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intentionally inflicted emotional distress against Jane Doe 1 and the Class Members. 
304. JP Morgan's actions, described above, constitute extreme and 
outrageous conduct that shocks the conscience. 
For example, JP Morgan 
intentionally and knowingly participated in Epstein's sex-trafficking venture, as 
outlined above. JP Morgan had a legal duty not to participate in, facilitate, or aid and 
abet Epstein's sex-trafficking venture and Epstein's Chapter 130 Crimes. 
305. JP Morgan's conduct was especially extreme and outrageous due to 
Jane Doe 1 and the Class Members' particular vulnerabilities as targets of a sex-
trafficking venture. 
306. JP Morgan intended to cause, and did cause, Jane Doe 1 and the Class 
Members severe emotional distress. At the very least, JP Morgan recklessly 
disregarded a substantial probability that its actions in aiding, abetting, and 
facilitating Epstein's sex crimes would cause Jane Doe 1 and the Class Members 
severe emotional distress. 
307. Because JP Morgan intentionally inflicted extreme emotional distress 
on Jane Doe I and the Class Members, it is liable to Jane Doe 1 and the Class 
Members for damages they suffered as a direct and proximate result. 
308. As a direct and proximate result of JP Morgan's conduct, Jane Doe 1 
and the Class Members have in the past and will in the future continue to suffer 
substantial damages from psychological and physical injury, including extreme 
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emotional distress, humiliation, fear, psychological trauma, loss of dignity and self-
esteem, and invasion of privacy. JP Morgan's aiding, abetting, and facilitating 
Epstein's sex crimes in violation of Chapter 130 directly and proximately caused 
Epstein's sex crimes. 
309. 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 I and other 
Members of the Class for punitive damages. 
COUNT III 
NEGLIGENT FAILURE TO EXERCISE REASONABLE CARE TO 
PREVENT PHYSICAL HARM 
310. Plaintiff Jane Doe I realleges and incorporates by reference paragraphs 
1 - 285, as if fully set forth in this Count. 
311. Jane Doe 1 brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
312. In addition to any duties that might arise as a financial institution 
(alleged in the next Count, below), JP Morgan owed a duty to Jane Doe 1 and the 
Class Members to exercise reasonable care to avoid conduct that created a risk of 
physical harm to them. JP Morgan's duties included a duty to exercise reasonable 
care to avoid conduct that would combine with Epstein's crimes, and permit 
Epstein's crimes, in violation of Chapter 130. 
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313. JP Morgan's own conduct in providing financial and other support for 
Epstein's sex trafficking venture set forces in motion that directly and proximately 
injured and caused physical harm to Jane Doe 1 and the Class Members. These 
forces that JP Morgan set in motion caused Epstein's intentional tortious conduct 
and Chapter 130 Crimes against Jane Doe 1 and the Class Members, causing 
physical harm and in themselves constituted physical harm to Jane Doe 1 and the 
Class Members. JP Morgan owed Jane Doe 1 and the Class Members a duty not to 
set those forces in motion because they unreasonably created a risk of physical harm. 
314. JP Morgan reasonably could foresee, and did in fact foresee, that its 
negligent failure to prevent physical harm would result in physical harm to Jane Doe 
1 and the Class Members. JP Morgan owed a duty to prevent that physical harm. 
315. JP Morgan failed to act objectively reasonably in failing to take 
precautions to prevent Epstein's intentional tortious conduct and sex-trafficking and 
sex crimes in violation of Chapter 130, which were committed against Jane Doe 1 
and the Class Members. If JP Morgan had acted reasonably to prevent physical 
harm, it would not have supported and allowed Epstein's tortious conduct and sex-
trafficking and sex crimes to occur. JP Morgan owed Jane Doe 1 and the Class 
members a duty to act objectively reasonably. 
