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UNITED STATES DISTRICT COURT FOR THE 
SOUTHERN DISTRICT OF NEW YORK 
Jane Doe 1, individually and on 
) 
behalf of all others similarly 
) 
situated 
) 
) 
Plaintiffs, 
) 
) 
) 
v. 
) 
) 
JP Morgan Chase Bank, N.A., 
) 
) 
Defendant. 
) 
CLASS ACTION COMPLAINT 
JURY TRIAL DEMANDED 
Case No.: 22-cv-10019-JSR 
FIRST AMENDED INDIVIDUAL AND CLASS ACTION COMPLAINT 
Plaintiff Jane Doe 1 files this first amended individual and civil class action 
complaint for damages and other relief under (among other provisions of law) the 
United States federal anti-sex trafficking statute, 18 U.S.C. § 1591, et seq.—the 
Trafficking Victim Protection Act ("TVPA")—and for aiding and abetting, 
intentional infliction of emotional distress, and negligence related to sexual offenses 
as defined in article one hundred thirty of the penal law, pursuant to the New York 
Adult Survivors Act, N.Y. CPLR §214-j. The suit arises from Defendant JP Morgan 
Chase Bank, N.A.'s (hereinafter "JP Morgan") participation and intentional 
involvement in Jeffrey Epstein's widespread and well-publicized sex-trafficking 
operation, as well as the direct financial benefits it received therefrom. 
JP Morgan knew that it was providing the financial lifeblood for Epstein's 
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international sex-trafficking organization from 1998 through August 2013. In 
exchange for that crucial financial support, JP Morgan knowingly and intentionally 
benefited and received things of value from Epstein and his sex-trafficking 
operation. And that crucial financial support allowed Epstein to successfully rape, 
sexually assault, and coercively sex traffic Jane Doe 1 and the numerous other 
members of the Class proposed below (the "Class"). JP Morgan knew that Epstein 
was regularly committing violations of New York Penal Law Art. 130, including, 
and especially, New York Penal Law §§ 130.20, 130.35, 130.50, 130.52, and 130.66, 
and acted to enable, aid and abet, and facilitate Epstein's commission of such 
offenses against countless young women, including Jane Doe 1 and Class Members. 
JP Morgan also knew that Epstein would use means of force, threats of force, 
fraud, abuse of legal process, exploitation of power disparity, and a variety of other 
forms of coercion to cause young women and girls to engage in commercial sex acts. 
Knowing that it would earn millions of dollars in exchange for facilitating Epstein's 
sex abuse and trafficking, JP Morgan chose profits over following the law. 
Specifically, JP Morgan chose participating in and facilitating Epstein's sex-
trafficking conspiracy for many years, including through the criminal investigation 
and incarceration of Jeffrey Epstein, in order to churn profits. 
Jane Doe 1 makes the following allegations on information and belief and 
believes that substantial additional evidentiary support will exist for the allegations 
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set forth herein after a reasonable opportunity for discovery: 
I. JURISDICTION, VENUE, AND TIMELINESS 
1. 
This action is brought pursuant to various federal and state statues, 
including the federal TWA, 18 U.S.C. § 1589 through § 1595. This Court has 
federal question subject-matter jurisdiction pursuant to 28 U.S.C. §1331, because 
Jane Doe 1—individually and on behalf of the other Class members—proceeds 
under the federal TVPA statute. 
2. 
This Court also has supplemental jurisdiction over the state law claims 
recounted below pursuant to 28 U.S.C. § 1367(a), because all claims alleged herein 
are part of a uniform pattern and practice and form part of the same case or 
controversy. 
3. 
This Court is "an appropriate district court of the United States" in 
accordance with 18 U.S.C. § 1595, in which to bring this action. Venue is proper in 
this District under 28 U.S.C. § 1391(b)(2), because Epstein, his co-conspirators, and 
JP Morgan all conducted substantial activities in this District and knowingly aided 
and abetted, facilitated, and directly participated in Epstein's illegal venture through 
actions that originated in this District. In addition, Epstein sexually abused and 
trafficked Jane Doe 1 and members of the Class is this District. 
4. 
Often these acts of sexual abuse and commercial sex acts, committed 
by Jeffrey Epstein and certain select friends of his, took place in Jeffrey Epstein's 
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New York mansion, located within this District at 9 East 71st Street in New York 
City. Epstein also used his New York mansion to harbor his victims and as a base 
from which to transport them to other locations outside of New York. 
