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high degree of moral turpitude and demonstrated such wanton dishonesty as to imply 
a criminal indifference to civil obligations. JP Morgan's criminal attempt was 
directed specifically at Jane Doe 1 and other members of the Class, who were the 
victims of Epstein's sex trafficking organization. 
465. JP Morgan's conduct has caused Jane Doe 1 and other Class Members 
serious harm, including, without limitation, physical, psychological. financial, and 
reputational harm. This harm was a direct, proximate, and foreseeable result of JP 
Morgan's attempt in violation of 18 U.S.C. § 1594(a). 
466. By virtue of these violations of 18 U.S.C. § 1594(a), JP Morgan is liable 
to Jane Doe 1 and the other Members of the Class for the damages they sustained 
and reasonable attorneys' fees under 18 U.S.C. § 1595. 
467. By virtue of its intentional and outrageous attempt to violate 18 U.S.C. 
§ 1594(a), in) Morgan is liable to Jane Doe 1 and other members of the Class for 
punitive damages under 18 U.S.C. § 1595. 
COUNT X 
OBSTRUCTION OF THE ENFORCEMENT OF THE TRAFFICKING 
VICTIM PROTECTION ACT, 18 U.S.C. § 1591(d) 
468. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs 
1 — 285, as if fully set forth in this Count. 
469. Jane Doe 1 brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
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470. JP Morgan and its officers and employees (including Staley) knowingly 
and intentionally obstructed, attempted to obstruct, interfered with, and prevented 
the enforcement of 18 U.S.C. §§ 1591(a)(1) & (a)(2), all in violation of 18 U.S.C. § 
1591(d). This activity is hereinafter referred to collectively simply as "obstruction." 
471. JP Morgan's obstruction of the enforcement of 18 U.S.C. §§ 1591(a)(1) 
and (a)(2) was forbidden by 18 U.S.C. § 1591(d), and JP Morgan thereby violated 
Chapter 77, Title 18. JP Morgan's obstruction described here and in the preceding 
paragraph directly, proximately, and foreseeably harmed Jane Doe 1, as well as other 
members of the Class, by directly resulting in them coercively being caused to 
engage in commercial sex acts and in other ways. 
472. As outlined above, the United States Department of Justice (including 
the U.S. Attorney's Office for the Southern District of New York and the U.S. 
Attorney's Office for the Southern District of Florida) was investigating Epstein's 
federal criminal liability for violating (among other laws) the TVPA up to and 
following the return of an indictment against Epstein on or about July 8, 2019. On 
or about that date, the U.S. Attorney's Office for the Southern District of New York 
indicted Epstein (and unnamed "associates") for violating the TVPA. Later, on about 
June 29, 2020, the same Office indicted Epstein's co-conspirator, Ghislaine 
Maxwell, for conspiracy to entice minor victims to travel to be abused by Epstein. 
The federal criminal investigation of Maxwell included investigation of possible 
122 
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violations of the TVPA. 
473. By providing financing for Epstein's sex trafficking organization from 
about 2000 through about August 2013, and concealing its actions thereafter, .n) 
Morgan obstructed, interfered with, and prevented the federal government's 
enforcement of the TVPA against Epstein. To the extent that the federal government 
was able to ultimately charge Epstein with TVPA violations, the filing of those 
charges was delayed by JP Morgan's actions. Because of that delay, Jane Doe 1 as 
well as other members of the Class, were coercively caused to engage in commercial 
sex acts. 
474. As one example of how JP Morgan obstructed, attempted to obstruct, 
interfered with, and prevented the federal government's enforcement of the TVPA, 
JP Morgan provided large amounts of cash to Epstein and his associates so that the 
coercive commercial sex acts would escape the detection of federal law enforcement 
and prosecuting agencies. JP Morgan provided large amounts of cash to further the 
Epstein sex-trafficking venture and with the purpose of helping Epstein evade 
criminal liability for violating the TVPA. 
