York’s Adult Survivor’s Act, N.Y. CPLR § 214-j.
II. PARTIES
7. Jane Doe 1 is a U.S. citizen and was at all relevant times a resident of
and domiciled in the State of New York.
8. Plaintiff Jane Doe 1 is using a pseudonym to protect her identity
because of the sensitive and highly personal nature of this matter, which involves
sexual assault.
9. Jane Doe 1 is also at serious risk of retaliatory harm because the co-
conspirators who participated in the Epstein sex-trafficking venture had—and
continue to possess—tremendous wealth and power and have demonstrated a clear
ability to cause her serious harm.
10. Jane Doe 1’s safety, right to privacy, and security outweigh the public
interest in her identification.
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11. Jane Doe 1’s legitimate concerns outweigh any prejudice to
Defendant by allowing her to proceed anonymously. Accordingly, Jane Doe will be
filing a Motion to Proceed Anonymously.
12. As discussed below, many other women are similarly situated to Jane
Doe 1 and also need to proceed anonymously for the same reasons. The identities of
most of these other women are known to Defendant.
13. Defendant JP Morgan is a global financial institution headquartered
in New York, New York.
14. Defendant JP Morgan is licensed by the New York State Department
of Financial Services to operate a foreign bank branch in the State of New York.
15. Defendant JP Morgan currently conducts substantial business in this
District and conducted substantial business at the time of events covered in this
complaint.
16. As one example of business conducted in this District, JP Morgan
ordinarily shares trade on the New York Stock Exchange, located in this District. As
another example, JP Morgan maintains branch banks within this District.
17. JP Morgan’s financial activities, including the events alleged herein,
were in and affecting interstate and foreign commerce. In connection with the acts
alleged in this complaint, Defendant, directly or indirectly, used the means and
instrumentalities of interstate commerce, including, but not limited to, the mails,
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interstate telephone communications, and the facilities of national securities
markets.
18. JP Morgan is responsible, under United States law and otherwise, for
the acts of its officers, directors, employees, and agents, including the acts described
in this complaint.
III. INTRODUCTION
19. Jeffrey Epstein’s sex-trafficking venture operated in many respects as
a sex-themed cult designed to ensnare vulnerable young women and indoctrinate
them into Epstein’s carefully constructed world in which Epstein was their messiah.
Epstein and his co-conspirators preached the gospel of Epstein. Epstein’s victims
were taught to do what he said, and he would protect them; but disobey him, and he
would punish them; and continue to disobey, and he would cause them serious harm
from which they could never recover.
20. Once in Epstein’s clutches, each victim was taught and understood
that she must be completely compliant with every wish or demand Epstein had for
her; otherwise, she would certainly suffer serious reputational, financial, and
psychological harm. By using these and other means of force, threats of force, fraud,
threats of abuse of the legal process and coercion, Epstein and his co-conspirators
sexually trafficked and sexually abused Plaintiff Jane Doe 1 and the other members
of the Class.
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21. The Epstein sex-trafficking venture originated in the early 1990’s.
From its inception until Jeffrey Epstein’s arrest by the FBI for sex trafficking in 2019
(and his subsequent death on August 10, 2019, by apparent suicide), the venture
operated primarily for the purpose of luring young women and girls into a position
where Jeffrey Epstein and his co-conspirators could coerce them to engage in
commercial sex acts and commit sexual offenses against them. His venture also
operated to conceal its sex trafficking from law enforcement organizations.
22. The Epstein sex-trafficking venture was well-structured from the
beginning and grew increasingly more complex and powerful as it victimized more
young women and as its relationship with Defendant JP Morgan grew.
23. Epstein did not act alone. He created and maintained his sex-
trafficking venture with the assistance of other influential individuals and entities
who knew he was sexually abusing and sexually trafficking young women and girls
and provided support to facilitate his sexual abuse and sex trafficking operation.
24. Epstein’s sex-trafficking venture was not possible without the
assistance and complicity of a financial institution—specifically, banking
institution—which provided special treatment to the sex-trafficking venture, thereby
ensuring its continued operation and sexual abuse and sex-trafficking of young
women and girls. Without the financial institution’s participation, Epstein’s sex
trafficking scheme could not have existed.
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25. Epstein’s victims were young women and girls, who suffered severe
abuse as Epstein’s sex-trafficking victims and who believed they had to remain loyal
to the venture at all costs in order to survive. Epstein victimized hundreds of young
women and girls.
26. Epstein’s sexual abuse and sex trafficking scheme was supported by
virtually unlimited wealth, derived from select wealthy individuals who acted as the
financial engine behind the sex-trafficking operation.
27. Epstein masterfully assessed the specific needs and vulnerability of
each of his targeted victims. He then closed the trap on his victims with offers of
money, food, shelter, medical care for them or family members, travel, schooling,
and career opportunities. Epstein groomed the young women and girls,
indoctrinating them to believe that the sexual abuse was normal.
28. Epstein fraudulently represented to the victims that he would take
care of them in various ways, which ultimately allowed Epstein to cause them to
engage in commercial sex acts with himself and, on occasion, others, as well as to
create the opportunity for Epstein to sexually abuse them.
29. The Epstein sex-trafficking venture’s purpose included enticing,
obtaining, harboring, and transporting the young victims without drawing unwanted
attention from law enforcement. The venture had everything a sex-trafficking
organization needed—funding, infrastructure, the appearance of legitimacy, and a
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complicit banking institution. It was by many accounts the most powerful and
wealthiest sex-trafficking venture ever created.
30. The Epstein sex-trafficking venture knowingly used means of force,
threats of force, fraud, coercion (including threats of serious harm or physical
restraint), and abuse of law and the legal process, to cause Jane Doe 1, and many
dozens of others similarly situated women to engage in commercial sex acts.
31. The Epstein sex-trafficking venture operated in and affected interstate
and foreign commerce. Epstein recruited, solicited, coerced, harbored, transported,
and enticed some of his victims, including Jane Doe 1 and others similarly situated,
to engage in commercial sex acts in, among other places, New York (including the
Southern District of New York), Florida, the U.S. Virgin Islands, New Mexico,
England, and France.
32. The Epstein sex-trafficking venture operated throughout the world
from in and around the early 1990’s through in and around August 10, 2019, when
Epstein died by apparent suicide.
33. Thereafter, to and including the date of this complaint, members of
the sex-trafficking venture continued to further the venture by concealing the
activities and extent of the venture.
34. The manner of operation for Epstein’s particular sexual abuse and sex
trafficking operation was widely publicized. He would lure young girls or women
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to one of his luxurious mansions, under the guise of being a wealthy philanthropist,
able to advance careers, education, or provide other life necessities, and once inside
he would force his would-be victim into providing a massage that would turn sexual,
and from there he would cause each of his unsuspecting victims to engage in a
variety of commercial sex acts.
35. Once in his presence, each victim knew it was no option to disobey
Epstein. It was well known and understood that he was one of the most powerful and
connected people in the United States, able to help any of these young victims and
also capable and willing to hurt any of his victims.
36. While the first sexual abuse was discovered to have likely occurred
in the early 1990’s with the use of his then paramour, Ghislaine Maxwell, his
appetite for sexual abusing young women and girls grew over the years.
37. By 2000, each victim was being directed to bring other victims and
being paid handsomely in cash for recruiting other victims.
38. The Florida criminal investigation uncovered that Epstein’s sex-
trafficking operation grew its number of victims exponentially in the late 1990’s and
early 2000’s.
39. One major reason why Epstein’s sex-trafficking venture accumulated
new victims at an alarming rate in the late 1990’s and accelerating even faster by
2000 was his access to unlimited amounts of cash.
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40. Without exorbitantly large amounts of cash, Epstein’s operation
could not run, as newly recruited victims were each paid hundreds of dollars in cash
immediately after Epstein sexually abused them, as hush money.
41. Each victim was also informed that she would be paid hundreds of
dollars in cash for each additional victim she recruited, and Epstein made good on
that promise of large cash payments.
42. The public documents and articles stemming from the 2006 arrest
made abundantly clear that Epstein was doling out thousands of dollars in cash every
single day as hush money to victims he was sexually abusing and to victims he was
using to recruit additional victims.
43. If Epstein paid every victim with wire transfers and left a documented
money trail, his illegal sexual abuse and sex trafficking operation would have been
easily uncovered; however, with access to unlimited amounts of cash, Epstein was
able to commit the most egregious sexual crimes many times a day without leaving
a paper trail.
44. This constant expansion of sexual abuse and sex trafficking victims
required cash on hand for Epstein to pay each victim as hush money for the abuse
she was suffering as well as each victim’s finder’s fee for bringing another victim.
45. Because Epstein’s vast wealth, said to have been more than a billion
dollars, was maintained in seemingly legitimate financial institutions, he needed a
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complicit financial institution that would allow large, regular cash withdrawals in
order to operate his sex-trafficking operation.
46. In order to access the large amount of cash needed to maintain his
active sexual abuse of young women, it was essential that the financial institution
where he banked be complicit in his operation, and more specifically that Epstein
bank at a financial institution that would allow him to constantly withdraw cash from
his accounts without following anti-money laundering and reporting laws.
47. To put it plainly, Epstein needed a bank that knew he was engaging
in illegal activity and did not care—because the bank only cared about the money
that it was making from its relationship with Epstein.
48. This scheme of paying victims to bring other victims worked
effectively because it not only allowed expansion through the recruitment of other
victims in a pyramid scheme fashion, but it also allowed each victim a possibility to
avoid future sexual abuse—she could bring someone else who would get abused in
her place.
49. Epstein’s aptitude as a sex-trafficker and appetite as a sexual abuser
did not suffer because of his Florida incarceration in 2008. Even while he was in jail
in Florida, Epstein continued to sexually abuse young girls and women from his
work release office.
50. Once out of jail and off work release, Epstein continued to collect
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young women and lure them through force, fraud, or coercion into one of his
mansions, primarily his townhouse located at 9 East 71 Street, New York, NY,
where he would sexually abuse each one.
51. His sexual abuse and sex trafficking operation continued as it had in
the past, although it became more elaborate, creating more phony companies,
opening more bank accounts, withdrawing excessive amounts of cash, and
delivering money to victims through wires, payroll, direct deposits, and other means
known to his financial institution as evidence of the continuation of his criminal sex
trafficking scheme.
52. As time went by, the news articles and lawsuits continued to mount,
and more information became publicly available that Epstein was continuing to
abuse young women and was using professionals on his payroll to help him conceal
his illegal activity and give him ostensible cover as a well-connected money
manager.
53. As a registered sex offender discovered to be sexually abusing
multiple young women each day through a pyramid-type recruiting scheme that
required the transfer of millions of dollars to continue the operation, a complicit bank
became more important than ever.
54. As is more detailed below, Defendant JP Morgan worked closely with
Epstein through every step of Epstein’s sex trafficking operation’s expansion and
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growth in its most prolific of years—between 2000 and 2013.
IV. THE TRAFFICKING VICTIMS’ PROTECTION ACT
55. The Trafficking Victims Protection Act (TVPA) outlaws sex
trafficking activities that affect interstate or foreign commerce or take place within
the territorial jurisdiction of the United States. It is to be construed broadly because
it serves a remedial purpose and uses intentionally broad language.
56. The TVPA forbids the following sex-trafficking conduct:
(a) Whoever knowingly—
(1) in or affecting interstate or foreign commerce, or within the

special maritime and territorial jurisdiction of the United States
recruits, entices, harbors, transports, provides, obtains, advertises,
maintains, patronizes, or solicits by any means a person; or
(2) benefits, financially or by receiving anything of value, from

participation in a venture which has engaged in an act described in
violation of paragraph (1),
knowing, or, except where the act constituting the violation of

paragraph is advertising, in reckless disregard of the fact, that means of
force, threats of force, fraud, coercion described in subsection (e)(2), or
any combination of such means will be used to cause the person to
engage in a commercial sex act, or that the person has not attained the
age of 18 years and will be caused to engage in a commercial sex act,
shall be punished as provided in subsection (b). 18 U.S.C. § 1591(a).
57. The TVPA also contains an explicit “civil remedy” provision which
allows an individual who is a victim of a violation of Chapter 77 of Title 18 (e.g., 18
U.S.C. §§ 1591-95) to bring a civil action against the perpetrator and any person or
entity who knowingly benefits, financially or by receiving anything of value from

