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capacity as an officer and employee of JP Morgan. All of the information contained 
in those emails is imputed to JP Morgan, including information about sexual and 
related topics. These emails show, among other things, the close personal 
relationship between Epstein and Staley, that Epstein and Staley communicated and 
visited while Epstein was incarcerated, and that Staley visited Epstein's private 
island on multiple occasions. 
234. Despite knowledge of Epstein's illegal trafficking operation and the 
fact that one of JP Morgan's top executives being so in bed with the operation, JP 
Morgan continued to aid Epstein in his sex trafficking enterprise. 
235. JP Morgan, through its agents and employees such as Staley, had direct 
and specific knowledge that Epstein was operating a sex-trafficking venture and that 
he needed extraordinary banking infastructure from JP Morgan to successfully 
operate that illegal venture. 
236. JP Morgan also knew that Sarah Kellen and Nadia Marcinkova, women 
with Epstein-facilitated bank accounts at JP Morgan whom Staley knew well, were 
involved in the trafficking. 
237. Importantly, in January 2007, in the heart of the federal criminal 
investigation, Epstein trafficked Jane Doe 1 to the U.S. Virgin Islands where she was 
repeatedly raped. Not coincidentally, she was taken on Epstein's private jet—the 
same one Staley traveled on—with Sarah Kellen and Nadia Marcinkova, the same 
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JP Morgan account-holding passengers Staley traveled with and who were identified 
by the U.S. Government as Epstein's criminal co-conspirators. 
238. JP Morgan also knew from the press that Epstein was a registered sex 
offender who was always surrounded by young girls. Even so, JP Morgan conspired 
with Epstein to assist him to operate the financial side of the sex-trafficking scheme. 
239. JP Morgan knew, through Staley and other information, without any 
doubt that Epstein was a serial abuser and that sex-trafficking was his everyday 
lifestyle. JP Morgan also knew that without the bank's complicity, Epstein could 
not pay for commercial sex acts, for co-conspirators, for his co-conspirators' 
lawyers, for his own legal dream team, or for his private planes to traffic women to 
his New York mansion and island to abuse. 
240. Numerous of Epstein's co-conspirators had JP Morgan accounts tied to 
Epstein accounts. During the time when Kellen and Marcinkova were publicly outed 
as co-conspirators of Epstein's, they each had JP Morgan accounts that were noted 
as Epstein-related accounts, putting JP Morgan on clear notice that the criminal 
organization Epstein was running through the bank was an expansive one of sexual 
abuse and trafficking. 
241. MC2, the Epstein/Brunel modeling agency that was used to expand the 
trafficking scheme internationally, was funded through JP Morgan loans on Epstein 
accounts. This agency was started at a time when Brunel had already been publicly 
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ostracized from other known modeling agencies because he was a child sex abuser, 
a fact which JP Morgan was aware. 
242. All of Epstein's connections that were known to in) Morgan were either 
very wealthy individuals, companies that had no verifiable legitimate purpose, 
internationally known sex-abusing model scouts, publicly identified co-conspirators 
in the Epstein sex trafficking operation the crimes of which were identified in a 
public non-prosecution agreement, and young women and girls who could not 
possibly have a legal and legitimate connection to Epstein. JP Morgan knew all of 
this against the backdrop of their client—Epstein—having no professional expertise 
or legitimate business with legitimate banking needs. 
243. JP Morgan worked with Epstein to open new accounts in the name of 
companies that had no plausible legitimate purpose, move money from one account 
to another to mask payments to sexual abuse victims or co-conspirators, make wire 
transfers to trafficking recruiters, and worked with Epstein's agents to make his sex 
trafficking conspiracy less obvious to law enforcement authorities and others. 
244. 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, and JP Morgan knew Epstein was a sex trafficker 
constantly needing access to large amounts of cash. 
245. Payments to victims of sex trafficking are often made in cash to avoid 
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leaving a "paper trail" for law enforcement or other investigators to follow. 
246. 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." 
247. 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. 
248. 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 accounts 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 criminal organizations use. 
249. Sex trafficking organizations may also make cash deposits and 
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. 
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250. One indicator of sex trafficking can be media coverage of an account 
holder's activities relating to sex trafficking. 
251. 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). 
4. Epstein used JP Morgan accounts for the sex-trafficking venture, and JP 
Morgan knowingly and directly benefits from the venture. 
252. 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. 