475. As another example of how JP Morgan obstructed, attempted to 
obstruct, interfered with, and prevented the federal government's enforcement of the 
TVPA, JP Morgan did not follow AML and anti-structuring reporting requirements 
found in the Banking Secrecy Act and other laws. These requirements included an 
123 
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obligation that JP Morgan would review transactions in the Epstein's .n) Morgan 
accounts for a determination of whether they involved suspicious transactions. If JP 
Morgan had observed these requirement imposed by law, then it would have 
prevented many of the subsequent transactions committed by the Epstein sex-
trafficking venture. JP Morgan knowingly did not follow these requirements 
because it knew that doing so would have prevented Epstein's secret cash 
transactions that were necessary to his sex-trafficking operation escaping knowledge 
of federal investigative and prosecuting agencies. Without JP Morgan's cash, Jane 
Doe 1, as well as other members of the Class, would not have been coercively forced 
to engage in commercial sex act. 
476. As another example of how JP Morgan obstructed, attempted to 
obstruct, interfered with, and prevented the federal government's enforcement of the 
TVPA, JP Morgan failed to timely file with the federal government the required 
SARs that financial institutions must file with FinCEN whenever there is a suspected 
case of money laundering or fraud. Timely filing of these reports is required by the 
Bank Secrecy Act and related laws and regulations. These reports are tools that the 
federal government uses to detect and prosecute, among other illegal activities, sex 
trafficking in violation of the TVPA. By failing to timely file the required SARs 
regarding Epstein's cash transactions, JP Morgan obstructed, attempted to obstruct, 
interfered with, and prevented the federal government's enforcement of the TVPA 
124 
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by concealing from the federal government's attention Epstein's cash transaction in 
aid of sex trafficking. 
477. JP Morgan can disclose its failure to file appropriate SARs without 
disclosing the existence of a SAR. JP Morgan is not protected from liability for 
failure to file a required SAR. 
478. JP Morgan's failure to timely file SARs about Epstein's sex-trafficking 
venture, in spite of numerous red flags, was wrongful and purposeful. 
479. If JP Morgan had filed timely required SARs about Epstein's sex-
trafficking venture with the federal government, the appropriate federal agencies 
would have been well positioned to investigate Epstein's sex-trafficking venture's 
TVPA violations. JP Morgan's failure to timely file the required SARs obstructed 
the federal government's ability to investigate those TVPA violations, including 
violations harming Jane Doe 1 and other Class Members. If JP Morgan had timely 
filed the required SARs, it would have prevented the continuation of Epstein's sex 
trafficking venture, which required the ability to secretly use cash to payoff victims. 
480. By providing large amounts of cash to Epstein and his associates, JP 
Morgan intended and knew that Epstein's coercive commercial sex acts would 
escape the detection of federal law enforcement and prosecuting agencies for some 
period of time. JP Morgan provided large amounts of cash to further the Epstein 
sex-trafficking venture and with the purpose of helping Epstein evade criminal 
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liability for violating the TVPA. 
481. JP Morgan's obstruction, attempted obstruction, interference with, and 
prevention of the enforcement of the TVPA were all done intentionally and 
knowingly. For example, JP Morgan knew that Epstein was high risk—specifically, 
high risk to violate the TVPA through continuing criminal sex trafficking activities. 
482. JP Morgan was well aware that Epstein had pleaded guilty and served 
prison time for engaging in sex with a minor—a crime closely connected with sex 
trafficking in violation of the TVPA. JP Morgan was also well aware that there were 
public allegations that his illegal conduct was facilitated by several named co-
conspirators. But JP Morgan concealed from the federal government its numerous 
cash payments to those co-conspirators. JP Morgan continued its affirmative conduct 
of providing cash to Epstein so that he could make those cash payments to his co-
conspirators with knowledge that such cash transaction did not produce a clear paper 
trail. JP Morgan's intentional conduct obstructed, attempted to obstruct, in many 
ways interfered with, and prevented the enforcement of the TVPA by federal 
investigators and prosecuting agencies. 