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participation in an illegal sex-trafficking venture. 18 U.S.C. § 1595(a).
58. Unlike the criminal penalties provisions in the TVPA, the civil
remedies provision contains a “constructive knowledge” provision. This provision
allows a civil action to be brought not only against a person or entity who
participated in a venture known to have engaged in illegal sex trafficking but also
against a person or entity who participated in a venture that the person or entity
should have known had engaged in illegal sex trafficking. 18 U.S.C. § 1595(a). This
expansive provision is known as the “constructive knowledge” provision, which
provides an alternative to proving actual knowledge as part of civil damages claim.
59. In the paragraphs that follow, wherever Plaintiff alleges that the
Defendant acted with actual knowledge, or in reckless disregard of the fact, that the
Epstein sex-trafficking venture used means of force, threats of force, fraud, coercion,
abuse of process, or some combination thereof to cause a person to engage in
commercial sex acts, the Plaintiff also allege that, at a bare minimum, the Defendant
should have known that the Epstein sex-trafficking venture had used such means to
engage in illegal sex trafficking in violation of 18 U.S.C. §§ 1591-94—i.e., that they
had constructive knowledge of Epstein’s sex trafficking.
V. FACTUAL ALLEGATIONS
A. The Epstein Sex-Trafficking Venture.
60. During all times relevant to this complaint, Jeffrey Epstein was an
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extraordinarily wealthy man with multiple residences in the United States, including
a New York City mansion, a Palm Beach mansion, and an island in the U.S. Virgin
Island.
61. Beginning in the early 1990s and continuing through the summer of
2019, Jeffrey Epstein knowingly established and ran a sex-trafficking venture in
violation of 18 U.S.C. §§ 1591-95. As part of the venture, Epstein used means of
force, threats of force, fraud, coercion, abuse of legal process, and a combination of
these means to cause young women and girls from all over the world to engage in
commercial sex acts and to sexually abuse them.
62. In creating and maintaining this network of victims in multiple states
and in other countries to sexually abuse and exploit, Epstein worked and conspired
with others, including employees and associates who facilitated his conduct by,
among other things, recruiting victims, coercing victims, and scheduling their sexual
abuse by Epstein at his New York mansion, his Palm Beach mansion, and his island
in the U.S. Virgin Islands.
63. In this District and elsewhere, Epstein perpetuated this abuse in
similar ways. Epstein and his co-conspirators used Epstein vast (yet mysterious)
wealth and connections to other rich and powerful individuals to lure new victims
into his home for seemingly innocuous activity. Victims were initially recruited to
speak with an alleged philanthropic Epstein and provide “massages” to him.
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64. Once at the home and trapped in Epstein’s bedroom the victims would
be instructed to remove their clothing. Epstein would then force the massages to
become increasingly sexual in nature, typically including one or more forced sex
acts. Epstein would use means of force, threats of force, or fraud to coerce the
victims to participate in these sex acts and to cause them to return and continue to
engage in commercial sex acts with him. Epstein and his associates then paid his
victims hundreds of dollars in cash for each sexual encounter.
65. Moreover, Epstein actively encouraged his victims to recruit
additional girls to be similarly sexually abused, causing the number of victims to
grow exponentially. Epstein incentivized his victims to become recruiters by paying
these victim-recruiters hundreds of dollars for each girl that they brought to Epstein.
In so doing, Epstein, through this system of paying victims to recruit others whom
he would also pay for being sexually abused as well as for recruiting, created a sexual
abuse and sex trafficking spider web and maintained a steady supply of new victims
to exploit.
66. Epstein was skilled at ascertaining his victim’s greatest fears and
aspirations and targeted those fears and aspirations to coerce and trap his victims
into performing commercial sex acts and to be subject to sexual abuse.
67. Among other things, Epstein sexually abused his many victims and
caused his victims to engage in commercial sex acts, specifically sex acts for which
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his victims received things of value, including cash, promises of educational and
career advancement, and promises that Epstein would provide various forms of
assistance.
68. Epstein provided things of value to his victims in order to cause them
to engage sex acts with him and on occasion his friends, co-conspirators, or other
victims.
69. As one means of causing victims to engage in commercial sex acts,
Epstein and his co-conspirators threatened that harm would come to victims if they
did not comply with his demands that they perform commercial sex acts.
70. As another means of causing victims to engage in commercial sex
acts, Epstein and his co-conspirators fraudulently promised to further victims’
educational or career aspirations if they would comply with his sexual demands.
These promises were a quid pro quo for the sex acts that occurred.
71. As one means of causing victims to engage in commercial sex acts,
Epstein and his co-conspirators would give his victims money to stay quiet about the
assault or as a “finder’s fee” for bringing other young women or provide them with
living accommodations, clothing, education, or other necessities.
72. Throughout most of the 1990’s through about July 2019, the Epstein’s
sex-trafficking venture recruited, solicited, enticed, harbored, obtained, provided,
and transported hundreds of victims to cause them to engage in commercial sex acts
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with Epstein and Epstein’s friends.
73. In 2006, Jeffrey Epstein was arrested in Florida after state and federal
law enforcement discovered that he had sexually abused more than 30 children in
his Palm Beach, FL mansion. During that investigation, it was concluded that
Epstein and his co-conspirators had committed federal criminal acts constituting
violations of 18 U.S.C §§ 2422 (b), 2422 (2), 2423 (f), 2423 (b), 2424 (e), 18 U.S.C
§ 371, 18 U.S.C § 1591 (c) (1) and 1591 (a) (1) and (2), as well as state crimes in
violation of Florida Statute §§ 796.07 and 796.03, against dozens of young women.
74. As a consequence of the Florida investigation, Epstein pled guilty to
two felonies, was permanently labeled a “Registered Sex Offender,” and was jailed
in 2008.
75. Epstein’s criminal case in Florida and the many related news reports
left no doubt about Jeffrey Epstein and his extraordinary penchant for sex abuse and
trafficking of young females. For instance, it was revealed that until the time of his
Florida arrest, Jeffrey Epstein was sexually abusing three to four young females per
day; it was a full-time job for him.
76. Beginning with his Florida arrest and for years moving forward,
Epstein was embroiled in dozens of public lawsuits pertaining to his sexual abuse of
females and hundreds if not thousands of news stories circulated worldwide about
his illegal sexual proclivities.
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77. In addition to the many civil lawsuits seeking damages for sexual
abuse, Epstein’s victims also filed a public lawsuit against the Unites States under
18 U.S.C 3771, the Crime Victim’s Rights Act (CVRA), further exposing Epstein’s
sexual crimes as well as a secret Non-Prosecution Agreement he entered into with
the Federal Government.
78. Epstein recruited, solicited, enticed, harbored, obtained, provided,
and transported his victims to cause them to engage in commercial sex acts in ways
that were in and affecting interstate and foreign commerce, including using means
of interstate communications (such as cellular telephones) and means of interstate
and foreign travel (such as aircraft that he owned and controlled).
79. Epstein transported his victims in interstate and foreign commerce,
including transportation to and from his mansion in this District.
80. The Epstein sex-trafficking venture transported victims across state
boundaries between New York, Florida, New Mexico, New Jersey, Massachusetts,
and the U.S. Virgin Islands and elsewhere, and in foreign commerce to places,
especially Eastern Europe.
81. At all times relevant to this complaint, the Epstein sex-trafficking
venture was a group of two or more individuals associated in fact, even if they were
not a formal legal entity. Indeed, members of the Epstein sex-trafficking venture
referred to it as “The Organization.”
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82. On July 2, 2019, the United States Attorney’s Office for the Southern
District of New York filed a sealed, two-count Indictment against Epstein, including
one count of Sex Trafficking Conspiracy and one count of Sex Trafficking for
violations of 18 U.S.C. §1591, in part due to Epstein’s criminal activities in his New
York Mansion located at 9 East 71st Street. See United States v. Jeffrey Epstein,
Case No. 1:19-cr-480 (S.D.N.Y.).
83. On July 8, 2019, Jeffrey Epstein was arrested pursuant to the New
York Indictment.
84. On August 10, 2019, prison guards found Epstein unresponsive in his
Metropolitan Correctional Center jail cell, where was awaiting trial on the federal
sex trafficking charges. He was later pronounced dead from apparent suicide.
85. In July 2020, Epstein’s co-conspirator in the origin of the sex-
trafficking venture, Ghislaine Maxwell, was arrested on federal sex trafficking
charges filed in this Court. The charges alleged that she had assisted, facilitated, and
contributed to Epstein’s abuse of sex trafficking victims, helping Epstein to recruit,
groom, and ultimately abuse his victims. See United States v. Maxwell, Case No.
1:20-cr-00330 (S.D.N.Y.).
86. On December 29, 2021, Maxwell was found guilty in this Court on
five federal sex trafficking counts in this Court and is now serving close to 20 years
in federal prison for these crimes.
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B. Consistent with His Uniform Pattern and Practice, Jane Doe 1 Was
Forced to Engage in Commercial Sex Acts with Epstein by Means of
Force, Fraud, and Coercion.
87. Jane Doe 1 was living with her mother when she met Jeffrey Epstein
in 2006.
88. Jane Doe 1 was a ballet dancer in New York when she was recruited
to meet Jeffrey Epstein by another young female who had also fallen prey to Jeffrey
Epstein’s sex trafficking scheme.
89. Epstein and his co-conspirators had a long history of grooming,
indoctrinating, controlling, and ultimately committing sexual offenses against
young, vulnerable women like Jane Doe 1. Epstein and his co-conspirators
constantly reminded Jane Doe 1 how powerful and important Epstein was. Jane Doe
1 was chastised if she refused Epstein’s sexual demands and told she should be
grateful that Epstein was willing to help her with her career and education. She came
to believe what she was told.
90. The well-oiled Epstein sex abuse and trafficking venture included
frequent statements to Jane Doe 1 and other victims by Jeffrey Epstein and his co-
conspirators that: (1) Jeffery Epstein possessed extraordinary wealth, power and
influence; (2) Jeffrey Epstein’s business and political friends, including world
leaders, also included some of the most powerful people in the world; (3) Jeffrey
Epstein had the ability to advance or destroy nearly anyone financially,
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reputationally, and otherwise; (4) medical and normal life necessities would be
denied victims if they, including Jane Doe 1, failed to perform commercial sex acts
for Epstein; and (5) Epstein could take away Jane Doe 1’s and other victims’ life
needs such as shelter or housing if she or they failed to perform those acts.
91. Jane Doe 1 was exceptionally vulnerable to being victimized by
Epstein. His sex-trafficking venture targeted vulnerable young women and Jane Doe
1 was soon indoctrinated and unable to extricate herself. Jane Doe 1 was sexually
abused and trafficked by Epstein for several years. Having been conditioned that
the sexual abuse was “normal” and knowing that everyone surrounding Epstein,
including accountants, lawyers, and other important people, were aware of the sex
abuse, Jane Doe 1 was coerced into a cult-like life controlled and manipulated by
Epstein and others doing Epstein’s bidding.
92. Over the ensuing years, from 2006 through 2013, Epstein sexually
abused Jane Doe 1 on a number of occasions in direct violation of New York Penal
Law 130, including but not limited to the following:
a. Sexual misconduct as defined in §130.20 inasmuch as Jeffrey Epstein

engaged in sexual intercourse with Plaintiff without Plaintiff’s consent;
b. Rape in the first degree as defined in §130.35 inasmuch as Jeffrey