253. Over the course of the relationship, Epstein and his representatives also 
obtained vast sums of cash from JP Morgan to fund the sex-trafficking venture. 
254. JP Morgan was aware that the recipients of some of these wire transfers 
and cash described in the previous paragraphs were to Epstein's co-conspirators and 
that the wire and cash transfers were in furtherance of the Epstein sex-trafficking 
venture. 
255. JP Morgan was aware that known co-conspirators of Epstein also had 
JP Morgan accounts. 
256. Epstein used JP Morgan accounts to pay, through wire transfers and in 
cash, for coerced commercial sex acts by Jane Doe 1 and other Class Members. 
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257. 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. 
258. 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. 
259. JP Morgan 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 
allegations that his conduct was facilitated by several named co-conspirators. 
260. Despite its knowledge, JP Morgan deliberately 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. JP Morgan intentionally failed to conduct this 
basic inquiry, knowing that an inquiry would reveal the sex-trafficking scheme. 
Instead, it chose to continue to financially benefit from its relationship with Epstein 
and his co-conspirators. 
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261. Hush money, financial compensation to recruiters, and compensation 
to victims was integral to Epstein's scheme, without which his sex-trafficking 
conspiracy could not effectively operate. The ability to send wire transfers and cash 
to young females was critical to Epstein's ability to coerce his victims into 
commercial sex acts. 
262. 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 him to continue 
to operate his sex-trafficking conspiracy and for the continued abuse of hundreds of 
young women. 
263. In January 2013 — the year JP Morgan terminated Epstein's accounts—
the Office of the Comptroller of the Currency ("OCC") entered into a consent order 
with JP Morgan regarding deficiencies in the bank's overall program for BSA/AML 
compliance. The OCC found that JP Morgan failed to develop adequate due 
diligence on customers and failed to comply with federal banking regulations. In 
fact, the OCC noted that JP Morgan "failed to identify significant volumes of 
suspicious activity."2
264. Before JP Morgan became Epstein's banker, Epstein was only able to 
2 
See 
NYSDFA 
Consent 
Order 
at 
2-4 
(Jan. 
14, 
2013), 
https://occ.treas.govinews-issuances/news-releases/2013/nr-occ-2013-8a.pdf. 
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abuse young women sporadically and in fear of being caught. Once JP Morgan 
became Epstein's banker, it eliminated that fear, agreeing and conspiring with 
Epstein to ensure that the suspicious money trail that would reveal Epstein's 
operation would be concealed. 
265. 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. 
266. JP Morgan knowingly and intentionally benefited financially and in 
other ways from its participation in Epstein's sex-trafficking venture, with 
knowledge, or with reckless disregard of 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. 
267. As recounted throughout this complaint, JP Morgan financially 
benefited 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 
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. 
268. By facilitating and financing Epstein's commercial sex acts in interstate 
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and foreign commerce, JP Morgan earned interest, commissions, fees, and other 
financial benefits directly from its connection 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. 
269. JP Morgan benefited 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. 
270. 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. 
271. In violation of various banking laws and regulations, including various 
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"Know Your Customer" and anti-structuring 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. 
272. 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. 
273. Among the young women and girls whose sex trafficking and sex abuse 
JP Morgan participated in, benefited from, aided and abetted, and furthered were 
Jane Doe 1 and the Class Members. 
D. The Statute of Limitations 
274. 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, arose 
within ten years of the filing of this complaint. Epstein's sex-trafficking venture 
constituted a criminal conspiracy and a sex-trafficking venture that operated 
continuously from around 1998, through and including September 2013, and up to 
and following Epstein's death in 2019. The conspiracy and venture undertook 
criminal actions in violation of the TVPA throughout those years, including 2013 
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and after, thereby automatically bringing all actions in furtherance of the conspiracy 
and venture within TVPA's statute of limitations. 
275. The New York Adult Survivors Act has opened up a one-year revival 
window for the statute of limitations regarding intentional and negligent torts 
connected to violations of the New York Penal Law Chapter 130. See New York 
State, Governor Hochul Signs Adult Survivors Act, Governor Kathy Hochul (May 
24, 
2022), 
https://wvvw.governor.ny.govinews/governor-hochul-signs-adult-
survivors-act ("For many survivors, it may take years to come to terms with the 
trauma of sexual assault and feel ready to seek just."). 