483. JP Morgan's relationship with Epstein in providing to his sex-
trafficking venture with vast sums of cash each year went far beyond a normal (and 
lawful) banking relationship. JP Morgan knew, and intended, that its relationship 
with Epstein would go far beyond a normal banking relationship. JP Morgan knew 
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that its decision to beyond a normal banking relationship with Epstein obstructed the 
ability of federal law enforcement and prosecuting agencies to enforce the TVPA. 
484. JP Morgan's obstruction of the federal government's TVPA and other 
law enforcement efforts was intentional and willful and, therefore, JP Morgan 
intentionally and willfully caused Epstein's commission of the forcible commercial 
sex acts with Jane Doe 1 and other Class Members through its obstruction supporting 
the concealment of Epstein's sex-trafficking venture. JP Morgan knew that Epstein 
and his other co-conspirators would use means of force, threats of force fraud, 
coercion, and a combination of such means to cause Jane Doe I and Class Members 
to engage in commercial sex acts. 
485. JP Morgan knew, acted in reckless disregard of the fact, and should 
have known, that its obstruction in violation of 18 U.S.C. § 1591(d) would directly 
and proximately lead to unlawful coercive commercial sex acts by Epstein with 
young women and girls, including Jane Doe 1 and other Class Members. 
486. JP Morgan's obstruction has caused Jane Doe 1 and other Class 
Members serious harm, including, without limitation, physical, psychological, 
financial, and reputational harm. That harm was directly and proximately caused by 
the obstruction and the harm resulting from obstruction was foreseeable. 
487. JP Morgan's obstruction has caused Jane Doe 1 harm that is sufficiently 
serious, under all the surrounding circumstances, to compel a reasonable person of 
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the same background and in the same circumstances to perform or to continue 
performing commercial sexual activity in order to avoid incurring that harm. 
488. This case does not involve mere fraud. Instead, JP Morgan's criminal 
conduct in obstructing enforcement of the TVPA was outrageous and intentional, 
because it was in deliberate furtherance of a widespread and dangerous criminal sex 
trafficking organization. JP Morgan's obstruction 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 obstruction was directed specifically 
at Jane Doe 1 and other members of the Class, who were the victims of Epstein's 
sex trafficking organization. 
489. By virtue of these violations of 18 U.S.C. § 1591(d), JP Morgan is liable 
to Jane Doe 1 and the other Members of the Class for the damages they sustained 
and reasonable attorneys' fees by operation of 18 U.S.C. § 1595. JP Morgan 
perpetrated an obstruction of the TVPA, and therefore perpetrated a violation of 
Chapter 77, Title 18. 
490. By virtue of its intentional and outrageous obstruction to prevent 
enforcement of the TVPA, in violation 18 U.S.C. § 1591(d), JP Morgan is liable to 
Jane Doe 1 and other members of the Class for punitive damages by operation of 18 
U.S.C. § 1595. 
VIII. REQUEST FOR RELIEF 
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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 
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: January 13, 2023 
Respectfully Submitted, 
EDWARDS POTTINGER, LLC 
By: /s/ Bradley Edwards 
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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 130 of 130 
Bradley J. Edwards 
425 N. Andrews Ave., Suite 2 
Fort Lauderdale, FL 33301 
(954)-524-2820 
Fax: (954)-524-2822 
Email: [email protected] 
EDWARDS POTTINGER 
Brittany N. Henderson 
1501 Broadway 
Floor 12 
New York, NY 
(954)-524-2820 
Fax: (954)-524-2820 
Email: [email protected] 
David Boies 
Boies Schiller Flexner LLP 
55 Hudson Yards 
New York, New York 
Telephone: (212) 446-2300 
Facsimile: (212) 446-2350 
E-mail: dboiesabsfllp.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 
Email: [email protected] 
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Exhibit 1 
To Plaintiff, Jane Doe's Amended Complaint 
against JPMorgan Chase Bank, N.A. 
EFTA00162251

Caws61. 221c-1,081193641-9BR Deicorneistrita-0. IRI sm O11/5113/22 
I". :OF' 2 at 3123 
UNITED STATES DISTRICT COURT FOR THE 
SOUTHERN DISTRICT OF NEW YORK 
GOVERNMENT OF THE UNITED 
) 
STATES VIRGIN ISLANDS 
) 
PLAINTIFF, 
V. 