Epstein engaged in sexual intercourse with Plaintiff by forcible
compulsion;
c. Criminal sexual act in the first degree as defined in §130.50 inasmuch

as Jeffrey Epstein engaged in oral sexual conduct with Plaintiff by
forcible compulsion;
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d. Forcible touching as defined in §130.52 inasmuch as Jeffrey Epstein,

intentionally and for no legitimate purpose, engaged the forcible sexual
touching of Plaintiff for the purpose of degrading or abusing her or for
the purpose of gratifying his own sexual desire; and
e. Sexual abuse in the third degree as defined in §130.66 inasmuch as

Jeffrey Epstein inserted a foreign object in the vagina of Plaintiff by
forcible compulsion.
93. Jane Doe 1 was also trafficked to Jeffrey Epstein’s friends for
commercial sex acts in this District.
94. Epstein used means of force, threats of force, fraud, coercion, abuse
of process, and a combination of such means to cause Doe 1 to engage in commercial
sex acts.
95. Epstein’s recruited Jane Doe 1 to cause her to engage in commercial
sex acts in ways that were in and affecting interstate and foreign commerce,
including use of cellular telephones and means of interstate transportation (such as
aircraft that he owned or controlled).
96. Epstein transported Jane Doe 1 from New York to other states to
cause her to engage in commercial sex acts.
97. Jane Doe 1 wanted to escape from the Epstein sex trafficking venture,
yet Epstein and his supporting team of co-conspirators increased the tactics of fraud,
force, or coercion to cause her to remain compliant in fulfilling Epstein’s sexual
demands.
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98. Jeffrey Epstein controlled Jane Doe 1 financially, emotionally, and
psychologically. He used his knowledge of Jane Doe 1’s aspirations, fears and
problems to manipulate her until she was completely controlled by and dependent
upon him.
99. When Epstein went to jail for sex offenses in Florida, he maintained
contact with Jane Doe 1. He and employees of his business entities, which were
created to support and legitimize Epstein’s sexual abuse and sex trafficking
enterprise, including HBRK, NES, Financial Trust, and Florida Science Foundation,
caused Jane Doe 1 to be transported to Florida in order to engage in commercial sex
with Epstein in his Florida residence while on so-called “work release” from jail,
while he was still wearing his ankle monitor.
100. There came a time when Epstein forced Jane Doe 1 to give massages
to his powerful friends. During some of these massages she was sexually abused, by
force and against her will, by Epstein’s friends whom she had been required to
massage. At least one of Epstein’s friends used aggressive force in his sexual assault
of her and informed Doe 1 that he had Epstein’s permission to do what he wanted to
her. Out of fear, Jane Doe 1 has still not named this powerful financial executive
publicly.
101. Epstein and his co-conspirators withdrew large sums of cash from JP
Morgan to make cash payments to victims, including Jane Doe 1, in furtherance of
25
the sex-trafficking operation.
102. JP Morgan knew that its accounts were being used for this trafficking
based on a number of factors, including but not limited to, the identity of the
individuals making the withdrawals and wire transfers, the identity of the recipients,
the account opening activity, the pattern of the financial activity, and Epstein’s well
documented criminal history and involvement in trafficking.
103. Over the ensuring years, Epstein threatened Jane Doe 1 in many ways
including threatening that if she did not abide by his demands, she would lose contact
with people she cared about.
104. Epstein would alternate promises and threats to secure Jane Doe 1’s
compliance with his demands, including demands that she engage in commercial sex
acts with him and others. In some instances, Epstein would pay Jane Doe 1 directly
in cash obtained from JP Morgan for sex acts.
105. Epstein and his co-conspirators continued to coerce Jane Doe 1 in
various ways until her ultimate escape around the end of 2013.
C. JP Morgan
1. JP Morgan’s participation in the venture.
106. In or about 1998, in furtherance of his rapidly growing sexual abuse
and sex trafficking operation, Jeffrey Epstein realized that he needed a reliable
banking institution that would provide the necessary legitimate appearance for his
26
operation, allow him to open many accounts for illegitimate companies, ignore red
flags, ignore federal banking laws, allow him to transfer money without questioning,
allow him access to abundant cash, and to otherwise facilitate the commercial aspect
of his commercial sex trafficking enterprise. Epstein found all of those things in JP
Morgan.
107. From about 2000 through 2013, JP Morgan knowingly and
intentionally participated in the Epstein sex-trafficking venture by (among other
things) providing the essential financial underpinnings for the venture. There can be
no doubt that JP Morgan’s conduct, as described below, was outrageous and
intentional.
108. Around 2000, Epstein developed a key relationship to expanding
exploitative sexual abuse and his sex trafficking operation when he began working
with James “Jes” Staley (“Staley”), the then-head of JP Morgan’s private banking
division.
109. Before meeting Staley, Epstein was a serial sexual abuser of young
girls and women, with an insatiable desire to sexually abuse females that were, in
his words, “the younger, the better.”
110. Before Staley, Epstein relied heavily on the massive wealth bestowed
upon him by one individual, Leslie Herbert Wexner (“Wexner”), to give him the
appearance of grand importance while relying on his madame, Ghislaine Maxwell
27
(“Maxwell”), to find and groom young women to be abused by Epstein.
111. However, Epstein could not expand his operation to the level it
ultimately reached without a complicit financial banking institution that would
ignore red flags to the point of allowing him to pay hundreds of young females in
wire transfers and allow him access to hundreds of thousands of dollars in cash to
pay hush money to his growing number of victims.
112. Staley was the key to making all of Epstein’s depraved dreams of
sexual abuse and sex trafficking of countless young women possible. With his help,
the number of victims of the Epstein sex trafficking operation began to grow on a
vertical trajectory beginning in 2000.
113. When Epstein and Staley first teamed up, in or about 2000, Staley
was the head of JP Morgan’s private banking division and was later promoted to
CEO of JP Morgan Asset Management in 2001.
114. The relationship between Epstein and Staley was symbiotic. Epstein
agreed to bring many ultra-high wealth clients to JP Morgan, and in exchange, Staley
would use his clout within JP Morgan to make Epstein untouchable. This meant that
JP Morgan would keep Epstein on as a client at all costs, including failing to act on
any red flags and ultimately allowing him the ability to run and grow what to the
bank was obviously an operation designed to sexually abuse and traffic countless
young women.
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115. There were several key figures who created Epstein’s international
sex trafficking operation, most notably Ghislaine Maxwell, Les Wexner, and Jes
Staley through JP Morgan.
116. In later years, Deutsche Bank picked up where JP Morgan left off and
provided the necessary complicit financial institution for the operation.
117. Without Maxwell, Epstein would never have been able to recruit his
first victims and been able to bring them into his abusive lair. She approached
young, vulnerable victims and spread the word that Epstein was this altruistic
messiah who could help them. One they were in Epstein’s clutches, she groomed
them to make them feel comfortable being sexually exploited and abused.
118. Without Wexner, Epstein’s sex trafficking operation and sexual abuse
of women could never have occurred to the extent that it did, as Epstein needed the
appearance of extraordinary wealth to attract his victims and force them to stay
silent.
119. However, even with Wexner’s funding of Epstein’s operation,
Epstein’s sexual abuse of hundreds of women would have been limited because the
money trail from Epstein’s accounts to the many victims and recruiters would have
exposed the illegality of the operation quickly.
120. Therefore, the final essential ingredient Epstein needed to expand his
sexual abuse of young women and sex trafficking enterprise was a financial
29
institution that would not care that Epstein was sexually abusing women on a daily
basis and paying out millions in hush money.
121. JP Morgan provided the final component Epstein needed, and Staley
made sure Epstein and his illegal sexual abuse organization was absolutely protected
by the bank.
122. From the beginning of the Epstein/Staley relationship, Staley
understood that Epstein’s money was only a part of the incentive to protect Epstein’s
operation.
123. As long as Epstein’s money stayed at
the bank, Staley also knew that Wexner, Epstein’s
client who had turned over a power of attorney to
Epstein, would likewise keep his money with JP
Morgan. Wexner’s money was said to amount to
over a billion dollars.
124. It did not stop there. Epstein made clear that he “collected people”
and was close with many ultra-wealthy individuals that he could bring into the bank.
These new customers made JP Morgan even more profitable. Along the way, Epstein
gave credit for these new bank customers to Staley, which made Staley enormously
wealthy.
125. Epstein controlled Staley like he did his many victims, by flaunting
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his power and connections to the extremely wealthy. Epstein made it clear to Staley
that if JP Morgan ever decided to terminate its relationship with Epstein, e the bank
would lose Wexner and the other wealthy connections Epstein had promised JP
Morgan.
126. Staley was enamored with Epstein and driven by greed, which made
Epstein one of the most coveted clients of JP Morgan. Through the years, Staley
helped accumulate other protectors of Epstein within JP Morgan (such as Mary
Erdoes) who were also willing to turn a blind eye to Epstein’s blatantly illegal
operation.
127. With JP Morgan’s complicity, Epstein was free to sexually abuse
hundreds of women, paying millions in hush money, without the fear of detection
by law enforcement. Epstein used the support from a reputable institution—JP
Morgan—to help cover up his criminal activity.
128. JP Morgan cared about one thing—profit—and showed absolute
loyalty to Epstein, including a willingness to violate banking laws and ignore
multiple red flags of criminality to enable Epstein to fulfill his abusive sexual
appetite at the expense of countless vulnerable young women.
129. As Epstein’s criminal sex trafficking venture expanded and he needed
more protection and support from JP Morgan, Epstein continued to grow closer to
Staley.
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130. As another example of JP Morgan and Staley’s benefit from assisting
Epstein, another highly profitable deal for JP Morgan was the Highbridge deal.
131. In 2004, at the height of Epstein’s sex trafficking and abuse operation,
when he was transferring massive amounts of hush money to his victims and
recruiters and withdrawing hundreds of thousands of dollars in cash so that all the
payments were not traceable (the most obvious red flag for any criminal enterprise),
Epstein served up another big financial payday for JP Morgan.
132. Epstein was close friends with Glenn Dubin, the billionaire who ran
Highbridge Capital Management, whom he introduced to Staley.
133. Through Epstein’s connection, it has been reported that Staley
arranged for JP Morgan to buy a majority stake in Dubin’s fund, which resulted in a
sizeable profit for JP Morgan. This arrangement was profitable for both Staley and
JP Morgan, further incentivizing JP Morgan to ignore the suspicious activity in
Epstein’s accounts.
134. In addition to Epstein, JP Morgan also housed accounts for Epstein’s
main sex trafficking madame, Ghislaine Maxwell, who is now serving 20 years in
prison for sex trafficking related to her participation in Epstein’s operation.
135. In 2022, JP Morgan representative, Patrick McHugh, testified in
Maxwell’s criminal sex-trafficking trial that between 1999 and 2007, Epstein
transferred approximately $31M to Maxwell, an amount believed to be payment for
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her role in Epstein’s sex trafficking venture.
136. Between 2000 and 2005, Epstein provided clients to JP Morgan and,
in exchange, JP Morgan allowed Epstein to do as he pleased with his JP Morgan
accounts. JP Morgan allowed Epstein to engage in structuring violations and other
financial maneuvers required to maintain a criminal enterprise. The relationship
continued without much of a question from outsiders. JP Morgan financially
benefitted from allowing Epstein to use his JP Morgan accounts to run his sex
trafficking venture.
137. However, in 2006, Epstein’s relationship with JP Morgan hit a snag
when Epstein was publicly exposed for sexually abusing dozens of young girls and
women, several as young as 14 years old. There were hundreds of pages of police
reports and news articles revealing that Epstein was a serial sexual abuser and
trafficker, and that his operation depended on his accessing nearly unlimited cash to
use as payments to his victims.
138. With respect to the specific discoveries, the United States Attorney’s
Office for the Southern District of Florida found that some of the victims “went to
Mr. Epstein’s house only once, some went there as much as 100 times or more.”
139. It was publicly revealed in the investigation that Epstein was sexually
abusing three to four young females every single day of his life and that he was
paying each victim hundreds of dollars in hush money, usually in cash.
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140. The criminal investigation also revealed that Epstein was paying
countless recruiters to constantly bring him more victims, making clear that quick
access to cash at a financial institution was the lifeblood for his sex-trafficking
venture.
141. The money trail into Epstein’s accounts was a dead giveaway that
Epstein was engaging in crimes and the recipients of his money exposed the type of
crimes.
142. To the extent JP Morgan could feign plausible deniability before
Epstein’s arrest in 2006, thereafter its ability to play dumb was eviscerated when