316. At the time of JP Morgan's own negligent conduct, JP Morgan both 
realized and should have realized the likelihood that it was creating an opportunity 
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for Epstein to commit intentional tortious conduct and Chapter 130 Crimes against 
Jane Doe 1 and the Class Members. Indeed, HI Morgan knew that its own conduct 
was necessary to create Epstein's opportunities to engage in that conduct and commit 
those crimes. JP Morgan owed Jane Doe 1 and the Class Members a duty not to 
create those opportunities for Epstein. 
317. JP Morgan's breaches of its legal duties were the direct—Le., the but-
for—cause of physical and psychological injuries to Jane Doe 1 and the Class 
Members. Without JP Morgan's breaches of legal duties, those injuries would not 
have occurred. The injuries that occurred were readily foreseeable to JP Morgan. 
318. Jane Doe 1 and the Class Members were easily within the zone of 
foreseeable harm from the JP Morgan's negligent acts and omissions. JP Morgan's 
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. 
319. Because of JP Morgan's negligent failure to prevent physical harm to 
Jane Doe 1 and the Class Members, it is liable to Jane Doe 1 and the Class Members 
for damages suffered as a direct and proximate result. 
320. As a direct and proximate result of JP Morgan's negligent failure to 
prevent physical harm, Jane Doe 1 and the Class Members have in the past and will 
in the future continue to suffer substantial damages from psychological and physical 
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injury, including extreme emotional distress, humiliation, fear, psychological 
trauma, loss of dignity and self-esteem, and invasion of privacy. JP Morgan's 
aiding, abetting, and facilitating Epstein's tortious conduct and sex crimes in 
violation of Chapter 130 directly and proximately caused Epstein's sex crimes. 
321. 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 IV 
NEGLIGENT FAILURE TO EXERCISE REASONABLE CARE AS A 
BANKING INSTITUTION PROVIDING NON-ROUTINE BANKING 
322. Plaintiff Jane Doe I realleges and incorporates by reference paragraphs 
1 - 285, as if fully set forth in this Count. 
323. Jane Doe 1 brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
324. JP Morgan owed a duty to Jane Doe 1 and the Class Members not to 
knowingly provide non-routine banking support and assistance for Epstein that it 
knew, and reason to know, would lead to and support intentional tortious conduct 
and Chapter 130 Crimes by Epstein against Jane Doe 1 and the Class Members. 
325. As described in detail above, JP Morgan did not merely provide routine 
banking support for Epstein. Instead, it participated in, aided and abetted, and 
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facilitating his sex-trafficking venture and his commission of intentional tortious 
conduct and Chapter 130 crimes. JP Morgan also knew, and was willfully blind to 
the fact, that it was going beyond providing routine banking support but instead 
facilitating Epstein's sex-trafficking venture and his commission of tortious conduct 
and Chapter 130 crimes. 
326. As an example, in providing hundreds of thousands of dollars in cash 
to Epstein and his co-conspirators in circumstances where it knew that the cash 
would be used to facilitate coercive sex acts, JP Morgan took substantial actions 
outside the scope of a routine, lawful, and ordinary customer relationship. 
327. As another example, JP Morgan deliberately failed to follow numerous 
banking requirements in connection with financial dealings with Epstein, including 
AML rules, KYC rules, and anti-structing rules. In deliberately ignoring and failing 
to follow those rules, JP Morgan acted in a non-routine way to facilitate and support 
Epstein's and his co-conspirators' intentional torts, sex-trafficking, and commission 
of Chapter 130 Crimes. Jr, Morgan, through Staley, knew that Epstein was abusing 
females sexually on a daily basis and through that knowledge, developed a special 
relationship with Epstein. As a banking institution providing the necessary 
infrastructure to the sex trafficking operation, JP Morgan developed a special 
relationship with Epstein and thus undertook an obligation to protect others from his 
abuse. 
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328. Likewise, JP Morgan, acting through Staley, having observed Jane Doe 
1 in circumstances indicating sexual abuse and trafficking, and whose relationship 
with Epstein was always maintained for the benefit of JP Morgan, owed a duty to 
protect the victims from the abuse of Jeffrey Epstein about which Staley, on behalf 
of JP Morgan, was well aware. 