JPMORGAN CHASE BANK, N.A. 
DEFENDANT. 
) 
) 
) 
) 
Case Number: I:22-cv-10904 JSR 
ACTION FOR DAMAGES 
JURY TRIAL DEMANDED 
FIRST AMENDED COMPLAINT AND DEMAND FOR A JURY TRIAL 
Plaintiff Government of the United States Virgin Islands ("Government") files this 
Complaint against JPMorgan Chase Bank, N.A. ("JP Morgan") for violations of Trafficking 
Victims Protection Act, 18 U.S.C. §§ 1591 to 1595, the Virgin Islands Criminally Influenced and 
Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and 
Deceptive Business Practices Act, 12A V.I.C. §§ 301 to 336, and in support thereof alleges as 
follows: 
PARTIES 
I. 
The Attorney General of the United States Virgin Islands (hereinafter "Virgin 
Islands") brings this parens patriae action on behalf of the Plaintiff, Government of the Virgin 
Islands, pursuant to 15 U.S.C. § 1595(d) and 3 V.I.C. § 114 and her statutory authority to enforce 
the laws of the Virgin Islands and protect public safety. 
2. 
The Attorney General, pursuant to her authority to represent the Government of the 
United States Virgin Islands, also acts on behalf of, and with the lawfully delegated authority of, 
the Virgin Islands Department of Licensing and Consumer Affairs under 12 V.I.C. § 327 in regard 
to Count Four of the Government's Complaint alleging violations of the Virgin Islands Consumer 
EFTA00162252

aras 221-kc-1,0211104-9BR D6C111111311rna 
(fl11/513/23 Page 2 at m 3 
Fraud and Deceptive Business Practices Act. 
3. 
This action stems from an enforcement action the Government filed against the 
Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey 
Epstein ("Epstein"), under the Virgin Islands' Criminally Influenced and Corrupt Organizations 
Act ("CICO Act"), see Government of the U.S. Virgin Islands v. Indyke et at, Case No. ST-20-
CV-14 (Super. Ct. V.I. Jan. 15, 2020). The Attorney General brings this action, after presenting 
her findings to JP Morgan in September 2022, in her ongoing effort to protect public safety and to 
hold accountable those who facilitated or participated in, directly or indirectly, the trafficking 
enterprise Epstein helmed. The investigation revealed that JP Morgan knowingly, negligently, and 
unlawfully provided and pulled the levers through which recruiters and victims were paid and was 
indispensable to the operation and concealment of the Epstein trafficking enterprise. Financial 
institutions can connect—or choke—human trafficking networks, and enforcement actions filed 
and injunctive relief obtained by attorneys general are essential to ensure that enterprises like 
Epstein's cannot flourish in the future. 
4. 
Defendant JPMorgan Chase Bank, N.A. is an American multinational investment 
bank and financial services company headquartered in New York City and incorporated in 
Delaware. 
5. 
At all relevant times, JP Morgan engaged in business in the Virgin Islands, 
including, but not limited to, the acts and practices described herein. 
6. 
As described below, based on documents reviewed and interviews conducted by 
the Government, JP Morgan knowingly facilitated, sustained, and concealed the human trafficking 
network operated by Jeffrey Epstein from his home and base in the Virgin Islands, and financially 
benefitted from this participation, directly or indirectly, by failing to comply with federal banking 
2 
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C esi5 d 221c-IGEDEN11-8 BR Deicatmenallei.-Et In kali (111//10/23 Page 3 di an 
regulations, 
JP Morgan facilitated 
and concealed wire and cash transactions that raised suspicion of—and were in fact part of—a 
criminal enterprise whose currency was the sexual servitude of dozens of women and girls in and 
beyond the Virgin Islands. Human trafficking was the principal business of the accounts Epstein 
maintained at JP Morgan. 
7. 