Epstein registered as a sex offender and the details of his daily sexual abuse of young
females came to public light.
143. Because Epstein was so publicly exposed as a sex trafficker and
abuser, one of his primary financial engines, Les Wexner, abandoned him and
separated himself from Epstein.
144. In 2008, around the same time Epstein was pleading guilty to felony
sex offenses and registering as a lifetime sex offender, it was discovered that another
of JP Morgan’s high value clients, Bernie Madoff, was running the largest Ponzi-
scheme in modern history through his accounts at JP Morgan, causing JP Morgan to
review its clientele with the directive of severing ties with any problematic
customers.
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145. With this indisputable knowledge that Epstein was a sexual offender
who was using his wealth for only one purpose—to run a sexual abuse and
trafficking operation—any responsible bank would have cut ties, if only to attempt
to maintain the not-so-plausible deniability that it had not known of Epstein’s illegal
sexual abuse operation earlier.
146. However, rather than cut ties with Epstein, it has been reported that
Staley, acting on behalf of JP Morgan, personally visited Epstein when he was
serving his jail sentence in Florida.
147. No matter the cost, the bank made clear to Epstein that he could
continue to fund his sexual abuse operation through JP Morgan.
148. When executives on the board at JP Morgan recommended cutting
ties with Epstein, Staley made strong and successful arguments for JP Morgan
keeping Epstein as a customer.
149. In support, JP Morgan’s CEO of private banking, Mary Erdoes,
argued that Epstein was too valuable of a client to let go and played a pivotal role in
maintaining JP Morgan’s relationship with Epstein.
150. After Staley went to visit Epstein in Florida while Epstein was
incarcerated on sex offenses, Epstein and Staley’s relationship continued to grow.
Ultimately, after Epstein’s release from jail, Staley and Epstein spent significant
time together at Epstein’s townhouse in New York City. Staley also visited Epstein
35
on his private island in the United States Virgin Islands—an island commonly
dubbed “Pedophile Island.”
151. After his arrest in 2008, dozens of public lawsuits mounted against
Epstein, revealing greater details of Epstein’s sexual abuse of young women, each
of which also detailed millions in payments that Epstein was making to recruiters,
co-conspirators, cover-guys such as his longtime fixer/lawyer and fixer/accountant,
and to his victims.
152. Through the civil lawsuits, evidence such as message pads taken from
Epstein’s trash by police or through prior search warrants, as well as flight logs
began to publicly surface, shedding further public light on the expansiveness of
Epstein’s sex-trafficking operation.
153. In addition to the inner workings of Epstein’s sex trafficking scheme
becoming public when he was arrested and served his jail time in Florida, other
relevant information also became public and was widely published: Epstein had no
college degree, he had never obtained any specialized license, none of the companies
with whom he was associated had any legitimate business structure or purpose, and
he had no documented expertise that would provide the requisite skill or knowledge
to amass his vast wealth.
154. Despite the false rumors he had created to conceal his true “business,”
Jeffrey Epstein was exposed as literally nothing other than a sex trafficker and abuser
36
of young females, a fact easily discernible by any responsible financial institution
with whom he was banking.
155. For JP Morgan, a sophisticated financial institution legally
responsible for complying with Know Your Customer laws and other banking
obligations, the details of Epstein’s sexual abuse and trafficking were not a surprise.
Even so, JP Morgan never cooperated in any civil or criminal case against Epstein,
because to do so would reveal JP Morgan’s complicity in Epstein’s operation.
156. Fearful that Epstein could turn on the bank for its willful blindness,
JP Morgan and Staley remained incentivized to maintain and grow the relationship
and to assist in concealing Epstein’s illegal and questionable banking practices.
157. When a subpoena was served on JP Morgan in 2009 by one of Jeffrey
Epstein’s sexual abuse victims, JP Morgan refused to comply with the subpoena,
making it abundantly clear whose side JP Morgan was on.
158. After Epstein was released from his Florida incarceration, he picked
up right where he left off—abusing young women on a daily basis, paying recruiters,
and paying hush money to victims. JP Morgan also picked right up right where it
left off—protecting Epstein’s operation and allowing it to flourish once again.
159. With the encouragement of Staley, JP Morgan knowingly and
intentionally participated in the Epstein sex-trafficking venture by (among other
things) providing the financial underpinnings for Epstein to have ready and reliable
37
access to resources—including cash—to recruit, lure, coerce, and entice young
women and girls to cause them to engage in commercial sex acts and other
degradations.
160. JP Morgan assisted and participated in Epstein’s sex-trafficking venture
by knowingly enabling him to make payments to victims, including directly or
indirectly Jane Doe 1, and others similarly situated, and obtain large sums of cash
from his various accounts in violation of structuring laws in order to finance his well-
known cash-driven sexual abuse and sex trafficking venture.
161. JP Morgan participated in Epstein’s violations of the Trafficking
Victims Protection Act (TVPA) by knowingly and intentionally facilitating,
assisting, and enabling Epstein’s illegal sexual abuse and sex-trafficking venture,
including in particular his coercive sex trafficking in violation of 18 U.S.C. §
1591(a)(1).
162. JP Morgan’s conduct knowingly and intentionally violated the
TVPA, which forbids benefiting financially by participating in a sex trafficking
venture knowing, or in reckless disregard of the fact, that means of force, threats of
force, fraud, coercion, abuse of process, and combination of those means have been
used to cause young women and girls to engage in commercial sex acts.
163. Ultimately, JP Morgan financially benefitted by earning millions of
dollars for its participation in the Epstein sex-trafficking venture.
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164. Throughout its relationship with Epstein, JP Morgan violated
numerous regulations in order to continue its lucrative venture facilitating the
Epstein sexual abuse and sex trafficking scheme.
165. It was later revealed that Staley and Epstein exchanged more than
1,200 emails between 2008 and the end of Staley’s tenure at JP Morgan, which
speaks volumes to the close personal and business relationship that the two shared.
166. Due to the extensive publicity about Jeffrey Epstein’s illegal sexual
activities, and the departure of Staley from JP Morgan, the bank finally severed ties
with Epstein in 2013.
167. After losing Staley, Epstein no longer had his primary protector at JP
Morgan. In order to continue to operate, Epstein would need to find a new bank.
168. Fortunately for Epstein, former JP Morgan banker, Paul Morris,
joined Deutsche Bank in November 2012. Soon after joining Deutsche Bank, Morris
suggested to senior management that Epstein was a potential client who could
generate millions of dollars of revenue as well as leads for other lucrative clients to
Deutsche Bank. Morris and Epstein began discussions in the spring of 2013 about a
potential relationship between Deutsche Bank and Epstein.
169. Shortly thereafter, Morris on-boarded Epstein’s accounts to Deutsche
Bank and instantly Epstein had a new bank willing to circumvent banking laws to
make profits from Epstein’s widely known sex trafficking venture.
39
170. JP Morgan enabled Epstein to have ready and reliable access to
resources—including cash—to recruit, solicit, entice, harbor, obtain, provide, and
transport young women and girls (including the plaintiffs bringing this action) to
cause them to engage in commercial sex acts and to sexually abuse them.
171. Deutsche Bank then took over exactly where JP Morgan left off, with
the complete acquired knowledge of Epstein’s history of sexual abuse and his sex
trafficking operation.
2. Banking Regulations Exist to Help Prevent Funding of Criminal Ventures.
172. The Federal Bank Secrecy Act (“BSA”) requires financial institutions
to have adequate anti-money laundering (“AML”) policies and systems in place.
New York state law requires financial institutions to devise and implement systems
reasonably designed to identify and report suspicious activity and block transactions
prohibited by law.
173. All regulated institutions are expected to configure systems based on
their unique risk factors, incorporating parameters such as institution size, presence
in high-risk jurisdictions, and the specific lines of business involved, and the
institutions have an affirmative duty to ensure that their systems run effectively.
174. In addition to having effective AML controls in place, it is also
necessary for financial institutions to monitor their customers for the purpose of
preventing their customers from facilitating criminal activity using the institutions’
40
facilities.
175. As part of preventing criminal activity, Know Your Customer
(“KYC”) and customer due diligence are critically important, and financial
institutions must collect customer information at the time of establishing new
relationships with clients, including as necessary to assess the risks associated with
the client. To properly consider these risks, financial institutions must consider
relevant factors such as the nature of the client’s business, the purpose of the client’s
accounts, and the nature and duration of the relationship.
176. Financial institutions must also conduct KYC reviews for each client
relationship at intervals commensurate to the AML risks posed by the client,
including reviewing account activity to determine whether such activity fits with
what would have been expected given the nature of the account. Each client’s AML
risk should also be re-assessed if material new information or unexpected account
activity is identified.
177. Financial institutions must also establish criteria for determining
when a client relationship poses too high of a risk and therefore must be terminated.
A financial institution may be liable under applicable laws if it maintains such a
relationship despite repeated indications of facilitation of improper transactions.
3. JP Morgan’s Knowledge about the Epstein Venture.
178. JP Morgan failed in various respects to meet its Know Your Customer
41
and other obligations fully with respect to its relationship with Jeffrey Epstein and
entities related to Epstein.
179. JP Morgan was aware that Epstein was a wealthy man with hundreds
of millions of dollars in assets and an extensive network of friends and connections
that included prominent financial institutions, politicians, royalty, and billionaires.
180. JP Morgan was aware that Epstein also had a well-publicized
reputation for sexually trafficking and abusing young women. Allegations against
him began appearing in the press as early as March 2005, with the accusation that
he paid a 14-year-old girl for a “massage.”
181. That year, the Palm Beach (Florida) Police Department began an
investigation into allegations against Epstein related to his sexual abuse in Palm
Beach. The investigation quickly uncovered dozens of other Epstein sex abuse
victims. The investigation also identified the Epstein sex-trafficking venture, which
included a number of individuals who were responsible for recruiting young women
to come to Epstein’s Palm Beach mansion to give “massages” or otherwise
furthering his abuse.
182. In 2006, the State Attorney handling the case, after meeting privately
with an attorney representing Epstein, referred the case to a state grand jury instead
of charging Epstein and his co-conspirators for crimes for which local police
believed there was abundant evidence. As a result, the Palm Beach Police Chief
42
publicly denounced the State Attorney and referred the case to the Federal Bureau
of Investigation, which subsequently opened its own investigation and interviewed
potential witnesses and victims.
183. In September 2007, Epstein agreed to plead guilty to two
“prostitution” charges in state court, including the solicitation of a minor to engage
in prostitution, in exchange for a federal non-prosecution agreement (NPA)
providing him and his co-conspirators (including Lesley Groff, Sarah Kellen,
Adriana Ross, and Nadia Marcinkova) with immunity from federal prosecution for
extensive federal sex-trafficking charges in Florida. The deal included an 18-month
sentence and Epstein was also required to register as a sex offender upon his release.
Epstein ultimately served only 13 months of his 18-month sentence in the Palm
Beach County jail and was allowed work release privileges that enabled him to leave
jail six days a week for twelve hours a day.
184. In the summer of 2008, Epstein’s non-prosecution agreement (NPA)
with the U.S. Department of Justice was made public when it was unsealed in
connection with a challenge to the NPA by two of his victims. Among other things,
the agreement outlined the possible federal sex offense charges that could have
resulted from the investigation, including charges that Epstein conspired to use a
means of interstate commerce to induce minors to engage in prostitution, to engage
in illicit sexual conduct with minors, conspiring with others to do the same, and
43
trafficking minors. That agreement also noted that the United States had compiled
“a list of individuals whom it [had] identified as victims,” and that Epstein would
pay for legal representation for these alleged victims.
185. Court proceedings involving the challenge to Epstein’s NPA
continued between 2008 and 2013 (and beyond) and attracted significant media
attention.
186. Indeed, between 2005 and 2013, press reports outlined the allegations
underlying the NPA and to varying degrees detailed the involvement of Epstein’s
alleged co-conspirators, including Lesley Groff, Sarah Kellen, and Nadia
Marcinkova.
187. Some articles reported that Lesley Groff and Sarah Kellen had
invoked their Fifth Amendment right against self-incrimination, and others reported
that Nadia Marcinkova had allegedly recruited underage girls to give Epstein
“massages.”
188. Additionally, press reports during this time noted allegations that