329. JP Morgan also owed Jane Doe 1 and the Class Members a duty of care 
because it affirmatively and intentionally chose not to investigate Epstein's 
suspicious banking activities even after being confronted with explicit information 
that Epstein was using JP Morgan to further a sex-trafficking venture harming Jane 
Doe 1 and the Class Members. JP Morgan chose not to do so because it knew what 
the investigation would reveal, and that it would need to end its lucrative relationship 
with Epstein as a result of the investigation. Once JP Morgan had information about 
Epstein's use of JP Morgan for a sex-trafficking venture, and once it knew or has 
reason to know that it was providing material support to that venture, it owed a duty 
of care to investigate suspicious banking activity. 
330. But for JP Morgan, Epstein could not have successfully run and 
expanded his sexual abuse organization. Epstein could not have abused the hundreds 
of victims that he did without JP Morgan. 
331. JP Morgan failed to act objectively reasonably by failing to comply 
with relevant banking laws and regulations with regard to its interactions with 
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Epstein and his co-conspirators. JP Morgan owed a duty to Jane Doe 1 and the Class 
Members to act objectively reasonably in its interactions with Epstein and his co-
conspirators and to exercise reasonable care to prevent them from engaging in 
foreseeable tortious and criminal activity by using JP Morgan's exceptional and non-
routine banking infrastructure. 
332. JP Morgan owed a legal duty to Jane Doe 1 and the Class Members to 
act objectively reasonably and to not deliberately ignore banking obligations, 
including KYC and AML laws and regulations described above, so as to provide 
Epstein and others with an opportunity to engage in tortious conduct, coercive sex-
trafficking and Chapter 130 Crimes. 
333. Under KYC, AML, and related laws and regulations, JP Morgan had 
special duties not ignore tortious conduct and crimes being committed by its 
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 banks know are being harmed. The regulations establish a duty of 
care that must be followed by banks, including JP Morgan. These duties exist at 
least in situations where a bank is knowingly going beyond offering routine banking 
for its customers and instead offers banking infrastructure specially adapted to 
facilitate tortious conduct and crimes. 
334. JP Morgan also owed Jane Doe 1 and the Class Members a duty of care 
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because it knew, and had reason to know, that Epstein and his co-conspirators were 
using JP Morgan to facilitate a sex-trafficking venture, raising a duty to make a 
reasonable inquiry about suspicious activity. 
335. JP Morgan owed Jane Doe 1 and the Class Member a duty not to 
deliberately and purposely fail to file SARs—filings which would have alerted 
federal authorities to Epstein's and his co-conspirators' illegal activities, including 
committing Chapter 130 Crimes. 
336. JP Morgan also owed Jane Doe 1 and the Class Members a duty to 
prevent physical harm to them when confronted with explicit information that 
Epstein and his co-conspirators were using JP Morgan's non-routine banking to 
further a sex-trafficking venture harming Jane Doe 1 and the Class Members. Once 
JP Morgan had information about Epstein's use of JP Morgan for a sex-trafficking 
venture that was physically harming Jane Doe 1 and the Class Members, it owed 
them a duty of care to investigate and prevent Epstein's and his co-conspirators' 
suspicious, tortious, and criminal activities. 
337. In the exercise of reasonable care, JP Morgan and its employees knew, 
and should have known, of the dangerous propensities of Jeffrey Epstein and his co-
conspirators to commit intentional torts and violations of article 130 of New York 
Penal Law against women and girls with whom he was in close proximity, including 
Jane Doe 1 and the Class Members. 
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338. JP Morgan breached its legal duties to Jane Doe 1 and the Class 
Members as described above. JP Morgan's breach of its duties led to it failing to 
prevent Epstein from committing intentional torts and Chapter 130 Crimes against 
Jane Doe 1 and the Class Members. 
JP Morgan realized that Epstein were 
committing intentional torts and Chapter 130 Crimes against Jane Doe 1 and the 
Class Members. The criminal activity that harmed Jane Doe 1 and the Class 
Members included foreseeable intentional torts as well as TVPA and Chapter 130 
Crimes committed by the Epstein. 