5. 
A substantial part of the acts, events, and omissions giving rise to this 
cause of action occurred in this District. 
6. 
This action has been timely filed pursuant to 18 U.S.C. § 1595(c)(1), 
which provides that a plaintiff shall have ten years after the cause of action arose to 
file suit against any person who knowingly benefits, financially or by receiving 
anything of value from participation in a venture which that person knew or should 
have known violated the laws against sex trafficking. This action is also timely 
because the conspiracy continued until recently. This action is also timely under 
New York's Adult Survivor's Act, N.Y. CPLR § 214-j. 
II. PARTIES 
7. 
Jane Doe 1 is a U.S. citizen and was at all relevant times a resident of 
and domiciled in the State of New York. 
8. 
Plaintiff Jane Doe 1 is using a pseudonym to protect her identity 
because of the sensitive and highly personal nature of this matter, which involves 
sexual assault. 
9. 
Jane Doe 1 is also at serious risk of retaliatory harm because the co-
conspirators who participated in the Epstein sex-trafficking venture had—and 
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continue to possess—tremendous wealth and power and have demonstrated a clear 
ability to cause her serious harm. 
10. 
Jane Doe l's safety, right to privacy, and security outweigh the public 
interest in her identification. 
11. 
Jane Doe l's legitimate concerns outweigh any prejudice to Defendant 
by allowing her to proceed anonymously. 
12. 
As discussed below, many other women are similarly situated to Jane 
Doe 1 and also need to proceed anonymously for the same reasons. The identities of 
most of these other women are known to Defendant. 
13. 
Defendant HI Morgan is a global financial institution headquartered in 
New York, New York. 
14. 
Defendant JP Morgan is licensed by the New York State Department 
of Financial Services to operate a foreign bank branch in the State of New York. 
15. 
Defendant JP Morgan currently conducts substantial business in this 
District and conducted substantial business at the time of events covered in this 
complaint. 
16. 
As one example of business conducted in this District, JP Morgan 
ordinarily trades shares on the New York Stock Exchange, located in this District. 
As another example, JP Morgan maintains branch banks within this District. 
17. 
JP Morgan's financial activities, including the events alleged herein, 
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were in and affecting interstate and foreign commerce. In connection with the acts 
alleged in this complaint, Defendant, directly or indirectly, used the means and 
instrumentalities of interstate commerce, including, but not limited to, the mails, 
interstate telephone communications, and the facilities of national securities 
markets. 
18. 
JP Morgan is responsible, under United States law and otherwise, for 
the acts of its officers, directors, employees, and agents, including the acts described 
in this complaint. The acts alleged were committed by JP Morgan's officers, 
directors, employees, and agents were within actual and apparent scope of their 
employment and with the intention, at least in part, to benefit JP Morgan. 
III. INTRODUCTION 
19. 
Jeffrey Epstein's sex-trafficking venture operated in many respects as 
a sex-themed cult designed to ensnare vulnerable young women and indoctrinate 
them into Epstein's carefully constructed world in which Epstein was their messiah. 
Epstein and his co-conspirators preached the gospel of Epstein. Epstein's victims 
were taught to do what he said, and he would protect them; but disobey him, and he 
would punish them; and continue to disobey, and he would cause them serious harm 
from which they could never recover. 
20. 
Once in Epstein's clutches, each victim was taught and understood that 
she must be completely compliant with every demand Epstein had for her; otherwise, 
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she would certainly suffer serious reputational, financial, and psychological harm. 
By using these and other means of force, threats of force, fraud, threats of abuse of 
the legal process and coercion, Epstein and his co-conspirators sexually trafficked 
and sexually abused Jane Doe 1 and the other members of the Class. 
21. 
The Epstein sex-trafficking venture originated in the early 1990's. 
From its inception until Jeffrey Epstein's arrest by the FBI for sex trafficking in 2019 
(and his subsequent death on August 10, 2019, by apparent suicide), the venture 
operated primarily for the purpose of luring young women and girls into a position 
where Jeffrey Epstein and his co-conspirators could coerce them to engage in 
commercial sex acts and commit sexual offenses against them. His venture also 
operated to conceal its sex trafficking from law enforcement organizations. And his 
venture provided financial and other benefits to those who assisted and enabled the 
venture. 
