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75. 
In addition to coercing commercial sex acts from his victims, Epstein 
also committed coercive sexual offenses against them as defined in New York Penal 
Law § 130, as described in greater detail below. 
76. 
Throughout around 1998 through about July 2019, the Epstein's sex-
trafficking venture recruited, solicited, enticed, harbored, obtained, provided, and 
transported hundreds of victims to cause them to engage in commercial sex acts with 
Epstein and Epstein's friends. 
77. 
At all relevant times, Epstein maintained numerous apartment units at 
301 East 66th Street in New York City, where Epstein's co-conspirators often stayed 
and which operated as stash houses where numerous victims were kept over the 
years. 
78. 
JP Morgan knew of the 301 East 66th Street Epstein properties and knew 
that these units operated as victim stash houses. 
79. 
In 2006, Jeffrey Epstein was arrested in Florida after state and federal 
law enforcement discovered that he had sexually abused more than 30 children in 
his Palm Beach, Florida mansion. During that investigation, the government 
concluded that Epstein and his co-conspirators had committed federal criminal acts 
constituting violations of the TVPA and other federal laws, including 18 U.S.0 §§ 
2422(b), 2423(0, 2423(b), 2424 (e); 18 U.S.0 § 371; 18 U.S.0 §§ 1591(c)(1), 
1591(a)(1), 1591(a)(2); as well as state crimes in violation of Florida Statutes §§ 
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796.07 and 796.03, against dozens of young women. 
80. 
As a consequence of the Florida investigation, Epstein pled guilty to 
two felonies, was permanently labeled a "Registered Sex Offender," and was jailed 
in 2008. Epstein also entered into a non-prosecution agreement with the U.S. 
Attorney's Office for the Southern District of Florida barring his prosecution (and 
prosecution of his known and unknown co-conspirators) for violations of the TVPA 
and other sex offenses in Florida. When the U.S. Attorney's Office entered into that 
non-prosecution agreement with Epstein, it had not received reports from JP Morgan 
about vast sums of cash that it was providing Epstein. Nor did JP Morgan provide 
any other assistance in the investigation. 
81. 
Epstein's criminal case in Florida and the many related news reports 
left no doubt about Jeffrey Epstein and his extraordinary penchant for sex abuse and 
trafficking of young females. For instance, it was reported that up until the time of 
his Florida arrest in July 2006, Epstein had been sexually abusing during that year 
and the previous year three to four young females per day; it was a full-time job for 
him. 
82. 
Beginning with his 2006 Florida arrest and for years moving forward, 
Epstein was embroiled in dozens of public lawsuits detailing his sexual abuse of 
females, and thousands of news stories circulated worldwide about his illegal sexual 
proclivities. 
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83. 
Epstein paid millions of dollars to settle sexual abuse lawsuits filed 
against him by many victims. The money used to make settlement payments was 
paid from Epstein-related entity accounts at JP Morgan. And while he was paying 
to settle these claims, Epstein was continuing to abuse new victims—all facts known 
to JP Morgan. 
84. 
In addition to the many civil lawsuits seeking damages for sexual abuse, 
Epstein's victims also filed a public lawsuit against the Unites States under 18 U.S.C. 
§ 3771, the Crime Victim's Rights Act ("CVRA"), further exposing Epstein's sexual 
crimes as well as his secret Non-Prosecution Agreement with the Federal 
Government. 
85. 
Epstein recruited, solicited, enticed, harbored, obtained, provided, and 
transported his victims to cause them to engage in commercial sex acts in ways that 
were in and affecting interstate and foreign commerce, including using means of 
interstate communications (such as cell phones) and means of interstate and foreign 
travel (such as aircraft that he owned and controlled). 
86. 
Epstein transported his victims in interstate and foreign commerce, 
including transportation to and from his mansion in this District. 
87. 
The Epstein sex-trafficking venture transported victims across state 
boundaries between New York, Florida, New Mexico, New Jersey, Massachusetts, 
the U.S. Virgin Islands, and elsewhere, and in foreign commerce between the United 
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States and Europe, especially Eastern Europe. 