Upon information and belief, JP Morgan turned a blind eye to evidence of human 
trafficking over more than a decade because of Epstein's own financial footprint, and because of 
the deals and clients that Epstein brought and promised to bring to the bank. These decisions were 
advocated and approved at the senior levels of JP Morgan, including by the former chief executive 
of its asset management division and investment bank, whose inappropriate relationship with 
Epstein should have been evident to the bank. Indeed, it was only after Epstein's death that JP 
Morgan belatedly complied with federal banking regulations regarding Epstein's accounts. 
JURISDICTION, VENUE, AND RELATED CASE 
8. 
This action is brought pursuant to and based on federal and Virgin Islands statutes, 
including the federal Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595 ("TVPA"), 
and the federal Bank Secrecy Act, 31 U.S.C. §§ 5311 to 5336 and its implementing regulations 
("BSA"). 
9. 
This Court has federal question subject-matter jurisdiction pursuant to 28 U.S.C. 
§ 1331 because the Government's TVPA and BSA-based causes of action arise under federal law. 
10. 
This Court has supplemental jurisdiction over the Government's Virgin Islands law 
claims pursuant to 28 U.S.C. § 1367(a) because these claims are so related to those arising under 
or based on federal law as to form part of the same case or controversy under Article III of the 
United States Constitution. 
3 
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C easel. 221c-1.02911)4GBR Deicamentit 6.43. IR BS man 
Page SIM3 
11. 
This Court is an "appropriate district court of the United States" in which for the 
Government to obtain appropriate relief under 18 U.S.C. § 1595(d) and venue is proper under 28 
U.S.C. § 1391(6)(2) because Defendant maintains its principal place of business within this 
judicial district, so that this Court may exercise general personal jurisdiction over Defendant, and 
because many of the alleged acts and omissions of Defendant giving rise to the Government's 
claims took place within this judicial district, so that this Court may exercise specific personal 
jurisdiction over Defendant. 
12. 
Pursuant to Local Civil Rule 1.6(a), the undersigned believe that this action is 
related to Doe I v. JP Morgan Chase & Co., No. 1:22-cv-10019 (S.D.N.Y. Nov. 24, 2022), because 
both actions arise from a common nucleus of operative fact involving Defendant JP Morgan's 
alleged participation, directly or indirectly, in Epstein's sex-trafficking venture by facilitating 
payments to women and girls, channeling funds to Epstein to fund the operation, and concealing 
Epstein's criminal conduct by failing to comply with federal banking regulations. 
BACKGROUND 
I. 
JP Morgan's Federal and State Legal Requirements 
13. 
JP Morgan is subject to federal laws, including the BSA and the Uniting and 
Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct 
Terrorism Act of 2001, Pub. L. No. 107-56, 115 Stat. 272 ("USA PATRIOT Act"), which amended 
certain BSA regulations. 
14. 
Under both the BSA and USA PATRIOT Act, JP Morgan is required to implement 
adequate, risk-based anti-money laundering ("AML") policies and systems to detect and prevent 
money laundering or other use of the institution's services to facilitate criminal activities. This 
includes, but is not limited to, maintaining a due diligence program, filing suspicious activity 
4 
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C ease. 221c40.519541-58R Deicainenall 6.$ Plaa/15111//112/23 Page 5 aff 3123 
reports ("SARs") when the financial institutions detect suspicious behavior and currency 
transaction reports ("CTRs") for currency transactions or series of currency transactions that 
exceed $10,000 in a 24-hour period, preventing structuring or assistance with structuring of 
transactions undertaken for the purpose of evading federal reporting requirements, and maintaining 
systems to prevent money laundering. 
15. 
The FDIC and the other federal banking regulators, including the Federal Reserve 
Board and Office of the Comptroller of the Currency, formed an interagency organization known 
as Federal Financial Institutions Examination Council ("FFIEC"). 
16. 
To provide further guidance to banks on what BSA compliance requires, FFIEC 
published a Bank Secrecy Act/Anti-Money Laundering Examination Manual ("BSA Manual"). 