VI. CLASS ACTION ALLEGATIONS 
276. Jane Doe 1 brings this action pursuant to Federal Rule of Civil 
Procedure 23(b)(3) and 23(c)(4) on behalf of herself and the following Class: 
All women who were sexually abused or trafficked by Jeffrey Epstein during 
the time when JP Morgan maintained bank accounts for Epstein and/or 
Epstein related-entities, which included January 1, 1998, through in or about 
August 2013, both dates inclusive, and continuing to the time of Epstein's 
death on August 10, 2019 (the "Class Period"). 
277. Jane Doe 1 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. 
278. 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 
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and the identities of the individual Class members are ascertainable through records 
maintained by the Epstein Estate and JP Morgan, including but not limited to JP 
Morgan's records for Epstein-related accounts (e.g., account ledgers reflecting 
payments from Epstein to Class members). 
279. Typicality: Jane Doe 1's claims are typical of the claims of the other 
Class members she seeks to represent. The claims of Jane Doe 1 and the other Class 
members are based on the same legal theories and arise from the same unlawful 
pattern and practice of JP Morgan's participation in, conspiring to join in, and 
funding of the Epstein's sexual abuse and Epstein's sex-trafficking venture. 
280. Commonality: There are many questions of law and fact common to 
the claims of Jane Doe 1 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. 
281. Common questions of fact and law affecting Class members include, 
but are not limited to, the following: 
a. Whether the Epstein sex-trafficking venture and conspiracy 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 and conspiracy recruited, 
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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, 
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 benefited 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); 
g. Whether JP Morgan was part of conspiracy to violate 18 U.S.C. § 
1591(a), in violation of 18 U.S.C. § 1594(c); and 
h. Whether JP Morgan committed intentional and negligent acts or 
omissions that facilitated sexual abuse which would constitute a sexual 
offense as defined in article 130 of New York Penal Law committed 
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against such persons who were eighteen years of age or older. 
282. 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. 
283. Adequacy: Jane Doe I 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. Jane Doe 1 and her counsel are committed to vigorously prosecuting 
this action on behalf of the other Class members and have the financial resources to 
do so. Neither Jane Doe 1 nor her counsel have any interests adverse to those of the 
other Class members. 
284. This action has been brought and may properly be maintained as a class 
action against JP Morgan 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 JP Morgan's records. 
285. 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; 
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b. The prosecution of individual remedies by members of the Class will 
tend to establish inconsistent standards of conduct for JP Morgan 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 JP Morgan will escape liability for its criminal and 
tortious conduct and be able to continue to violate New York and 
federal law without remedy; 
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. Jane Doe 1 and her counsel are unaware of any class action brought 
against JP Morgan by victims for the violations alleged in this action; 
g. The forum is desirable because Jane Doe 1 conducted the subject 
business with Jeffrey Epstein in this District and Class Members were 
consequently trafficked in this District; and, 
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h. This action presents no difficulty that would impede its management by 
the Court as a class action. 
VII. CAUSES OF ACTION 
COUNT I 
AIDING, ABETTING, AND FACILITATING 
BATTERY 
286. Plaintiff Jane Doe 1 realleges and incorporates by paragraphs 1 — 285, 
as if fully set forth in this Count. 
287. Jane Doe 1 brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
288. Between about 1998 and 2013, in this District in New York, Jeffrey 
Epstein intentionally committed batteries and other intentional tortious conduct, 
including crimes in violation of New York Penal Law Chapter 130 such as New 
York Penal Law §§ 130.20, 130.35, 130.50, 130.52, and 130.66 (hereinafter 
"Chapter 130 crimes"), against Jane Doe 1 and the Class Members. Epstein 
committed the intentional tortious conduct and crimes against Jane Doe 1 and Class 
Members and when they were 18 or older. As described throughout this complaint, 
Epstein intentionally and non-consensually touched Jane Doe 1 and the Class 
Members in a harmful and offensive manner that resulted in substantial injuries, 
including damages from physical and psychological injury, extreme emotional 
distress, humiliation, fear, psychological trauma, loss of dignity and self-esteem, and 
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invasion of privacy. 
289. The resulting injuries that Jane Doe 1 and the Class Members suffered 
include 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, 
130.52, and 130.66. 
290. Regardless of when the tortious conduct (e.g., battery) and Chapter 130 
Crimes were committed by Epstein, the conduct and crimes are now civilly 
actionable, regardless of any statute of limitations to the contrary, because they are 
covered by the one-year "look back" window in New York Adult Survivors Act. 