88. 
At all times relevant to this complaint, the Epstein sex-trafficking 
venture was a group of two or more individuals associated in fact, even if they were 
not a formal legal entity. Indeed, members of the Epstein sex-trafficking venture 
referred to it as "The Organization." Epstein was continuously at the hub of The 
Organization, which operated throughout the times indicated in this complaint. 
89. 
On July 2, 2019, the United States Attorney's Office for the Southern 
District of New York filed a sealed, two-count Indictment against Epstein, including 
one count of sex trafficking conspiracy and one count of sex trafficking for violations 
of 18 U.S.C. § 1591, in part due to Epstein's criminal activities in his New York 
Mansion located at 9 East 71st Street. See United States v. Jeffrey Epstein, Case No. 
1:19-cr-00490 (S.D.N.Y.). 
90. 
On July 8, 2019, Epstein was arrested pursuant to the New York 
Indictment. 
91. 
On August 10, 2019, prison guards found Epstein unresponsive in his 
Metropolitan Correctional Center jail cell, where was awaiting trial on the federal 
sex trafficking charges. He was later pronounced dead from apparent suicide. 
92. 
In July 2020, Epstein's co-conspirator in the sex-trafficking venture, 
Maxwell, was arrested on federal sex-trafficking charges filed in the Southern 
District of New York. The charges alleged that she had assisted, facilitated, and 
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contributed to Epstein's abuse of sex-trafficking victims, helping Epstein to recruit, 
groom, and ultimately abuse his victims. See United States v. Maxwell, Case No. 
1:20-cr-00330 (S.D.N.Y.). 
93. 
On December 29, 2021, after a weeks-long jury trial during which 
witnesses testified about Epstein's sex-trafficking operation in painstaking detail, 
Maxwell was found guilty on five federal sex-trafficking counts and is now serving 
nearly 20 years in federal prison for these crimes. 
B. 
Consistent With Jeffrey Epstein's Uniform Pattern and Practice, Jane 
Doe 1 Was Forced to Engage in Commercial Sex Acts with Epstein by 
Means of Force, Fraud, and Coercion. 
94. 
Jane Doe I was living with her mother when she met Jeffrey Epstein in 
2006. 
95. 
At that time, Jane Doe I was a ballet dancer in New York. Another 
young female who had also fallen prey to Jeffrey Epstein's sex trafficking scheme 
recruited Jane Doe 1 to meet Epstein. 
96. 
Epstein and his co-conspirators had a long history of grooming, 
indoctrinating, controlling, and ultimately committing sexual offenses against 
young, vulnerable women like Jane Doe I. Epstein and his co-conspirators 
constantly reminded Jane Doe 1 how powerful and important Epstein was. Jane Doe 
I was chastised if she refused Epstein's sexual demands and told she should be 
grateful that Epstein was willing to help her with her career and education. She came 
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to believe what she was told. 
97. 
The well-oiled Epstein sex abuse and trafficking venture included 
frequent statements to Jane Doe I and other victims by Epstein and his 
co-conspirators that: (1) Epstein possessed extraordinary wealth, power and 
influence; (2) Epstein's business and political friends, including world leaders, also 
included some of the most powerful people in the world; (3) Epstein had the ability 
to advance or destroy nearly anyone financially, reputationally, and otherwise; 
(4) medical and other life necessities would be denied victims if they, including Jane 
Doe 1, failed to perform commercial sex acts for Epstein; and (5) Epstein could take 
away Jane Doe l's and other victims' life necessities such as shelter or housing if 
she or they failed to perform those acts. 
98. 
Jane Doe I was exceptionally vulnerable to being victimized by 
Epstein. His sex-trafficking venture targeted vulnerable young women and Jane Doe 
I was soon indoctrinated and unable to extricate herself. Jane Doe 1 was sexually 
abused and trafficked by Epstein for several years. Having been conditioned that 
the sexual abuse was "normal" and knowing that everyone surrounding Epstein, 
including accountants, lawyers, and other important people, were aware of the sex 
abuse, Jane Doe 1 was coerced into a cult-like life controlled and manipulated by 
Epstein and others doing Epstein's bidding. 