22. 
The Epstein sex-trafficking venture was well-structured from the 
beginning and grew increasingly more complex and powerful as it victimized more 
young women and as its relationship with Defendant JP Morgan grew. 
23. 
Epstein could not and did not act alone. He created and maintained his 
sex-trafficking venture with the assistance of other influential individuals and 
entities who knew he was sexually abusing and sexually trafficking young women 
and girls and provided support to facilitate his sexual abuse and sex trafficking 
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operation. 
24. 
Epstein's sex-trafficking venture was not possible without the 
assistance and complicity of a financial institution—specifically, a banking 
institution—which provided special treatment to Jeffrey Epstein and the sex-
trafficking venture, thereby ensuring its continued operation and sexual abuse and 
sex-trafficking of young women and girls. Without the financial institution's 
participation, Epstein's sex trafficking scheme could not have existed and flourished. 
25. 
Epstein's victims were young women and girls, who suffered severe 
abuse as Epstein's sex-trafficking victims and who believed they had to remain loyal 
to the venture at all costs to survive. Epstein victimized hundreds of young women 
and girls with the assistance of a wide network of co-conspirators, including JP 
Morgan. 
26. 
Epstein's sexual abuse and sex trafficking scheme was supported by 
virtually unlimited wealth, derived from select wealthy individuals who acted as the 
financial engine behind the sex-trafficking operation, in exchange for sexual and 
other benefits. 
27. 
Epstein masterfully assessed the specific needs and vulnerability of 
each of his targeted victims. He then closed the trap on his victims with offers of 
money, food, shelter, medical care for them or family members, travel, schooling, 
and career opportunities. 
Epstein groomed the young women and girls, 
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indoctrinating them to believe that the sexual abuse was normal. 
28. 
Epstein fraudulently represented to the victims that he would take care 
of them in various ways, which ultimately allowed Epstein to cause them to engage 
in commercial sex acts with himself and, on occasion, select others, as well as to 
create the opportunity for Epstein to sexually abuse them. 
29. 
The Epstein sex-trafficking venture's purpose included enticing, 
obtaining, harboring, and transporting the young victims without drawing unwanted 
attention from law enforcement. The venture had everything a sex-trafficking 
organization needed—funding, infrastructure, the appearance of legitimacy, and a 
complicit banking institution. It was by many accounts the most powerful and 
wealthiest sex-trafficking venture ever created. 
30. 
The Epstein sex-trafficking venture knowingly used means of force, 
threats of force, fraud, coercion (including threats of serious harm or physical 
restraint), and abuse of law and the legal process, to cause Jane Doe 1, and many 
dozens of others similarly situated women to engage in commercial sex acts. 
31. 
The Epstein sex-trafficking venture operated in and affected interstate 
and foreign commerce. Epstein recruited, solicited, coerced, harbored, transported, 
and enticed some of his victims, including Jane Doe 1 and others similarly situated, 
to engage in commercial sex acts in, among other places, New York (including the 
Southern District of New York), Florida, the U.S. Virgin Islands, New Mexico, 
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England, and France. 
32. 
The Epstein sex-trafficking venture operated throughout the world from 
in and around (at least) 1998 through (at least) in and around August 10, 2019, when 
Epstein died by apparent suicide. Thereafter, through at least July 2020, to and 
including the date of this complaint, members of the sex-trafficking venture 
continued to further the venture by concealing the activities and extent of the 
venture. 
33. 
The manner of operation for Epstein's particular sexual abuse and sex 
trafficking operation was widely publicized. He would lure young girls or women 
to one of his luxurious mansions, under the guise of being a wealthy philanthropist, 
able to advance careers, education, or provide other life necessities, and once inside 
he would force his would-be victim into providing a massage that would turn sexual, 
and from there he would cause each of his unsuspecting victims to engage in a 
variety of commercial sex acts. 
34. 
Once in his presence, each victim knew it was no option to disobey 
Epstein. It was well known and understood that he was one of the most powerful 
and connected people in the United States, able to help any of these young victims 
and capable and willing to seriously harm any of his victims. 
35. 
While Epstein's abuse began in the early 1990s with the use of his 
paramour turned madame, Ghislaine Maxwell ("Maxwell"), Epstein's appetite for 
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sexually abusing young women and girls grew over the years. 