339. As a direct and proximate result of the breach of legal duties by JP 
Morgan, Jane Doe 1 and the Class Members repeatedly suffered direct and 
foreseeable injuries from Epstein and his co-conspirators, including injuries from 
federal and state sexual offenses (including sexual assaults) and resulting emotional 
distress, mental pain and suffering, and other physical, psychological, and other 
injuries. 
340. The breaches of JP Morgan's legal duties were the direct—Le., the but-
for—cause of these physical and psychological injuries to Jane Doe 1 and the Class 
Members. Without JP Morgan's breaches of its legal duties, those injuries would 
not have occurred. The injuries that occurred were readily foreseeable to JP Morgan. 
341. The injuries that Jane Doe 1 and the Class Members suffered included 
injuries directly and proximately suffered while they were adults who were present 
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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. 
342. JP Morgan could reasonably foresee that their actions and omissions in 
facilitating Epstein's sex trafficking enterprise would lead to intentional torts and 
sex offenses against Jane Doe land the Class Members. Indeed, JP Morgan was 
aware, and should have been aware, that Epstein was a high risk to commit sex 
offenses against young women and girls. 
343. Jane Doe 1 and the Class Members were easily within the zone of 
foreseeable harm from JP Morgan's negligent acts and omissions. JP Morgan's acts 
and omissions foreseeably created substantial risk of Jeffrey Epstein and his co-
conspirators committing intentional torts and sex crimes against young women with 
whom he was in contact. Tragically, Jane Doe 1 and the Class Members fell within 
that zone. 
344. While the foregoing allegations easily make out a clear case of 
negligence, this case does not involve mere negligence. Instead, Defendants' 
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. JP Morgan's tortious conduct was directed 
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specifically at Jane Doe 1 and other Members of the Class, who were the victims of 
Epstein's sexual abuse and sex trafficking organization. 
345. As a result of JP Morgan's negligent actions and omissions described 
in this Count, Jane Doe 1 and the Class Members have sustained both general and 
specifical damages from physical and psychological injury in substantial amounts. 
346. 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 V 
KNOWING BENEFICIARY IN A SEX-TRAFFICKING VENTURE IN 
VIOLATION OF THE TRAFFICKING VICTIMS PROTECTION ACT, 
18 U.S.C. §§ 1591(aX2), 1595 
347. Plaintiff Jane Doe I realleges and incorporates by reference paragraphs 
1 - 285, as if fully set forth in this Count. 
348. Jane Doe I brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
349. JP Morgan knowingly and intentionally benefitted, financially and by 
receiving things of value, from participating in, assisting, supporting, and facilitating 
an illegal coercive 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). 
350. JP Morgan took many concrete steps to aid and participate in Epstein's 
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sex-trafficking venture. Among the concrete steps that JP Morgan took to aid Epstein 
was providing vast sums of cash, which made the sex-trafficking venture possible. 
Providing Epstein with large sum of U.S. currency caused JP Morgan to receive 
financial benefits. JP Morgan's willingness to provide large amounts of cash to 
Epstein was the quid pro quo for it receiving financial benefits from Epstein. 
351. The cash that JP Morgan provided was necessary for Epstein to coerce 
Jane Doe 1 as well as other Class Members to engage in commercial sex acts. The 
cash directly formed part of the commercial nature of the sex acts. The cash was 
also a necessary and required part of Epstein's recruitment of Jane Doe 1 and other 
victims of his sex-trafficking venture. By providing cash that JP Morgan knew 
would be used to fund the sex trafficking venture, JP Morgan actively participated 
in the recruitment of victims of the venture. 
352. The cash that JP Morgan provided went far beyond providing routine 
banking opportunities for a client. It was far from routine for JP Morgan to provide 
substantial sums of cash per year to Epstein, who did not have an apparent legitimate 
need for such extravagant sums. Moreover, the circumstances in which Epstein was 
requesting such large amounts were far from routine and raised numerous "red 
flags"—taking it well outside routine circumstances. 