99. 
Over the ensuing years, from 2006 through 2013, Epstein sexually 
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abused Jane Doe 1 on a number of occasions in New York, Florida, New Mexico, 
and the United States Virgin Islands in direct violation of Article 130 of New York's 
Penal Law, including but not limited to the following: 
a. Sexual misconduct as defined in *130.20, inasmuch as Jeffrey Epstein 
engaged in sexual intercourse with Plaintiff without Plaintiff's consent; 
b. Rape in the first degree as defined in §130.35, inasmuch as Jeffrey 
Epstein engaged in sexual intercourse with Plaintiff by forcible 
compulsion; 
c. Criminal sexual act in the first degree as defined in §130.50, inasmuch 
as Jeffrey Epstein engaged in oral sexual conduct with Plaintiff by 
forcible compulsion; 
d. Forcible touching as defined in §130.52, inasmuch as Jeffrey Epstein, 
intentionally and for no legitimate purpose, engaged in the forcible 
sexual touching of Plaintiff for the purpose of degrading or abusing her 
or for the purpose of gratifying his own sexual desire; and 
e. Sexual abuse in the third degree as defined in §130.66, inasmuch as 
Jeffrey Epstein inserted a foreign object in the vagina of Plaintiff by 
forcible compulsion. 
100. Jane Doe 1 was also coercively trafficked to Jeffrey Epstein's friends 
for commercial sex acts in this District. 
101. Epstein used means of force, threats of force, fraud, coercion, abuse of 
process, and a combination of such means to cause Jane Doe 1 to engage in 
commercial sex acts. 
102. Epstein recruited Jane Doe 1 to cause and force her to engage in 
commercial sex acts in ways that were in and affecting interstate and foreign 
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commerce, including use of cell phones and means of interstate transportation (such 
as aircraft that he owned or controlled). 
103. Epstein transported Jane Doe 1 from New York to other states to cause 
her to engage in commercial sex acts. 
104. Jane Doe 1 wanted to escape from the Epstein sex-trafficking venture, 
yet Epstein and his supporting team of co-conspirators increased the tactics of fraud, 
force, or coercion to cause her to remain compliant in fulfilling Epstein's sexual 
demands. 
105. Jeffrey Epstein controlled Jane Doe 1 financially, emotionally, and 
psychologically. He used his knowledge of Jane Doe 1's aspirations, fears, and 
problems to manipulate her until she was completely controlled by and dependent 
upon him. 
106. When Epstein went to jail for sex offenses in Florida, he maintained 
contact with Jane Doe 1. He and employees of his business entities, which were 
created to support and legitimize Epstein's sexual abuse and sex-trafficking 
enterprise, including HBRK, NES, Financial Trust, and Florida Science Foundation, 
caused Jane Doe 1 to be transported to Florida to engage in commercial sex with 
Epstein in his Florida residence while on so-called "work release" from jail, while 
he was still wearing his ankle monitor. 
107. There came a time when Epstein forced Jane Doe 1 to give massages to 
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certain of his powerful friends. During some of these massages Jane Doe 1 was 
sexually abused, by force and against her will, by Epstein's friends whom she had 
been required to massage. At least one of Epstein's friends used aggressive force in 
his sexual assault of her and informed Jane Doe 1 that he had Epstein's permission 
to do what he wanted to her. Out of fear, Jane Doe 1 has still not named this powerful 
financial executive publicly. 
108. Epstein and his co-conspirators withdrew large sums of cash from JP 
Morgan to make cash payments to victims, including Jane Doe 1, in furtherance of 
the sex-trafficking operation. 
109. Jane Doe 1 was regularly paid cash by Epstein or one of his co-
conspirators that was withdrawn from one of Epstein's accounts at JP Morgan. 