36. 
By (at least) 1998, Epstein's sex trafficking venture had crystalized into 
criminal conspiracy. By 1998, each victim was being directed to recruit other 
vulnerable victims and being paid handsomely, typically in cash, for each 
recruitment, creating a pyramid scheme of abuse. 
37. 
A Florida criminal investigation uncovered that the number of victims 
of Epstein's sex-trafficking conspiracy grew exponentially in and around the early 
2000s. 
38. 
While Epstein did pay victims and his many co-conspirators using wire 
transfers and checks, because there were hundreds of victims, Epstein could not pay 
all of his victims with traceable wires. 
39. 
One primary reason why Epstein's sex-trafficking venture and 
conspiracy accumulated new victims at an alarming rate in the late 1990s and 
accelerated even faster by 2000 was Epstein's access to unlimited amounts of cash 
and his knowledge that he had a complicit bank—JP Morgan—through which he 
could operate his illegal abuse organization without fear of being reported to law 
enforcement. 
40. 
Without exorbitantly large amounts of cash, Epstein's operation could 
not effectively operate, as newly recruited victims were each paid hundreds of 
dollars in cash immediately after Epstein sexually abused them, as hush money. 
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41. 
Each victim was also informed that she would be paid hundreds of 
dollars in cash for each additional victim she recruited, and Epstein made good on 
those promises of large cash payments to keep his victims quiet and complicit. 
42. 
The public documents and articles stemming from the 2006 arrest made 
abundantly clear that Epstein was doling out thousands of dollars in cash every 
single day as hush money to victims he was sexually abusing and to victims he was 
using to recruit additional victims. 
43. 
If Epstein paid every victim with wire transfers or checks and left a 
documented money trail, his illegal sexual abuse and sex trafficking operation would 
have been easily uncovered; however, with access to unlimited amounts of cash, 
Epstein was able to commit the most egregious sexual crimes many times a day 
without leaving a paper trail. 
44. 
Accordingly, Epstein's constant expansion of sexual abuse and 
trafficking required cash on hand for Epstein to pay each victim as hush money for 
the abuse she was suffering as well as each victim's finder's fee for bringing another 
victim. 
45. 
To access the large amount of cash needed to maintain his active sexual 
abuse of young women, it was essential that the financial institution where he banked 
be complicit in his operation, and more specifically that Epstein bank at a financial 
institution that would allow him to constantly withdraw cash from his accounts 
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without following anti-money laundering and reporting laws. 
46. 
To put it plainly, Epstein needed a bank that knew he was engaging in 
illegal activity and did not care, which Epstein had in JP Morgan. 
47. 
This scheme of paying victims to recruit other victims worked 
effectively for Epstein. It not only allowed expansion through the recruitment of 
other victims in a pyramid scheme or spiderweb fashion, but it also gave each victim 
hope that she could avoid future sexual abuse—she could bring someone else who 
would get abused in her place. 
48. 
Epstein's aptitude as a sex-trafficker and appetite as a sexual abuser did 
not suffer because of his Florida incarceration in 2008. Even while he was in jail in 
Florida, Epstein brazenly continued to sexually abuse young girls and women from 
his work-release office. 
49. 
Once out of jail and off work release, Epstein continued to collect 
young women and lure them through force, fraud, or coercion into one of his 
mansions, primarily his townhouse located at 9 East 71 Street, New York, NY, 
where he would sexually abuse each one. 
50. 
Epstein's sexual abuse and sex-trafficking operation continued as it had 
in the past, although it became more elaborate, creating more phony companies, 
opening more bank accounts, withdrawing excessive amounts of cash, and 
delivering money to victims through wires, payroll, direct deposits, and other means 
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known to his financial institution as evidence of the continuation of his criminal sex 
trafficking scheme. 
51. 
As time went by, especially after Epstein's Florida arrest, the news 
articles and lawsuits about his activities continued to mount. More information 
became publicly available that Epstein was continuing to abuse young women and 
was using professionals on his payroll to help him conceal his illegal activity and 
give him ostensible cover as a purported well-connected money manager. 
52. 
As a registered sex offender discovered to be sexually abusing multiple 
young women each day through a pyramid-type recruiting scheme that required the 
transfer of millions of dollars to continue the operation, a complicit bank became 
more important than ever. 