The BSA Manual explains that an effective SAR program is essential: 
Suspicious activity reporting forms the cornerstone of the BSA reporting system. It 
is critical to the United States' ability to utilize financial information to combat 
terrorism, terrorist financing, money laundering and other financial crimes. 
Examiners and banks should recognize that the quality of SAR content is critical to 
the adequacy and effectiveness of the suspicious activity reporting system.' 
17. 
Pursuant to the BSA Manual, "[p]roper monitoring and reporting processes are 
essential to ensuring that the bank has an adequate and effective BSA compliance program. 
Appropriate policies, procedures, and processes should be in place to monitor and identify unusual 
activity."2 When a bank detects suspicious activity, it is required to report that information within 
30 days to the U.S. Department of the Treasury's Financial Crimes Enforcement Network 
("FinCEN"). The reporting requirement ensures that the government is able to monitor and act 
FFIEC Bank Secrecy AcUAnti-Money Laundering Examination Manual, Suspicious Activity 
Reporting at 1 (2014) 
https://bsaaml.ffiec.gov/docs/manual/06_AssessingComplianceWithBSARegulatoryRequirement 
s/04.pdf. 
2 Id. at 2. 
5 
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C eas 22-ZAc-1,021394-9BR D etoraeit011 ELEt SI tail ¢1E1//112/23 Page ET at a.23 
when alerted to potential illegal conduct. 
18. 
Appendix F of the BSA Manual includes examples of suspicious transactions that 
may indicate money laundering, terrorist financing, or fraud, including: 
a. 
Funds transfer activity is unexplained, repetitive, or shows unusual patterns; 
b. 
The currency transaction patterns of a business show a sudden change 
inconsistent with normal activities; 
c. 
Unusual transfers of funds occur among related accounts or among accounts 
that involve the same or related principals; 
d. 
Currency is deposited or withdrawn in amounts just below identification or 
reporting thresholds; 
e. 
Regarding nonprofit or charitable organizations, financial transactions 
occur for which there appears to be no logical economic purpose or in which 
there appears to be no link between the stated activity of the organization 
and the other parties in the transaction; 
f. 
Funds are sent or received via international transfers from or to higher-risk 
locations. 
19. 
In addition, the CICO Act, 14 V.I.C. § 600, incorporates violations of Virgin Islands 
Law and federal felonies, which includes the BSA's criminal-liability provisions. 
II. 
Jeffrey Epstein's Criminal Conduct 
20. 
Jeffrey Epstein was a resident of the Virgin Islands. 
21. 
In 2008, Epstein pled guilty to one count of solicitation of prostitution with a minor 
in Palm Beach, Florida. As a result of that conviction, Epstein was forced to register as a sex 
offender in the Virgin Islands. 
6 
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C easel. 221c- 1.021341841GBR DDziornettall 6.-a IFIS/103//112/23 Paw -Bat m 3 
22. 
Epstein was a Tier 1 offender under Virgin Islands law based upon his Florida 
conviction of procuring a minor for prostitution. 
23. 
On January 15, 2020, the Government filed a lawsuit against Jeffrey Epstein's 
estate and related individuals and entities for violation of the CICO Act, 14 V.I.C. §§ 600 to 614, 
and civil conspiracy, which the Government recently settled. As laid out in the Government's 
Second Amended Complaint, ST-20-CV-14, ("SAC") (attached as Exhibit I), Epstein created a 
network of companies and individuals who participated in, directly or indirectly, and conspired with 
him in a pattern of criminal activity related to the sex trafficking, forced labor, sexual assault, child 
abuse, and sexual servitude of these young women and children. SAC
 43-75. Epstein and his 
associates trafficked underage girls to the Virgin Islands, held them captive, and sexually abused 
them, causing them grave physical, mental, and emotional injury. Id. 
24. 
To accomplish this criminal activity, Epstein formed an association in fact with 
both companies and non-profit organizations that he owned and operated, as well as individuals, 
who were willing to participate in, directly or indirectly, facilitate, and conceal Epstein's criminal 
activity in exchange for Epstein's bestowal of financial and other benefits, including sexual 
services and forced labor from victims. Id.11 at 157-195. 
25. 