110. As alleged more fully below, JP Morgan knew that its accounts were 
being used for Epstein's sex-trafficking venture based on a number of facts, 
including but not limited to the identity of the individuals making the withdrawals 
and wire transfers, the vast size of the withdrawals and transfers, the identity of the 
recipients, the account opening activity, the pattern of the financial activity, the 
personal relationship between Epstein and at least one high-ranking executive with 
JP Morgan as detailed more thoroughly below, and Epstein's well-documented 
criminal history and involvement in trafficking. 
111. Over the ensuing years, Epstein threatened Jane Doe I in many ways 
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including threatening that if she did not abide by his demands, she would lose contact 
with people she cared about and that those people would also suffer serious harm. 
112. Epstein would alternate promises and threats to secure Jane Doe 1 's 
compliance with his demands, including demands that she engage in commercial sex 
acts with him and others. In some instances, Epstein would pay Jane Doe 1 directly 
in cash obtained from JP Morgan for sex acts. 
113. Epstein and his co-conspirators continued to coerce Jane Doe 1 in 
various ways until her ultimate escape around the end of 2013. 
114. Epstein and his co-conspirators continued to coerce Jane Doe 1 to 
engage in commercial sex with Epstein, through the use of Epstein's force, fraud 
(such as false promises, including the continued promise to assist Jane Doe l's sister 
medically) and coercion (making it clear that if she did not abide then she would 
suffer serious financial and reputational harm), through the end of 2013. 
115. James "Jes" Staley ("Staley"), the then-head of JP Morgan's private 
banking division, was a regular visitor of Epstein's during that period of time, 
through and beyond 2013, and personally observed Jane Doe 1 as a sexual trafficking 
and abuse victim at times including through his departure from JP Morgan in 2013. 
C. 
JP Morgan's Role in the Sex-Trafficking Venture 
1. Banking laws and regulations exist to prevent funding of criminal ventures. 
116. The Federal Bank Secrecy Act ("BSA") requires financial institutions 
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to have adequate anti-money laundering ("AML") policies and systems in place. 
New York state law also requires financial institutions to devise and implement 
systems reasonably designed to identify and report suspicious activity and block 
transactions prohibited by law. 
117. All regulated institutions are expected to configure systems based on 
their unique risk factors, incorporating parameters such as institution size, presence 
in high-risk jurisdictions, and the specific lines of business involved, and the 
institutions have an affirmative duty to ensure that their systems run effectively. 
118. In addition to having effective AML controls in place, it is also 
necessary for financial institutions to monitor their customers for the purpose of 
preventing their customers from facilitating criminal activity using the institutions' 
facilities. 
119. As part of preventing criminal activity, Know Your Customer ("KYC") 
and customer due diligence are critically important, and financial institutions must 
collect customer information at the time of establishing new relationships with 
clients, including as necessary to assess the risks associated with the client. To 
properly consider these risks, financial institutions must consider relevant factors 
such as the nature of the client's business, the purpose of the client's accounts, and 
the nature and duration of the relationship. 
120. Financial institutions must also conduct KYC reviews for each client 
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relationship at intervals commensurate to the AML risks posed by the client, 
including reviewing account activity to determine whether such activity fits with 
what would have been expected given the nature of the account. Each client's AML 
risk should also be re-assessed if material new information or unexpected account 
activity is identified. 
121. Financial institutions must also establish criteria for determining when 
a client relationship poses too high of a risk and therefore must be terminated. A 
financial institution may be liable under applicable laws if it maintains such a 
relationship despite repeated indications of facilitation of improper transactions. 
2. JP Morgan directly participated in Epstein's sex-trafficking venture. 
122. With the encouragement of Staley, JP Morgan knowingly and 
intentionally participated in the Epstein sex-trafficking venture by (among other 
things) providing the financial underpinnings for Epstein to have ready and reliable 
access to resources—including cash—to recruit, lure, coerce, and entice young 
women and girls to cause them to engage in commercial sex acts and other 
degradations. 