53. 
As further detailed below, JP Morgan worked closely with Epstein 
through every step of the sex trafficking operation's expansion and growth in some 
of its most prolific of years—between around 1998 through 2013. 
IV. THE TRAFFICKING VICTIMS PROTECTION ACT 
54. 
The Trafficking Victims Protection Act (TVPA) outlaws sex trafficking 
activities that affect interstate or foreign commerce or take place within the territorial 
jurisdiction of the United States. It is to be construed broadly because it serves a 
remedial purpose and uses intentionally broad language. 
55. 
The TVPA forbids, among other things, the following sex-trafficking 
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conduct: 
(a) Whoever knowingly—
(1) in or affecting interstate or foreign commerce, or within 
the special maritime and territorial jurisdiction of the 
United States recruits, entices, harbors, transports, 
provides, obtains, advertises, maintains, patronizes, or 
solicits by any means a person; or 
(2) benefits, financially or by receiving anything of value, 
from participation in a venture which has engaged in an 
act described in violation of paragraph (1), 
knowing, or, except where the act constituting the violation of 
paragraph is advertising, in reckless disregard of the fact, that means of 
force, threats of force, fraud, coercion described in subsection (e)(2), or 
any combination of such means will be used to cause the person to 
engage in a commercial sex act, or that the person has not attained the 
age of 18 years and will be caused to engage in a commercial sex act, 
shall be punished as provided in subsection (b). 
18 U.S.C. § 1591(a). 
56. 
The TVPA also forbids (among other things) conspiring to violate 18 
U.S.C. § 1591. 18 U.S.C. § 1594(c). 
57. 
The TVPA also contains an explicit "civil remedy" provision which 
allows an individual who is a victim of a violation of Chapter 77 of Title 18 (e.g., 
violation of 18 U.S.C. §§ 1591-94) to bring a civil action against the perpetrator and 
any person or entity who knowingly benefits, financially or by receiving anything of 
value from participation in an illegal sex-trafficking venture. 18 U.S.C. § 1595(a). 
58. 
Unlike the criminal penalties provisions in the TVPA, the civil 
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remedies provision contains a "constructive knowledge" provision. This provision 
allows a civil action to be brought not only against a person or entity who 
participated in a venture known to have engaged in illegal sex trafficking but also 
against a person or entity who participated in a venture that the person or entity 
should have known had engaged in illegal sex trafficking. 18 U.S.C. § 1595(a). This 
expansive provision is known as the "constructive knowledge" provision, which 
provides an alternative to proving actual knowledge as part of civil damages claim. 
59. 
In the paragraphs that follow, wherever Jane Doe 1 alleges that 
Defendant acted with actual knowledge, or in reckless disregard of the fact, that the 
Epstein sex-trafficking venture used means of force, threats of force, fraud, coercion, 
abuse of process, or some combination thereof to cause a person to engage in 
commercial sex acts, the Plaintiff also allege that, at a bare minimum, Defendant 
should have known that the Epstein sex-trafficking venture had used such means to 
engage in illegal sex trafficking in violation of 18 U.S.C. §§ 1591-94—Le., that they 
had constructive knowledge of Epstein's sex trafficking. 
60. 
In this complaint, Jane Doe 1 and other members of the Class also 
allege that JP Morgan was willfully blind to the fact that was facilitating and 
participating in Epstein's sex-trafficking venture. 
V. FACTUAL ALLEGATIONS 
A. 
The Epstein Sex-Trafficking Venture and Conspiracy 
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61. 
During all times relevant to this complaint, Jeffrey Epstein was an 
extraordinarily wealthy man with multiple residences in the United States, including 
a New York City mansion, a Palm Beach mansion, and an island in the U.S. Virgin 
Islands. 
62. 
Beginning in and around 1998 and continuing through the summer of 
2019, Jeffrey Epstein knowingly established and ran a sex-trafficking venture and 
conspiracy in violation of 18 U.S.C. §§ 1591-95. As part of the venture, Epstein 
used means of force, threats of force, fraud, coercion, abuse of legal process, and a 
combination of these means to cause young women and girls from all over the world 
to engage in commercial sex acts and to sexually abuse them. Epstein and others 
also conspired to violate 18 U.S.C. § 1591. 
63. 