Epstein was involved with Eastern European women in particular and that a
modeling agency he helped fund brought “young girls . . . often from Eastern
Europe” to the U.S. on Epstein’s private jets.
189. At all times material hereto, JP Morgan was aware of the foregoing
information and more about Epstein’s sex trafficking activities.
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190. It is well known—and JP Morgan did know—that a large number of
cash transactions by a customer can be an indicator of criminal activity generally
and sex trafficking in particular.
191. Payments to victims of sex trafficking are often made in cash to avoid
leaving a “paper trail” for law enforcement or other investigators to follow
192. Forced sexual exploitation of victims has been estimated to generate
approximately $100 billion in yearly illicit profits, according to a recent study (2018)
by the Financial Action Task Force entitled “Financial Flows from Human
Trafficking.”
193. Given the illegal nature of sex trafficking, individuals perpetrating the
crime, as well as laundering the proceeds of that crime, may be identifiable by
observing financial transactions and information obtained by financial institutions in
the course of conducting their customer due diligence and the behavior of offenders.
194. Sex trafficking organizations have the need for large amounts of cash,
because many illegal transactions are often necessary to keep the organization
functioning. The techniques that financial institutions use to detect other criminal
enterprises using their services can also be employed to detect sex trafficking. For
example, sex trafficking organizations often use assets for money laundering (such
as cash, real estate, cars, etc.) that other sex trafficking organizations use.
195. Sex trafficking organizations may also make cash deposits and
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withdrawals below customer identification thresholds to avoid triggering additional
scrutiny or bank reporting requirements. Sex trafficking organizations may also use
multiple accounts to disguise the nature of their illegal transactions, thereby
“laundering” the funds involved.
196. One indicator of sex trafficking can be media coverage of an account
holder’s activities relating to sex trafficking.
197. Another indicator of sex trafficking can be recurring payments for
transportation of logistics service in the late night or early morning. A similar
indicator can be significant payments for transportation or logistics (car rental, taxi,
and ride sharing service transactions).
198. JP Morgan participated in Epstein’s violations of the TVPA by
knowingly and intentionally assisting, supporting, facilitating, and enabling
Epstein’s illegal conduct and sex-trafficking venture, including in particular his
coercive sex trafficking in violation of 18 U.S.C. § 1591(a)(1). JP Morgan’s conduct
violated the TVPA, which forbids benefitting financially from participating in a
venture that, in or affecting interstate or foreign commerce, has recruited, solicited,
enticed, transported, harbored, provided, or obtained a person knowing, or in
reckless disregard of the fact, that the person has been caused to engage in a
commercial sex act by means of force, threats of force, fraud, coercion, abuse of
process, or a combination of such means.
46
199. JP Morgan’s actions knowingly and intentionally furthered the
Epstein sex-trafficking venture, including specifically Epstein’s sex trafficking. For
example, JP Morgan provided cash to Epstein knowing that he would use the cash
to pay for commercial sex acts—including sexualized massages during which
Epstein penetrated Jane Doe 1, forcing her to engage in sexual activity.
200. JP Morgan also aided and abetted Epstein’s sex-trafficking venture
by (among other things) providing the financial underpinnings for the venture.
201. JP Morgan enabled Epstein to have ready and reliable access to
resources—including cash and a variety of bank accounts and other financial tools—
to recruit, entice, solicit, harbor, provide, obtain, and transport young women and
girls to cause them to engage in commercial sex acts.
202. JP Morgan knowingly and intentionally benefitted financially and in
other ways from its participation in Epstein’s sex-trafficking venture with
knowledge, or with reckless disregard to the fact, that Epstein used means of force,
threats of force, fraud, and coercion (and combinations thereof) to force young
women and girls into engaging in commercial sex acts.
203. As recounted throughout this complaint, JP Morgan financially
benefitted by earning millions of dollars from its participation in the Epstein-sex-
trafficking venture. The benefits that JP Morgan received came directly from its
participation in the sex-trafficking venture and because of its participation in that
47
venture. In other words, there was a causal relationship between JP Morgan’s
conduct furthering Epstein’s sex-trafficking venture and its receipt of the financial
benefits with actual (and constructive) knowledge of that causal relationship.
204. JP Morgan knowingly and intentionally financed Epstein’s illegal
sex-trafficking venture. JP Morgan knew that if it did not finance Epstein’s illegal
sex-trafficking venture, then it would lose valuable Epstein-related accounts. Faced
with the choice between profiting from Epstein’s sex-trafficking venture or
following the law, JP Morgan chose to profit.
205. In violation of various banking laws and regulations, including
various “Know Your Customer” laws, JP Morgan regularly authorized cash
withdrawals and deposits for the Epstein sex-trafficking venture, which allowed
Epstein, his co-conspirators, and those they directed to conduct the business of the
sex-trafficking venture.
206. JP Morgan’s knowing and intentional banking law violations allowed
Epstein and his various corporations to stay “under the radar” and continue the sex
trafficking operation without close scrutiny or interference.
207. JP Morgan knowingly and intentionally benefited financially from
Epstein’s sex-trafficking venture. By facilitating and financing Epstein’s
commercial sex acts in interstate and foreign commerce, JP Morgan earned interest,
commissions, service fees, and other financial benefits directly from its connection
48
with Epstein, Epstein-related entities, and others acting in concert with Epstein.
Epstein provided those financial benefits to JP Morgan precisely because it was
facilitating his sex-trafficking venture—and JP Morgan knew that was the reason
that Epstein was providing them with those financial benefits.
208. JP Morgan benefitted by receiving things of value from its
participation in the Epstein sex-trafficking venture. Among the various things of
value it received were (1) connections with Jeffrey Epstein, his co-conspirators, and
his wealthy friends and associates; (2) additional deposits from Epstein, his co-
conspirators, and his wealthy friends and associates; (3) the opportunity to earn
financial benefits from the funds that had been deposited with it. JP Morgan
knowingly and intentionally received these things of value as a direct result of its
participation in the Epstein sex-trafficking venture and because it was furthering
Epstein’s sex-trafficking venture.
209. Among the women and girls whose sex trafficking and sex abuse JP
Morgan furthered was Jane Doe 1.
4. Epstein Uses JP Morgan Accounts for the Sex-Trafficking Venture.
210. Over the course of the relationship, Epstein and his representatives
used JP Morgan accounts to send dozens of wires, directly and indirectly, to co-
conspirators in the sex-trafficking venture.
211. JP Morgan was aware that the recipients of some of these wire
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transfers described in the previous paragraph were to Epstein’s co-conspirators and
that the wire transfers were in furtherance of the Epstein sex-trafficking venture.
212. Epstein used JP Morgan accounts to pay for coerced commercial sex
acts by Jane Doe 1.
213. Given JP Morgan’s knowledge about Epstein’s past sex trafficking,
its continuation of its financial relationship with Epstein was, at a minimum, in
reckless disregard of the fact that Epstein was using means of force, threats of force,
fraud, coercion (and a combination of such means) to cause Epstein’s victims to
engage in commercial sex acts.
214. In addition to actual knowledge that it was facilitating the Epstein sex-
trafficking venture, JP Morgan benefitted financially by participating in a venture
that it should have known had engaged in coercive sex trafficking in violation of 18
U.S.C. § 1591(a).
215. If a financial institution decides to do business with a high-risk client,
that institution is required to conduct due diligence commensurate with that risk and
to tailor its transaction monitoring to detect suspicious or unlawful activity based on
what the risk is. JP Morgan knowingly, intentionally, deliberately, and maliciously
failed to do so with regard to its relationship with Epstein.
216. The Bank was well aware not only that Epstein had pled guilty and
served prison time for engaging in sex with a minor but also that there were public
50
allegations that his conduct was facilitated by several named co-conspirators.
217. Despite this knowledge, the Bank did little or nothing to inquire into
or block numerous payments to named co-conspirators, and to or on behalf of
numerous young women, or to inquire how Epstein was using hundreds of thousands
of dollars per year in cash.
218. Hush money, financial compensation to recruiters, and compensation
to victims was integral to Epstein’s scheme, without which his sex trafficking
operation could not exist. The ability to obtain exorbitant amounts of money, send
wires to young females, and obtain unlimited cash was critical to Epstein’s
operation.
219. Suspicious wire transfers and withdrawals of millions of dollars in
cash are basic hallmarks of any major criminal enterprise. A bank that would allow
Epstein to operate in this blatant criminal fashion was necessary for the growth of
his trafficking operation and for the continued abuse of hundreds of young women.
220. Before JP Morgan facilitated Epstein’s operation without question,
Epstein was able to abuse young women sporadically and in fear of being caught.
JP Morgan eliminated that fear, making sure that the suspicious money trail that
would unveil Epstein’s operation as the criminal sexual abuse machine that it was
would be covered up and not lead to his downfall.
221. The negligence of JP Morgan is clear. The complicity, though, far
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exceeded negligence, as JP Morgan acted with a high degree of moral turpitude and
demonstrated such wanton dishonesty as to imply a criminal indifference to civil
obligations. And JP Morgan also acted outrageously and intentionally.
222. JP Morgan knew Epstein had no college degree, no ongoing
legitimate business, and was engaging in sexual abuse of females on a daily basis.
JP Morgan recognized its importance to Epstein as the exclusive financial institution
that was willing to allow Epstein to engage in obvious criminal financial activities
to fund his sex trafficking venture. JP Morgan, acting through Staley, was a criminal
co-conspirator of the operation. There came a time when the JP Morgan absolutely
knew Epstein was running a sex trafficking venture. And JP Morgan choose to
remain Epstein’s banking partner to receive financial benefits in exchange for
ensuring the venture’s continued operation.
223. In order to make hundreds of millions of dollars off of Epstein and
his contacts, JP Morgan facilitated Epstein’s sex trafficking venture, which caused
billions of dollars in damages from the pain and suffering of hundreds of Epstein’s
sexual abuse and sex trafficking victims.
224. JP Morgan’s desire to maintain its profitable relationship with Epstein
led it to avoid taking steps that would have documented its involvement in Epstein’s
sex-trafficking venture.
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D. The Statute of Limitations
225. The statute of limitations under the TVPA is ten years after the cause
of action arose, or ten years after the victim reaches eighteen years of age, if the
victim was a minor at the time of the alleged offense. 18 U.S.C. § 1595(c)(1), (2).
The TVPA causes of actions for Jane Doe 1, and the other Class Members, all arose
within ten years of the filing of this complaint.
226. The New York Adult Survivor’s Act has opened up a one-year revival
window for the statute of limitations.
VI. CLASS ACTION ALLEGATIONS
227. Plaintiff Jane Doe 1 brings this action pursuant to Federal Rule of
Civil Procedure 23(b)(3) and 23(c)(4) on behalf of themselves and the following
Class:
All women who were sexually trafficked by Jeffrey Epstein during the
time when JP Morgan maintained bank accounts for Epstein and/or
Epstein related-entities, which was in or about 2000 through in or about
August 2013, both dates inclusive (the “Class Period”).
228. Plaintiff reserves the right to seek leave to modify this definition,
including the addition of one or more subclasses, after having the opportunity to
conduct discovery.
229. Numerosity: The Class consists of dozens of women, making joinder
impracticable, in satisfaction of Fed. R. Civ. P. 23(a)(1). The exact size of the Class
and the identities of the individual Class members are ascertainable through records
53
maintained by the Epstein estate and the Defendant, including but not limited to JP
Morgan’s records for Epstein-related accounts (e.g., account ledgers reflecting
payments from Epstein to Class members).
230. Typicality: Plaintiff’s claims are typical of the claims of the other
Class members she seeks to represent. The claims of Plaintiff and the other Class
members are based on the same legal theories and arise from the same unlawful
pattern and practice of Defendant’s participation in and funding of the Epstein’s
sexual abuse and Epstein’s sex-trafficking venture.
231. Commonality: There are many questions of law and fact common to
the claims of Plaintiff and the other Class members, and those questions predominate
over any questions that may affect only individual Class members, within the
meaning of Fed. R. Civ. P. 23(a)(2) and (b)(3). Class treatment of common issues
under Fed. R. Civ. P. 23(c)(4) will materially advance the litigation.
232. Common questions of fact and law affecting Class members include,
but are not limited to, the following:
a. Whether the Epstein sex-trafficking venture caused its victims to