123. In or about 1998, in furtherance of his rapidly growing sexual abuse 
and sex trafficking operation, Epstein realized that he needed a reliable banking 
institution that would provide the necessary legitimate appearance for his operation, 
allow him to open many accounts for illegitimate companies, ignore red flags and 
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relevant state and federal banking laws, permit him to transfer money without 
questioning, allow him access to abundant cash, and to otherwise knowingly 
facilitate the commercial aspect of his commercial sex trafficking enterprise. 
Epstein found all of those things in JP Morgan. 
124. From about 1998 through 2013 (and following), JP Morgan knowingly 
and intentionally participated in the Epstein sex-trafficking venture by (among other 
things) providing the essential financial underpinnings for the venture. It also 
financially benefited from that participation. There can be no doubt that JP 
Morgan's conduct, as described below, was outrageous and intentional. 
125. Around 2000, Epstein developed a key relationship to expanding 
exploitative sexual abuse and his sex-trafficking operation when he began working 
with Staley, the then-head of JP Morgan's private banking division. 
126. Before meeting Staley, Epstein was a serial sexual abuser of young girls 
and women, with an insatiable desire to sexually abuse females that were, in his 
words, "the younger, the better." 
127. Before Staley, Epstein relied heavily on the massive wealth bestowed 
upon him primarily by one individual, Leslie (Les) Herbert Wexner ("Wexner"), to 
give him the appearance of grand importance while relying on his then-madame, 
Maxwell, to find and groom young women to be abused. 
128. It has been reported that Wexner claims Epstein stole the money from 
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him. Nonetheless, the origin of Epstein's money was always a mystery, with Epstein 
claiming to be a money manager to a stable of clients who entrusted him with a 
minimum of $1 billion. JP Morgan knew that was a lie. Staley knew without any 
doubt that Epstein was trafficking and abusing girls and that all of his staff, including 
his main attorney and accountant, worked full time to conceal the illegal operation. 
129. However, Epstein could not expand his operation to the level it 
ultimately reached without a complicit financial banking institution that would 
ignore red flags and assist him in paying hundreds of young females in wire transfers 
and cash and allow him access to hundreds of thousands of dollars in cash to pay 
hush money to his growing number of victims. 
130. Staley was the key to making all of Epstein's depraved dreams of sexual 
abuse and sex trafficking of countless young women possible. With his help, the 
number of victims of the Epstein sex-trafficking operation began to grow on a 
vertical trajectory beginning in and around 2000. 
131. When Epstein and Staley first teamed up, in or around 2000, Staley was 
the head of JP Morgan's private banking division and was later promoted to CEO of 
JP Morgan Asset Management in 2001. 
132. The relationship between Epstein and Staley was symbiotic and special. 
Epstein agreed to bring many ultra-high wealth clients to JP Morgan, and in 
exchange, Staley would use his clout within JP Morgan to make Epstein 
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untouchable. 
133. Staley bragged within JP Morgan about Epstein's value to the bank and 
used his position in the bank to silence any critics of the relationship between JP 
Morgan and Epstein. 
134. This meant that JP Morgan would keep Epstein on as a client at all 
costs, including failing to act on any red flags and ultimately allowing him to run 
and grow an operation designed to sexually abuse and traffic countless young girls 
and women. 
135. Once Epstein had JP Morgan (through Staley) in his pocket, Epstein 
moved on to his next target, another known sexual abuser, Jean-Luc Brunel, a French 
model scout who had suffered public disgrace for serial sexual abuse of young 
females. 
136. Epstein enlisted Brunel to recruit new victims from all over the world, 
enticing them with promises of modeling careers before sexually abusing and 
trafficking them through a modeling agency Epstein and Brunel established called 
MC2. 
137. In 2019, Brunel was arrested in France for sex trafficking related to his 
relationship with Jeffrey Epstein and, like Epstein, was found hanging in his cell 
from an apparent suicide. 
138. There were several key figures who conspired and participated in 
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Epstein's international sex trafficking operation, most notably Ghislaine Maxwell, 
Les Wexner, Jean Luc Brunel, and Jes Staley, acting through and on behalf of JP 
Morgan. 