In October 2012, the Southern Trust Company—one of the companies Epstein 
owned—applied for economic benefits from the Virgin Islands Economic Development 
Commission ("EDC") so the company could provide "cutting edge consulting services" in the area 
of "biomedical and financial informatics." Id.
 157-158. Southern Trust Company received a 10-
year package of economic incentives running from February 1, 2013 until January 31, 2023 that 
included a 90% exemption from income taxes and 100% exemptions from gross receipts, excise, 
and withholding taxes in the Virgin Islands. Id.1 159. 
7 
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C Oas 221c40.6I911)4-3BR D eictouretErit EL-EL FHISI1M/filf3/23 Page 8 aff 
26. 
Southern Trust, in fact, appeared to perform no informatics or data-mining services 
during this period. Instead, Southern Trust funded the Epstein Enterprise (defined below), acting as 
a conduit for payment to foreign women, credit cards, airplanes and other instrumentalities. Id. 
11 167-173. 
27. 
This illicit association of Epstein, businesses, and his associates constitutes what is 
referred to herein as the "Epstein Enterprise." Specifically included in the Epstein Enterprise were 
the following companies and non-profit organizations, all of which had accounts with JP Morgan: 
2013 Butterfly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, 
Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, 
LLC, NES, LLC, Plan D, LLC, Southern Financial, LLC, and Southern Trust Company. 
28. 
Epstein used his wealth and power to create the Epstein Enterprise, which engaged 
in a pattern of criminal activity by repeatedly procuring and subjecting underage girls and young 
women to unlawful sexual conduct, sex trafficking, and forced labor. 
29. 
Many of these women, particularly after Epstein's conviction in 2008, were 
trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, 
these women were recruited and, in several instances, required to marry other Epstein victims in 
order to maintain their immigration status and their availability to Epstein. Id. f[ 62- 63, 78, 86. 
30. 
As also alleged in the Second Amended Complaint, recruiters and victims were paid 
in cash or through entities set up by Epstein and/or his associates. Id.91100. Many of these companies 
were shell companies, that existed merely to transfer money to other accounts, or to shelter Epstein's 
assets from judgment. Id. ¶ 116. 
31. 
Epstein's lawyer, Darren K. Indyke, and accountant, Richard Kahn, now the Co-
Executors of Epstein's Estate, authorized or directed many of the transactions in JP Morgan accounts 
8 
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C rsese 2222veLOSASIEFDdilaciane0616 Fled 01/1803 Page 10:C33123 
held by Epstein or related entities. hill 8-10, 76-117. 
32. 
Epstein and the Epstein Enterprise continued trafficking and sexually abusing 
young women and female children until Epstein was arrested by federal law enforcement 
authorities on July 6, 2019 on federal charges for the sex trafficking of minors. 
33. 
Epstein was found dead on August 10, 2019 while in custody in a federal detention 
center in New York on charges for sex-trafficking crimes. Id. 17. 
ALLEGATIONS 
I. 
Jeffrey Epstein Was an Extremely High-Risk Customer 
34. 
Jeffrey Epstein's reputation as a sex trafficker and abuser of women and girls was 
well-known and well-publicized for more than a decade before his death. 
35. 
Between 2005 and 2013, there were numerous press reports that Epstein sexually 
abused women and girls. 
36. 
In March 2005, there were press reports that Epstein paid a 14-year old girl in Palm 
Beach, Florida for a "massage" and then molested her. Following these allegations, multiple 
underage girls, many of them high school students, told police that Epstein also hired them to give 
sexual massages. 
37. 
Throughout 2006—when Epstein was arrested in Palm Beach, Florida for 
solicitation of a minor—there was extensive press regarding the nature and extent of Epstein's 
sexual offenses, including the existence of dozens of victims. 
38. 
In 2008, Epstein pled guilty to sexual offenses in Palm Beach, Florida, including 
solicitating a minor for prostitution. Epstein was sentenced to 18 months in jail and was required 
to register as a sex offender. 
39. 
In 2009, the non-prosecution agreement between Epstein and the United States 
9 
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