engage in commercial sex acts in violation of Trafficking Victims Protection
Act, 18 U.S.C. § 1591(a)(1);
b. Whether the Epstein sex-trafficking venture recruited, enticed,

solicited, harbored, provided, obtained, and transported victims in ways that
were in or affecting interstate or foreign commerce;
c. Whether Epstein and his co-conspirators used means of force,

fraud, coercion, and abuse of legal process, or a combination of such means,
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to sexually abuse the victims and to cause victims to engage in commercial

sex acts;
d. Whether JP Morgan knowingly and intentionally assisted,

facilitated, and supported the Epstein sex-trafficking venture’s pattern and
practice of coercively forcing victims to engage in commercial sex acts;
e. Whether JP Morgan benefitted financially or by receiving things

of value from its participation in a venture which has engaged in sex
trafficking in violation of TVPA, 18 U.S.C. § 1591(a)(1);
f. Whether JP Morgan knew or should have known that the Epstein

sex-trafficking venture had engaged in violations of the TVPA, 18 U.S.C. §
1591(a); and
g. Whether JP Morgan committed negligent acts or omissions that

facilitated sexual abuse which would constitute a sexual offense as defined in
article one hundred thirty of the penal law committed against such persons
who were eighteen years of age or older.
233. Absent a class action, most of the Class members would find the cost
of litigating their claims to be cost-prohibitive and will have no effective remedy.
The class treatment of common questions of law and fact is also superior to multiple
individual actions or piecemeal litigation, in that it conserves the resources of the
courts and the litigants and promotes consistency and efficiency of adjudication.
234. Adequacy: Jane Doe 1 will fairly and adequately represent and protect
the interests of the other Class members she seeks to represent. Jane Doe 1 has
retained counsel with substantial experience in prosecuting complex litigation and
class actions. Plaintiff and her counsel are committed to vigorously prosecuting this
action on behalf of the other Class members and have the financial resources to do
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so. Neither Plaintiff nor her counsel have any interests adverse to those of the other
Class members.
235. This action has been brought and may properly be maintained as a
class action against Defendant pursuant to Rule 23 of the Federal Rules of Civil
Procedure because there is a well-defined community of interest in the litigation and
the proposed Class is easily ascertainable from Defendant’s records.
236. Superiority: A class action is superior to all other available methods
for the fair and efficient adjudication of this controversy because:
a. Joinder of all Class Members is impracticable;

b. The prosecution of individual remedies by members of the Class will tend
to establish inconsistent standards of conduct for Defendant and result in
the impairment of Class Member’s rights and the disposition of their
interests through actions to which they were not parties;
c. Class action treatment will permit a large number of similarly-situated
persons to prosecute their common claims in a single forum
simultaneously, efficiently, and without the unnecessary duplication of
effort and expense that numerous individual actions would engender;
d. Absent a class action, Class Members will continue to suffer losses and be
aggrieved and Defendant will continue to violate New York and federal law
without remedy;
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e. Class treatment of this action will cause an orderly and expeditious