139. In later years, Deutsche Bank swapped in for JP Morgan and provided 
the necessary complicit financial institution for the operation, not coincidentally on-
boarding Epstein's trafficking operation through a former JP Morgan banker, Paul 
Morris. 
140. These co-conspirators were essential to Epstein's operation. Without 
Maxwell, Epstein would never have been able to recruit his first victims and bring 
them into his abusive lair. Maxwell approached young, vulnerable victims and 
painted Epstein as an altruistic messiah who could help them. Once the girls were 
in Epstein's clutches, Maxwell groomed them to make them feel comfortable being 
sexually exploited and abused. 
141. Without Brunel, Epstein would not have been able to expand his 
international recruiting of young victims and, specifically, aspiring models he could 
lure in with promises of opportunities. 
142. Without Wexner, Epstein's sex-trafficking operation could never have 
occurred to the extent that it did, as Epstein needed the appearance of extraordinary 
wealth to attract his victims and force them to stay silent. 
143. However, even with Wexner's funding of Epstein's operation, 
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Epstein's sexual abuse of hundreds of women would have been limited because the 
money trail from Epstein's accounts to the many victims and recruiters would have 
quickly exposed his illegal venture. 
144. Therefore, Epstein could not risk having a typical banking relationship 
where the bank might uncover something suspicious and report him to law 
enforcement. The final essential ingredient Epstein needed to expand his sexual 
abuse of young women and sex trafficking enterprise was therefore a financial 
institution that would know—but not care—that Epstein was sexually abusing 
women on a daily basis and paying out millions in hush money. Indeed, Epstein 
needed an institution that would in fact assist and participate in that activity, and that 
would support his enterprise and conceal it if he was ever caught. 
145. JP Morgan provided the final component Epstein needed, and Staley 
had a special relationship with Epstein and made sure Epstein and his illegal sexual 
abuse organization were absolutely protected by the bank. 
146. From the beginning of the Epstein/Staley relationship, Staley 
understood that Epstein's money was only a part of the incentive to protect Epstein's 
operation. 
147. During the Palm Beach Police Department's 2005 investigation into 
Epstein's sexual abuse of minor children, the detectives pulled message pads left by 
Epstein's assistant from his trash as well as a search warrant executed at Epstein's 
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Palm Beach, Florida mansion. 
148. According to those message pads, Staley was a frequent caller to 
Epstein's Florida home throughout the course of Epstein's banking relationship with 
JP Morgan. 
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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 39 of 130 
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150. As long as Epstein's money stayed at JP Morgan, Staley also knew that 
Wexner, Epstein's client who had turned over a power of attorney to Epstein, would 
likewise keep his money with JP Morgan. Wexner's money was said to amount to 
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over a billion dollars. 
151. Epstein made clear that Wexner was not the only JP Morgan client 
whose allegiance to the bank Epstein controlled. Staley knew that Epstein "collected 
people" and was close with many ultra-wealthy individuals that he could bring into 
the bank, and Epstein did bring additional customers to the bank in exchange for JP 
Morgan aiding and facilitating his international sex trafficking operation. These new 
customers made JP Morgan even more profitable. Along the way, Epstein gave 
credit for these new bank customers to Staley, which made Staley even more 
powerful within JP Morgan. 
152. Epstein controlled Staley like he did his many victims: by flaunting his 
power and connections to the extremely wealthy. Epstein made it clear to Staley 
that if JP Morgan ever decided to terminate its relationship with Epstein, the bank 
would lose Wexner and the other wealthy connections Epstein had promised JP 
Morgan. 
153. Staley and Epstein's relationship grew closer as the years went on. In 
fact, during the criminal investigation into Epstein in 2005, Staley flew on Epstein's 
plane along with Sarah Kellen and Nadia Marcinkova, individuals who had bank 
accounts through Epstein at JP Morgan and who were publicly identified as 
Epstein's co-conspirators in trafficking offenses. 
154. Rather than merely providing routine banking for Epstein, JP Morgan 
40 
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