In creating and maintaining this network of victims in multiple states 
and in other countries to sexually abuse and exploit, Epstein worked and conspired 
with others, including employees and associates who facilitated his conduct by, 
among other things, recruiting victims, coercing victims, and scheduling their sexual 
abuse by Epstein at his New York mansion, his Palm Beach mansion, and his island 
in the U.S. Virgin Islands. 
64. 
Epstein and his co-conspirators used Epstein's vast (yet mysterious) 
wealth and connections to other rich and powerful individuals to lure victims into 
his home for seemingly innocuous activity. Victims were initially recruited to speak 
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with an allegedly philanthropic Epstein and provide "massages" to him. 
65. 
Epstein and his co-conspirators had perfected a scheme for 
manipulation and abuse of young females. As part of the scheme, a female 
"recruiter" would approach a young female and strike up a conversation in an effort 
to quickly learn about the young female's background and any vulnerabilities they 
could expose. The recruiter would then manipulate the young female into coming 
back to one of Epstein's residences by offering the young female something she 
needed. At times, the recruiter's lure would be a modeling opportunity, money for 
education, help for the young female's family, and a whole host of other related 
offers depending on their target's situation. Once in the residence, the recruiter and 
Epstein would work in concert to impress and intimidate the young female with 
displays of vast wealth, including having employees that were butlers and maids 
formally dressed around the house. They would also strategically place photographs 
of very powerful political and social figures amongst photographs and art displaying 
nude females in an effort to normalize the sexual abuse. They would normalize the 
sexual abuse by placing a massage table and spa related products around the massage 
area in an effort to legitimize the area where the abuse was set to occur. Once 
abused, Epstein and his co-conspirators continued to manipulate the victims, using 
their financial power, promises, and threats to ensure that the victim returned as 
directed and remained compliant with their demands. 
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66. 
Once at the home and trapped in Epstein's bedroom the victims would 
be instructed to remove their clothing. Epstein would then force the massages to 
become increasingly sexual in nature, typically including one or more forced sex 
acts. Epstein would use means of force, threats of force, or fraud to coerce the 
victims to participate in these sex acts and to cause them to return and continue to 
engage in commercial sex acts with him. Epstein and his associates then paid his 
victims hundreds of dollars in cash for each sexual encounter. 
67. 
In this District and elsewhere, Epstein perpetuated this pattern of abuse 
in similar ways, hundreds of times. 
68. 
Moreover, Epstein actively encouraged and coerced his victims to 
become recruiters themselves, forcing them to recruit additional girls to be similarly 
sexually abused and causing the number of victims to grow exponentially. Epstein 
incentivized his victims to become recruiters by paying these victim-recruiters 
hundreds of dollars for each girl that they brought to Epstein. In so doing, Epstein, 
through this system of paying victims to recruit others whom he would in turn pay 
to recruit others, created a sexual abuse and sex trafficking spider web and 
maintained a steady supply of new victims to exploit. 
69. 
Epstein was skilled at ascertaining his victim's greatest fears and 
aspirations and targeted those fears and aspirations to coerce and trap his victims 
into performing commercial sex acts and to be subject to sexual abuse. 
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70. 
Among other things, Epstein sexually abused his many victims and 
caused his victims to engage in commercial sex acts, specifically sex acts for which 
his victims received things of value, including money, promises of educational and 
career advancement, a place to live, and promises that Epstein would provide various 
forms of assistance. 
71. 
Epstein provided things of value to his victims in order to coerce them 
to engage sex acts with him and on occasion his friends, co-conspirators, or other 
victims. 
72. 
As one means of coercing victims to engage in commercial sex acts, 
Epstein and his co-conspirators threatened that harm would come to victims if they 
did not comply with his demands that they perform commercial sex acts. 
73. 
As another means of coercing victims to engage in commercial sex acts, 
Epstein and his co-conspirators fraudulently promised to further victims' 
educational or career aspirations if they would comply with his sexual demands. 
These promises were a quid pro quo for the sex acts that occurred. 
74. 
As one means of coercing victims to engage in commercial sex acts, 
Epstein and his co-conspirators would give his victims money to stay quiet about the 
assault or as a "finder's fee" for bringing other young women. Epstein would also 
provide them with living accommodations, clothing, education, or other necessities, 
exploiting the vulnerabilities of his often poor and underprivileged victims. 
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