administration of class claims, economies of time, effort and expense will
be fostered, and uniformity of decisions will be ensured;
f. Plaintiff and her counsel are unaware of any class action brought against
any Defendant for the violations alleged in this action;
g. The forum is desirable because the Defendant conducted the subject
business with Jeffrey Epstein in this District and Class Members were
consequently trafficked in this District; and,
h. This action presents no difficulty that would impede its management by the
Court as a class action.
VII. CAUSES OF ACTION
COUNT I
INTENTIONAL AND NEGLIGENT ACTS AND OMISSIONS
UNDER THE NEW YORK ADULT SURVIVORS ACT
NEW YORK CPLR § 214-j.
237. Plaintiff Jane Doe 1 realleges and incorporates by paragraphs 1 - 236,
as if fully set forth in this Count.
238. Plaintiff Jane Doe 1 brings this Count individually and on behalf of
the other Class members they respectively seek to represent.
239. Pursuant to New York Civil Practice Law and Rules § 214-j, this
Count for intentional and negligent acts and omissions has been timely filed, as every
civil claim or cause of action brought against any party alleging intentional and
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negligent acts or omissions by a person for physical, psychological, or other injury
or condition suffered as a result of conduct which would constitute a sexual offense
as defined in article one hundred thirty of the penal law committed against such
person who was eighteen years of age or older was revived effective November 24,
2022.
240. Intentional and negligent actions and omissions committed by JP
Morgan within this District and elsewhere directly and proximately resulted in
sexual offenses by Epstein and his co-conspirators under the laws of the State of
New York (e.g., New York Penal Law Art. 130, including New York Penal Law §§
130.20, 130.35, 130.50, 130.52, and 130.66), which injured Plaintiff Jane Doe 1 and
the other Class Members.
241. As a financial institution operating within this District and within the
State of New York, JP Morgan owed legal duties to Plaintiff Jane Doe 1 and the
Class Members to exercise reasonable care to monitor JP Morgan’s customers
(including Jeffrey Epstein) for the purpose of preventing them from facilitating and
engaging in foreseeable criminal activity using the Bank’s facilities that could harm
the Plaintiff and the Class Members.
242. The legal duties of JP Morgan described in the two preceding
paragraphs also extended to the other Class members whom Plaintiff Jane Doe 1
seeks to represent.
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243. The legal duties of JP Morgan include, but are not limited to,
following the Know Your Customer (“KYC”) laws and related regulations described
above.
244. Under KYC laws, banks have special duties to inquire about possible
crimes being committed by their customers—duties above and beyond any duties
that the general public may have. The inquiries that banks must make include duties
to inquire about specific individuals who are being harmed. The regulations establish
a duty of care that must be followed by banks, including JP Morgan.
245. But for JP Morgan, Epstein could not have successfully run and
expanded his sexual abuse organization. While would have wanted to sexually abuse
women, he could not have abused the hundreds of victims that he did without JP
Morgan.
246. JP Morgan breached its legal duties to Plaintiff Jane Doe 1 and the
Class Members by failing to discharge its legal duties to prevent Jeffrey Epstein and
others from using the Bank’s facilities to facilitate and commit criminal activity
harming Jane Doe 1 and the Class Members. The criminal activity that harmed
Plaintiff and Class Members included foreseeable federal crimes committed by the
Epstein sex trafficking enterprise described above, as well as the state sex offense
crimes.
247. As a direct and proximate result of the breach of legal duties by JP
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Morgan, Plaintiff Jane Doe 1 and the Class Members repeatedly suffered foreseeable
injuries from Epstein and his co-conspirators, including federal and state sexual
offenses (including sexual assaults) and resulting emotional distress, mental pain and
suffering, and other physical, psychological, and other injuries. The breaches of legal
duties were the direct—i.e., the but-for-cause—of these injuries. Without JP
Morgan’s breaches of its legal duties, those injuries would not have occurred.
248. The breaches of legal duties were the direct—i.e., the but-for—cause
of these injuries. Without Defendant’s breaches of legal duties, those injuries would
not have occurred. The injuries that occurred were readily foreseeable to JP Morgan.
249. The injuries that Plaintiff Jane Doe 1 and the Class Members suffered
included injuries directly and proximately suffered while they were adults who were
present in this District. These injuries are permanent in nature and Jane Doe 1 and
the other class members will continue to suffer these losses in the future.
250. The injuries that Plaintiff Jane Doe 1 and the Class Members suffered
included injuries directly and proximately suffered as a result of sex offenses
committed by Epstein and other co-conspirators and criminalized under article 130
of the New York Penal Laws. The offenses included sexual intercourse without
consent and oral sexual conduct without consent, forbidden by New York Penal Law
§ 130.20. The offenses included forcible touching of sexual or other intimate parts
without consent, forbidden by New York Penal Law §§ 130.20, 130.35, 130.50,
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130.52, and 130.66.
251. The breaches of legal duties by JP Morgan proximately caused
Plaintiff Jane Doe 1 and the Class Members to repeatedly suffer injuries from
Epstein and his co-conspirators, including sexual assaults and resulting emotional
distress, mental pain and suffering, and other physical and psychological trauma.
These injuries were easily foreseeable, because JP Morgan knew, and acted in
reckless disregard of the fact, that their actions and omissions supporting and
facilitating Epstein would lead to (among other crimes) sex offenses by Epstein and
his co-conspirators forbidden by article 130 of New York Penal Law against his
victims, including Jane Doe 1 and the Class Members.
252. In the exercise of reasonable care, JP Morgan and its employees knew
or should have known of the dangerous propensities of Jeffrey Epstein and the
proximately harm that would be caused by his likely sexual crimes and various
violations of article 130 of New York Penal Law.
253. JP Morgan could reasonably foresee that its actions and omissions in
facilitating Epstein’s sex trafficking enterprise would lead to sex offenses against
Jane Doe 1 and the Class Members. Among other things, the Defendant was
specifically aware that Epstein had previously been prosecuted for similar sex crimes
and previously paid numerous civil settlements associated with similar sex crimes.
Indeed, Defendant was aware, and should have been aware, that Epstein was a high
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risk to commit sex offenses against young women and girls.
254. Plaintiff Jane Doe 1 and the Class Members were easily within the
zone of foreseeable harm from JP Morgan’s intentional and negligent acts and
omissions. JP Morgan’s intentional and negligent acts and omissions foreseeably
created substantial risk of Jeffrey Epstein and his co-conspirators committing sex
crimes against young women with whom he was in contact. Tragically, Jane Doe 1
and the Class Members fell within that zone.
255. The sex offenses Jeffrey Epstein committed against Jane Doe 1 and
the Class Members were easily within the zone of foreseeable risks that the JP
Morgan created with its intentionally and negligent actions and omissions. Those
actions and omissions foreseeably risked further sex crimes by Jeffrey Epstein and
his co-conspirators—which is exactly and tragically the harm that he inflicted on
Jane Doe 1 and the Class Members.
256. While the foregoing allegations easily make out a clear case of
negligence, this case does not involve mere negligence. Instead, Defendant’s tortious
conduct in this case evinced a high degree of moral turpitude and demonstrated such
wanton dishonesty as to imply a criminal indifference to civil obligations. It also
involved outrageous and intentional acts and omissions, because it was a deliberate
attempt to further the crimes of a widespread and dangerous criminal sex trafficking
organization. Defendant’s tortious conduct was directed specifically at Jane Doe 1
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and the Class Members, who were the victims of Epstein’s sexual abuse and sex
trafficking organization.
257. As a result of the intentional and negligent actions and omissions
described in this Count, Plaintiff Jane Doe 1 and the Class Members have sustained
both general and specifical damages in substantial amounts.
258. By virtue of acting intentionally, outrageously, and with a high degree
of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal
indifference to civil obligations. Defendant is liable to Jane Doe 1 and other
members of the class for punitive damages.
COUNT II
PARTICIPATING IN A SEX-TRAFFICKING VENTURE IN VIOLATION
OF THE TRAFFICKING VICTIMS PROTECTION ACT,
18 U.S.C. §§ 1591(a)(2), 1595
259. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs
1 – 236, as if fully set forth in this Count.
260. Plaintiff Jane Doe 1 brings this Count individually and on behalf of the
other Class members she seeks to represent.
261. JP Morgan knowingly and intentionally participated in, assisted,
supported, and facilitated a sex-trafficking venture that was in and affecting
interstate and foreign commerce, together and with others, in violation of 18 U.S.C.
§ 1591(a)(2).
262. JP Morgan knowingly and intentionally benefited financially from, and