353. JP Morgan providing large sums of cash to Epstein, under the 
circumstances of this case, was entirely inconsistent with the ordinary duties of a 
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bank or its employees. 
354. The reason that JP Morgan ignored the numerous red flags about 
Epstein was to receive financial benefits from Epstein and his sex-trafficking 
venture. JP Morgan knew that it would gain far-from-routine financial benefits by 
ignoring the red flags associated with Epstein and by participating in his sex-
trafficking venture. 
355. Among the concrete steps that JP Morgan took to aid and participate in 
the Epstein sex-trafficking venture were opening up numerous accounts at JP 
Morgan for Epstein, his related entities, and associates. By opening these accounts, 
JP Morgan received many benefits from participating in Epstein's venture. The 
opening of these accounts was affirmative conduct that caused JP Morgan to receive 
those benefits. 
356. Among the concrete steps that JP Morgan took to aid the Epstein sex-
trafficking venture, between about 2000 and continuing through about August 2013, 
JP Morgan concealed its delivery of vast sums of cash (likely hundreds of thousands 
of dollars) to Epstein and his associates. In order to benefit from the Epstein sex-
trafficking venture, JP Morgan willfully failed to timely file required SARs with the 
federal government, because doing so would imperil its ability to profit from the 
sex-trafficking venture. JP Morgan's concealment of the cash transactions caused it 
to receive financial benefits through continuation of the Epstein sex-trafficking 
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venture. 
357. Among the concrete steps that JP Morgan took to aid the Epstein sex-
trafficking venture were its failure to follow AML requirements. This failure was 
not just passive facilitation, but a deliberate omission by JP Morgan. This omission 
was specific act of concealment, which allowed Epstein to continue funding his sex-
trafficking venture through suspicious transactions that would have otherwise been 
prevented. 
358. By taking the concrete steps outlined above (along with the others 
alleged in this complaint), JP Morgan knowingly participated in sex trafficking and 
furthered the Epstein sex-trafficking venture. The concrete steps above constituted 
taking part in the sex-trafficking venture and were necessary for its success. The 
concrete steps above constituted active engagement by JP Morgan in Epstein's sex-
trafficking venture. 
359. JP Morgan knowingly and intentionally benefited financially from, and 
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 cause Jane Doe I, as well as other Class Members, some of whom were 
under the age of eighteen, to engage in commercial sex acts. 
360. JP Morgan actually knew, through Staley and other officers and 
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employees, that it was participating in a particular sex-trafficking venture—i.e., the 
coercive Epstein sex-trafficking venture outlined above. JP Morgan's knowledge 
went far beyond having an abstract awareness of sex trafficking in general. Indeed, 
JP Morgan discussed internally Epstein's specific sex trafficking and the large 
amounts of cash that JP Morgan was giving him. Thus, JP Morgan did not simply 
fail to adequately detect signs of Epstein's sex trafficking; it did detect multiple signs 
of Epstein's coercive sex-trafficking venture and continued to participate in the 
venture. JP Morgan knew that the venture was on-going, which was why Epstein 
required vast sums of cash. 
361. JP Morgan's actions extend well beyond a situation of failing to train 
its staff about recognizing the warning signs of sex trafficking. JP Morgan's 
employees did recognize the signs of Epstein's sex trafficking. Indeed, JP Morgan's 
employees knew about Epstein's sex-trafficking venture. But JP Morgan decided to 
continue facilitating the Epstein sex-trafficking venture rather than ending its 
participation in the venture. 
362. Among the signs that JP Morgan was facilitating Epstein's sex 
trafficking venture were those facts that came to the attention of JP Morgan's 
employees discussed above, which caused those employees to escalate issues 
regarding Epstein's coercive sex-trafficking venture to more senior levels. 
363. Among the signs that JP Morgan was facilitating Epstein's sex 
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trafficking venture were those facts that came to the attention of JP Morgan were 
those facts that came to its attention through Jes Staley's observations of Epstein's 
sex trafficking. Because of those observations, Staley—and JP Morgan—knew to a 
certainty that Epstein was engaged in sex trafficking. 