See N.Y. C.P.L.R. § 214-j. 
291. Between about 1998 and 2013, JP Morgan knowingly and intentionally 
aided, abetted, and facilitated Epstein's intentional tortious conduct (e.g., battery), 
through Chapter 130 Crimes recounted in the preceding paragraphs of this Count. 
Because JP Morgan criminally aided, abetted, and facilitated Epstein's conduct and 
crimes in violation of Chapter 130, it is vicariously and otherwise liable for damages 
caused by the conduct and crimes. 
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292. Between about 2000 and 2013, when it provided substantial assistance 
to Epstein, JP Morgan was well aware of its important and substantial role as a part 
of Epstein's intentionally tortious and illegal activity in committing Chapter 130 
Crimes. 
293. As a direct and proximate result of Epstein's tortious conduct and 
crimes, which JP Morgan knowingly and intentionally aided, abetted, and facilitated, 
Jane Doe 1 and the Class Members have in the past suffered, and in the future will 
continue to suffer, substantial damages, including damages from physical and 
psychological injury, extreme emotional distress, humiliation, fear, psychological 
trauma, loss of dignity and self-esteem, and invasion of her privacy. 
294. At the time of Epstein's batteries, intentionally tortious conduct, and 
crimes against Jane Doe 1 and the Class Members, JP Morgan was well aware of 
Epstein's sex-trafficking venture and that its concrete steps in furtherance of the 
venture were aiding, abetting, and facilitating his batteries, tortious conduct, and 
crimes. 
295. At the time of Epstein's crimes against Jane Doe 1 and the Class 
Members, JP Morgan knowingly provided substantial assistance in Epstein's 
tortious conduct and crimes. That knowing substantial assistance went beyond mere 
knowledge and approval of Epstein's wrongdoing. For example, JP Morgan 
knowingly and intentionally provided the cash and the financial support that made 
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it possible for Epstein to commit the coercive sex offenses described in the preceding 
paragraphs in this Count. Without that cash and financial support, Epstein could not 
have committed his tortious conduct and crimes—a fact that in) Morgan knew. 
296. JP Morgan knowingly and intentionally committed both substantial acts 
in support of Epstein and substantial deliberate omissions in support of Epstein. For 
example, JP Morgan deliberately omitted to take important steps (such as timely 
filing SARs) that substantially assisted Epstein to commit his crimes against Jane 
Doe 1 and Class Members in violation of New York Penal Law Chapter 130. 
297. In aiding, abetting, and facilitating Epstein's intentional tortious 
conduct and crimes, JP Morgan could readily foresee direct and proximate injury to 
Jane Doe 1 and the Class Member. JP Morgan should have foreseen direct and 
proximate injury from its actions and inactions to Jane Doe and the Class Members. 
Indeed, JP Morgan did foresee injury to Epstein's victims, including Jane Doe 1 and 
Class Members. 
298. In aiding, abetting, and facilitating Epstein's tortious conduct and 
crimes, JP Morgan committed intentional torts directed against Jane Doe 1 and the 
Class Members. JP Morgan's aiding, abetting, and facilitating Epstein's tortious 
conduct and crimes were its own wrongful acts and omissions. JP Morgan had a 
duty not to commit tortious conduct and crimes-specifically aiding, abetting, and 
facilitating New York sex crimes as described above— directed against Jane 1 and 
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the Class Members. 
299. As a result of the foregoing, JP Morgan is liable civilly for damages it 
directly, tortiously, and criminally caused to Jane Doe 1 and the Class Members. 
Jane Doe 1 and the Class Members according are entitled to bring a cause of action 
for damages for physical, psychological, or other injury or condition suffered as a 
direct and proximate result of JP Morgan's aiding, abetting, and facilitating 
Epstein's tortious conduct and crimes described above and for damages for physical, 
psychological, or other injury or condition suffered as a direct and proximate result 
of Epstein's tortious conduct and crimes. 
300. 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, JP Morgan is liable to Jane Doe 1 and other 
Members of the Class for punitive damages. 
COUNT II 
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 
301. Plaintiff Jane Doe 1 realleges and incorporates by paragraphs 1 — 285, 
as if fully set forth in this Count. 
302. Jane Doe 1 brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
303. As a direct and proximate result of aiding, abetting, and facilitating 
Epstein's tortious conduct and sex crimes in violation of Chapter 130, JP Morgan 
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