63
received value for, its participation in the sex-trafficking venture, in which Epstein,
with JP Morgan’s knowledge, or its reckless disregard of the fact, that Epstein would
use means of force, threats of force, fraud, coercion, and a combination of such
means to sexually abuse Jane Doe 1, as well as other Class members, and cause Jane
Doe 1, as well as other Class members, to engage in commercial sex acts. Some of
Epstein’s victims were under the age of 18.
263. Among the financial benefits that JP Morgan received for participating
in and facilitating Epstein’s sex-trafficking venture were the deposit of funds that
Epstein and Epstein-controlled entities made to JP Morgan. JP Morgan profited from
the use of these deposits. Epstein and Epstein-controlled entities deposited these
funds in exchange for JP Morgan’s facilitation and participation in the sex trafficking
venture.
264. Among the financial benefits that the Defendant received for
participating in Epstein’s sex-trafficking venture was referral of business
opportunities from Epstein and his co-conspirators. JP Morgan profited from these
referred business opportunities. Epstein referred business entities and business
opportunities to JP Morgan in exchange for its facilitation and participation in the
sex trafficking venture.
265. JP Morgan financially profited from the deposits made by Epstein and
Epstein-controlled entities and from the business opportunities referred to JP
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Morgan by Epstein in exchange for its facilitation and participation in Epstein’s sex
266. JP Morgan knew, and recklessly disregarded the fact, that it was
Epstein’s pattern and practice to use the channels and instrumentalities of interstate
and foreign commerce, to entice, recruit, solicit, harbor, provide, obtain, and
transport young women and underage girls for purposes of causing commercial sex
acts, in violation of 18 U.S.C. § 1591(a)(1).
267. JP Morgan and its employees had actual knowledge that they were
facilitating Epstein’s sexual abuse and sex trafficking conspiracy to recruit, solicit,
entice, coerce, harbor, transport, obtain and provide Jane Doe 1 as well as other
members of the Class, into commercial sex acts, through the means of force, threats
of force, fraud, abuse of process, and coercion.
268. Despite such knowledge, JP Morgan intentionally paid for, facilitated,
and participated in Epstein’s violations of 18 U.S.C. § 1591(a)(1), which Defendant
knew, and was in reckless disregard of the fact that, Epstein would coerce, defraud,
and force Jane Doe 1, as well as other members of the Class, to engage in commercial
sex acts.
269. JP Morgan, through its employees and agents, actively participated in
the sex trafficking conspiracy and led Jane Doe 1, as well as other members of the
Class, to believe that they would be rewarded if they cooperated and acquiesced to
65
Epstein’s demands.
270. JP Morgan’s affirmative conduct was committed knowing, or in
reckless disregard of the facts, that Epstein would use cash and financial supported
provided by JP Morgan as a means of defrauding, forcing, and coercing sex acts
from Jane Doe 1 as well as other members of the Class. Defendant’s conduct was
outrageous and intentional.
271. In addition to actual knowledge that they were participating in and
facilitating the Epstein sex-trafficking venture, JP Morgan also should have known
that it was participating in and facilitating a venture that had engaged in coercive sex
trafficking in violation of 18 U.S.C. § 1591(a)(1).
272. In exchange for facilitating and covering up Epstein’s commercial sex
trafficking, JP Morgan’s employees advanced in their careers at JP Morgan and
received financial benefits there from.
273. Facilitating and covering up Epstein’s sexual misconduct was a means
of obtaining economic success and promotion within the JP Morgan hierarchy.
274. JP Morgan’s knowing and intentional conduct has caused Jane Doe 1
and the other members of the Class serious harm including, without limitation,
physical, psychological, emotional, financial, and reputational harm.
275. JP Morgan’s knowing and intentional conduct has caused Jane Doe 1
and the other members of the Class harm that is sufficiently serious, under all the
66
surrounding circumstances, to compel a reasonable person of the same background
and in the same circumstances to perform or to continue performing commercial
sexual activity, in order to avoid incurring that harm.
276. This case does not involve mere fraud. Instead, JP Morgan’s tortious
conduct in violating the TVPA was outrageous and intentional because it was in
deliberate furtherance of a widespread and dangerous criminal sex trafficking
organization. JP Morgan’s tortious conduct also evinced a high degree of moral
turpitude and demonstrated such wanton dishonesty as to imply a criminal
indifference to civil obligations. JP Morgan’s tortious conduct was directed
specifically at Jane Doe 1 and other members of the class, who were the victims of
Epstein’s sexual abuse and sex trafficking organization.
277. By virtue of these violations knowing and intentional violations of 18
U.S.C. §§ 1591(a)(2), 1595, JP Morgan is liable to Jane Doe 1 and the other members
of the Class for the damages they sustained and reasonable attorneys’ fees.
278. By virtue of these intentional and outrageous violations of 18 U.S.C. §§
1591(a)(2), 1595, JP Morgan is liable to Jane Doe 1 and other members of the class
for punitive damages.
COUNT III
CONSPIRACY TO COMMIT VIOLATIONS OF THE TRAFFICKING
VICTIM PROTECTION ACT, 18 U.S.C. §§ 1594(c),1595
279. Plaintiff Jane Doe 1 realleges and incorporates by reference
67
paragraphs 1 – 236, as if fully set forth in this Count.
the other Class members she respectively seeks to represent.
281. JP Morgan intentionally conspired with others, by agreement and
understanding, to violate 18 U.S.C. § 1591(a), and to further Epstein’s sex-
trafficking venture to coerce commercial sex acts from Jane Doe 1 and other Class
members, all in violation of 18 U.S.C. § 1594(c). JP Morgan employees conspired
with Epstein himself to further the sex trafficking venture.
282. JP Morgan conspired with Epstein and his co-conspirators to further
the Epstein sex-trafficking venture and with the purpose of facilitating Epstein’s
illegal sex trafficking.
283. JP Morgan intentionally committed overt acts in furtherance of the
conspiracy, agreement, and understanding to violate 18 U.S.C. § 1591(a) by
knowingly playing an active role in assisting, supporting, and facilitating the
recruiting, enticing, coercing, harboring, transporting, and inducing Jane Doe 1 and
other Class members to engage in commercial sex acts, through providing financial
support for the Epstein sex-trafficking venture.
284. Among the many overt acts intentionally committed by JP Morgan in
furtherance of the sex-trafficking venture were creating and maintaining a financial
relationship between JP Morgan and Epstein within this District.
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285. It was part of the conspiracy that JP Morgan would financially benefit
from providing financial support for the Epstein sex-trafficking venture. JP Morgan
did financially benefit from its participation in the venture, including receiving
valuable deposits from Epstein and Epstein-related entities into JP Morgan.
286. JP Morgan’s participation in furthering Epstein’s sex-trafficking
venture was intentional and willful and, therefore, JP Morgan intentionally and
willfully caused Epstein’s commission of the commercial sex acts with Jane Doe 1
and other Class members through its affirmative and overt acts supporting Epstein.
287. JP Morgan knew, or acted in reckless disregard of the fact, that its
acts and conduct supporting and facilitating Epstein would lead to unlawful coercive
commercial sex acts by Epstein with young women and girls, including Jane Doe 1
and other Class members.
288. JP Morgan conspired with Epstein through their affirmative acts and
provided substantial support to Epstein committing commercial sex acts upon Jane
Doe 1 and other Class members.
289. In addition to acting with knowledge that they were supporting the
Epstein sex-trafficking venture, JP Morgan benefitted financially from participating
in the Epstein sex-trafficking venture which JP Morgan also should have known that
had engaged in coercive sex trafficking in violation of 18 U.S.C. § 1591(a)(1).
290. Defendant’s conduct has caused Jane Doe 1 and other Class members
69
serious harm, including, without limitation, physical, psychological, financial, and
reputational harm.
291. Defendant’s conduct has caused Jane Doe 1 harm that is sufficiently
serious, under all the surrounding circumstances, to compel a reasonable person of
the same background and in the same circumstances to perform or to continue
performing commercial sexual activity in order to avoid incurring that harm.
292. This case does not involve mere fraud. Instead, Defendant’s tortious
conduct in conspiring to violate the TVPA was outrageous and intentional, because
it was in deliberate furtherance of a widespread and dangerous criminal sex
trafficking organization. Defendant’s tortious conspiracy also evinced a high degree
of moral turpitude and demonstrated such wanton dishonesty as to imply a criminal
indifference to civil obligations. Defendant’s tortious conspiracy was directed
specifically at Jane Doe 1 and other members of the class, who were the victims of
Epstein’s sex trafficking organization.
293. By virtue of these violations of 18 U.S.C. §§ 1594(c), 1595,
Defendant is liable to Jane Doe 1 and the other members of the Class for the damages
they sustained and reasonable attorneys’ fees.
294. By virtue of its intentional and outrageous conspiracy to violate 18
U.S.C. §§ 1594(c), 1595, Defendant is liable to Jane Doe 1 and other members of
the class for punitive damages.
70
COUNT IV
ATTEMPT TO COMMIT VIOLATIONS OF THE TRAFFICKING VICTIM
PROTECTION ACT, 18 U.S.C. §§ 1594(a), 1595
295. Plaintiff Jane Doe 1 realleges and incorporates by reference
paragraphs 1 - 236, as if fully set forth in this Count.
the other Class members she respectively seeks to represent.
297. JP Morgan intentionally attempted to violate 18 U.S.C. § 1591(a), and
to further Epstein’s sex-trafficking venture to coerce commercial sex acts from Jane
Doe 1 and other Class members, all in violation of 18 U.S.C. § 1594(a).
298. JP Morgan employees deliberately took substantial steps to attempt
to violate 18 U.S.C. § 1591(a) within this District.
299. JP Morgan deliberately took substantial steps toward attempting to
violate 18 U.S.C. § 1591(a) providing financial support for the Epstein sex-
300. Among the many substantial steps taken by JP Morgan to deliberately
attempt to violate 18 U.S.C. § 1591(a) were creating a financial relationship between
JP Morgan and Epstein within this District.
301. It was part of the attempt to violate 18 U.S.C. 1591(a) that JP Morgan
would financially benefit from providing financial support for the Epstein sex-
trafficking venture. JP Morgan did financially benefit from its participation in the
71
venture, including receiving valuable deposits from Epstein and Epstein-related
entities into JP Morgan.
302. Defendant’s attempt to violate the TVPA by furthering Epstein’s sex-
trafficking venture was intentional and willful and, therefore, Defendant’s
intentionally and willfully caused Epstein’s commission of sexual abuse and
commercial sex acts with Jane Doe 1 and other Class members through its
affirmative and overt acts supporting Epstein.
303. Defendant knew and acted in reckless disregard of the fact, that its
acts and conduct supporting and facilitating Epstein would lead to sexual abuse and
unlawful coercive commercial sex acts by Epstein with young women and girls,
including Jane Doe 1 and other Class members.
304. In addition to acting intentionally and with knowledge that they were
supporting the Epstein sex-trafficking venture, Defendant benefitted financially
from participating in the Epstein sex-trafficking venture which Defendant should
have known that had engaged in coercive sex trafficking in violation of 18 U.S.C. §
1591(a)(1).
305. This case does not involve mere fraud. Instead, Defendant’s tortious
conduct in attempting to violate the TVPA was outrageous and intentional, because
it was a deliberate attempt to further the crimes of a widespread and dangerous
criminal sex trafficking organization. Defendant’s tortious attempts also evinced a
72
high degree of moral turpitude and demonstrated such wanton dishonesty as to imply
a criminal indifference to civil obligations. Defendant’s tortious attempt was
directed specifically at Jane Doe 1 and other members of the class, who were the
victims of Epstein’s sex trafficking organization.
306. Defendant’s conduct has caused Jane Doe 1 and other Class members
serious harm, including, without limitation, physical, psychological, financial, and
reputational harm.
307. By virtue of these violations of 18 U.S.C. §§ 1594(a), 1595(a),
Defendant is liable to Jane Doe 1 and the other members of the Class for the damages
they sustained and reasonable attorneys’ fees.
308. By virtue of its intentional and outrageous attempt to violate 18
U.S.C. §§ 1594(a), 1595, Defendant is liable to Jane Doe 1 and other members of
the class for punitive damages.
VIII. REQUEST FOR RELIEF
Jane Doe 1 respectfully requests that the Court enter judgment in her
favor, and against JP Morgan, as follows:
a. That the Court certify the Class, name Jane Doe 1 as Class
Representative, and appoint her lawyers as Class Counsel;
b. That the Court award Plaintiff and the other members of the Class
compensatory, consequential, general, nominal, and punitive damages
73
against Defendant in an amount to be determined at trial;
c. That the Court award punitive and exemplary damages against Defendant
in an amount to be determined at trial;
d. That the Court award to Plaintiff the costs and disbursements of the
action, along with reasonable attorneys’ fees, costs, and expenses;
e. That the Court award pre- and post-judgment interest at the maximum
legal rate; and
f. That the Court grant all such other and further relief as it deems just and
proper.
JURY DEMAND
Plaintiffs demand a trial by jury on all claims so triable.
Dated: November 24, 2022
Respectfully Submitted,
EDWARDS POTTINGER, LLC
By: /s/ Bradley Edwards

Bradley J. Edwards
425 N. Andrews Ave., Suite 2
Fort Lauderdale, FL 33301
(954)-524-2820
Fax: (954)-524-2822
Email: brad@epllc.com
EDWARDS POTTINGER
Brittany N. Henderson
1501 Broadway
Floor 12
New York, NY
74
(954)-524-2820
Fax : (954)-524-2820
Email : brittany@epllc.com
David Boies
Boies Schiller Flexner LLP
55 Hudson Yards
New York, New York
Telephone: (212) 446-2300
Facsimile: (212) 446-2350
E-mail: dboies@bsfllp.com
Sigrid McCawley
Pro Hac Vice
Boies Schiller Flexner LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL 33316
Telephone: (954) 356-0011
Facsimile: (954) 356-0022
E-mail: smccawley@bsfllp.com
75
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Jpmorgan Sex Trafficking Suit

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Case 1:22-cv-10019 Document 1 Filed 11/24/22 Page 1 of 75

UNITED STATES DISTRICT COURT FOR THE

Jane Doe 1, individually and on)

INDIVIDUAL AND CLASS ACTION COMPLAINT

federal anti-sex trafficking statute, 18 U.S.C. §§ 1591-95, et seq.—the Trafficking

financially benefitting from participating in Jeffrey Epstein’s sex trafficking by

international sex trafficking organization from 1998 through August 2013.

JP Morgan knowingly and intentionally benefited and received things of value

offenses against countless young women.

years, including through the criminal investigation and incarceration of Jeffrey

Epstein, in order to churn profits.

Plaintiff makes the following allegations on information and belief and

set forth herein after a reasonable opportunity for discovery:

I. JURISDICTION, VENUE, AND TIMELINESS

1. This action is brought pursuant to various federal and state statues,

federal question subject-matter jurisdiction pursuant to 28 U.S.C. § 1331, because

Jane Doe 1—individually and on behalf of the other Class members—proceeds

under the federal TVPA statute.

3. This Court is “an appropriate district court of the United States” in

trafficked Jane Doe 1 and members of the Class is this District.

from which to transport them to other locations outside of New York.

cause of action occurred in this District.

6. This action has been timely filed pursuant to 18 U.S.C. § 1595(c)(1),

under New York’s Adult Survivor’s Act, N.Y. CPLR § 214-j.

and domiciled in the State of New York.

8. Plaintiff Jane Doe 1 is using a pseudonym to protect her identity

conspirators who participated in the Epstein sex-trafficking venture had—and

continue to possess—tremendous wealth and power and have demonstrated a clear

ability to cause her serious harm.

interest in her identification.

11. Jane Doe 1’s legitimate concerns outweigh any prejudice to

Defendant by allowing her to proceed anonymously. Accordingly, Jane Doe will be

filing a Motion to Proceed Anonymously.

most of these other women are known to Defendant.

13. Defendant JP Morgan is a global financial institution headquartered

in New York, New York.

14. Defendant JP Morgan is licensed by the New York State Department

15. Defendant JP Morgan currently conducts substantial business in this

16. As one example of business conducted in this District, JP Morgan

another example, JP Morgan maintains branch banks within this District.

17. JP Morgan’s financial activities, including the events alleged herein,

interstate telephone communications, and the facilities of national securities

19. Jeffrey Epstein’s sex-trafficking venture operated in many respects as

a sex-themed cult designed to ensnare vulnerable young women and indoctrinate

from which they could never recover.

21. The Epstein sex-trafficking venture originated in the early 1990’s.

operated to conceal its sex trafficking from law enforcement organizations.

22. The Epstein sex-trafficking venture was well-structured from the

young women and as its relationship with Defendant JP Morgan grew.

24. Epstein’s sex-trafficking venture was not possible without the

assistance and complicity of a financial institution—specifically, banking

institution—which provided special treatment to the sex-trafficking venture, thereby

trafficking scheme could not have existed.

women and girls.

financial engine behind the sex-trafficking operation.

27. Epstein masterfully assessed the specific needs and vulnerability of

indoctrinating them to believe that the sexual abuse was normal.

28. Epstein fraudulently represented to the victims that he would take

create the opportunity for Epstein to sexually abuse them.

29. The Epstein sex-trafficking venture’s purpose included enticing,