364. JP Morgan's actual knowledge extended to the fact that specific 
individual women and girls were being coercively sex trafficked by Epstein between 
the time of his on-boarding and the termination of its relationship with Epstein. Even 
if JP Morgan did not know all the names of Epstein's victims, it knew that specific 
victims (e.g., Jane Doe 1) of a specific trafficker (Epstein) at a specific time period 
(various dates between 2000-2013 and following) existed and were being forced to 
engage in commercial sex acts. It also knew that some of the victims had eastern 
European surnames. JP Morgan was on notice, and knew, that such victims were 
being coercively trafficked by Epstein's sex-trafficking venture. 
365. One of JP Morgan's officers, Jes Staley, also knew the names of the 
many of Epstein's sex trafficking victims. 
366. JP Morgan helped to conceal the names of Epstein's victims from the 
public and from law enforcement and prosecuting agencies by helping to conceal the 
existence of the sex-trafficking venture. Among the ways in which JP Morgan 
helped to conceal the venture's existence was by providing the cash necessary for 
the venture to avoid leaving a visible "paper trail." 
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367. JP Morgan's concealment included failing to follow through on 
enhanced monitoring that was required for someone like Epstein. JP Morgan failed 
to implement that enhanced monitoring specifically to help conceal Epstein's 
ongoing sex-trafficking. JP Morgan knew that if it implemented that enhanced 
monitoring, it would have to stop providing Epstein with the cash needed to run his 
sex-trafficking venture. 
368. JP Morgan's concealment included failing to file required SARs for 
Epstein's suspicious cash transactions. 
369. In addition to having actual knowledge that it was participating in 
Epstein's sex trafficking venture, JP Morgan had constructive knowledge that it was 
participating in Epstein's sex trafficking venture. JP Morgan also had constructive 
knowledge that Jane Doe 1, as well as other Members of the Class, were being 
coercively sex trafficked by Epstein. Its constructive knowledge extended to the 
names of Epstein's victims, because Epstein and his associates knew the names of 
the victims. Staley also the knew the names of many of the victims. 
370. JP Morgan had constructive knowledge of Epstein's sex-trafficking 
venture because of specific acts by Epstein that put it on notice of a particular and 
ongoing sex trafficking venture. Among the specific acts were Epstein's use of vast 
sums of cash in circumstances that prompted JP Morgan employees to specifically 
raise questions about Epstein's sex-trafficking. 
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371. Also among the specific acts giving rise to constructive knowledge 
were the facts that associates of Epstein made numerous cash withdrawals from JP 
Morgan accounts. The circumstances of these withdrawals gave the bank notice that 
"structuring" was occurring to avoid alerting federal authorities. 
372. Among the financial benefits that the 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, including its willingness to provide large amounts of cash 
in suspicious circumstances and to allow "structuring" of withdrawals to avoid 
triggering reporting requirements. 
373. Among the financial benefits that JP Morgan 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. These referrals were a quid pro quo for JP Morgan's participation in the 
sex-trafficking venture. 
374. JP Morgan financially profited from the deposits made by Epstein and 
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Epstein-controlled entities and from the business opportunities referred to JP 
Morgan by Epstein in exchange for its facilitation and participation in Epstein's sex 
trafficking venture. 
375. JP Morgan knowingly received financial benefits in return for its 
assistance, support, and facilitation of Epstein's sex-trafficking venture. JP Morgan 
knew that if it stopped providing assistance, support, and facilitation of Epstein's 
sex-trafficking venture, it would no longer receive those benefits. 
376. JP Morgan knew, and was in reckless disregard of 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. § 159I(a)(1). 
377. 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, and a combination of all these means. 
378. Despite such knowledge, JP Morgan intentionally paid for, facilitated, 
and participated in Epstein's violations of 18 U.S.C. § 1591(a)(1), which JP Morgan 
knew, and were in reckless disregard of the fact that, Epstein would coerce, defraud, 
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