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went far beyond what a non-complicit bank would have done and instead assisted 
Epstein in setting up the necessary financial structure to operate his sex-trafficking 
venture. 
155. Specifically, money was paid from Epstein affiliated JP Morgan 
accounts to victims of trafficking and to known Epstein co-conspirators. Money was 
also withdrawn from Epstein affiliated JP Morgan accounts in cash to pay victims 
in furtherance of the sex trafficking operation. 
156. JP Morgan also deliberately failed to follow routine banking practices 
of review Epstein's accounts against the backdrop of the public information outing 
him as a serial sex abuser and reporting Epstein for what was obviously a sex 
trafficking operation he was running. JP Morgan, for example, purposely and 
deliberately failed to timely file required Suspicious Activity Reports ("SARs") for 
large cash and other suspicious activities of Epstein. In short, instead of providing 
ordinary and routine banking, JP Morgan instead assisted Epstein in covering up his 
past crimes and committing new ones. 
157. Acting on behalf of JP Morgan, Staley assured Epstein that the two 
were close friends and he would help Epstein and his operation in any way he could. 
JP Morgan advised Epstein strategically about opening new accounts for additional 
Epstein-related entities and assured him his cash needs would be satisfied—
permitting Epstein to continue to pay hush money to victims that could harm Epstein 
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in the criminal investigation. 
158. JP Morgan chose not to cooperate with law enforcement and other 
investigations into Epstein's sex trafficking, because it knew it would be exposed as 
assisting in Epstein's scheme. 
159. During a trip to the U.S. Virgin Islands in January 2007, Jane Doe 1 
was repeatedly raped and coerced into commercial sex. She was paid $10,000 in 
hush money, which Epstein's agents apparently withdrew from JP Morgan in cash. 
Epstein told Jane Doe I he expected her to remain loyal to him and compliant, 
making clear that if she did not, then she would suffer serious harm. 
160. Epstein was one of the most coveted clients of JP Morgan because of 
the financial benefits he provided to JP Morgan and its officers and employees, 
including Staley. Through the years, Staley helped accumulate other protectors of 
Epstein within JP Morgan. 
161. The New York Times reported in 2019 that Mary C. Erdoes, one of JP 
Morgan's highest-ranking executives intervened to keep Epstein as a client after he 
pled guilty to sex crimes and was registered a sex offender. 
162. With JP Morgan's complicity, Epstein was free to sexually abuse 
hundreds of women, paying millions in hush money, without the fear of detection 
by law enforcement. Epstein used the support of a reputable institution—JP 
Morgan—to help cover up his sex-trafficking venture. 
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163. JP Morgan cared about profiting and showed absolute loyalty to 
Epstein, including a willingness to violate banking laws, ignore multiple red flags of 
criminality, and participate directly in sex trafficking to enable Epstein to fulfill his 
abusive sexual appetite at the expense of countless vulnerable young women. 
164. As Epstein's criminal sex trafficking venture expanded, he needed 
more protection and support from JP Morgan. Through Staley and others, Epstein 
became more deeply involved with JP Morgan, providing JP Morgan with more 
financial benefits. And. as a quid pro quo, JP Morgan allowed Epstein to transfer 
massive amounts of hush money to his victims and recruiters. JP Morgan allowed 
Epstein to withdraw hundreds of thousands of dollars in cash so that all the payments 
were not traceable (the most obvious red flag for any criminal enterprise). 
165. As another example of JP Morgan and Staley's benefit from assisting 
Epstein, a highly profitable deal for JP Morgan was the Highbridge acquisition. 
166. In 2004, when Epstein's sex trafficking and abuse operation was 
running at full speed, Epstein served up another big financial payday for JP Morgan. 
167. Epstein was close friends with Glenn Dubin, the billionaire who ran 
Highbridge Capital Management. 
168. Through Epstein's connection, it has been reported that Staley arranged 
for JP Morgan to buy a majority stake in Dubin's fund, which resulted in a sizeable 
profit for JP Morgan. This arrangement was profitable for both Staley and JP 
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Morgan, further incentivizing JP Morgan to ignore the suspicious activity in 
Epstein's accounts and to assist in his sex-trafficking venture. 
169. For example, despite that Epstein was not FINRA-certified, Epstein 
was paid more than $15 million for his role in the Highbridge/JP Morgan deal. 
170. Moreover, Highbridge, a wholly-owned subsidiary of JP Morgan, 
trafficked young women and girls on its own private jet from Florida to Epstein in 
New York as late as 2012. 
171. Staley and JP Morgan benefited from Epstein's sex-trafficking 
operation because, in exchange for JP Morgan's knowing participation in that 
operation, Epstein generated millions of dollars for JP Morgan, directly and 
indirectly. Because Staley was generally in charge of Epstein's JP Morgan accounts, 
he also benefited in the receipt of massages, private jet flights with victims or co-
conspirators of the operation, and other things of value. 
172. Over many years, some JP Morgan executives lobbied within JP 
Morgan to sever ties with Epstein due to the sex-trafficking allegations against him. 
JP Morgan's leadership ignored their pleas and ultimately decided each time to keep 
Epstein as a client. JP Morgan decided that, because it was receiving such large 
monetary benefits from Epstein, it would continue participating in the Epstein sex-
trafficking venture by providing its financial infrastructure. 
173. Epstein offered his business, and the many millions it generated, 
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exclusively to JP Morgan because in) Morgan was willing to knowingly aid Epstein's 
sex trafficking operation and to help conceal it. JP Morgan knew that if it stopped 
aiding and concealing the operation, it would lose Epstein's accounts and the 
substantial financial benefits resulting from handling those accounts. 
174. In addition to housing Epstein's accounts, JP Morgan also housed 
accounts for numerous of Epstein's co-conspirators, including Epstein's main sex-
trafficking madame, Maxwell, who is now serving 20 years in prison for sex-
trafficking related to her participation in Epstein's operation. 
175. In 2022, JP Morgan representative Patrick McHugh testified in 
Maxwell's criminal sex-trafficking trial that between 1999 and 2007, Epstein 
transferred approximately $31 million to Maxwell, an amount believed to be 
payment for her role in Epstein's sex trafficking venture. 
176. In addition to the necessary financial infrastructure provided by JP 
Morgan, as late as 2012, a JP Morgan subsidiary company assisted with transporting 
certain Epstein sex-trafficking victims by private jet from Florida to Epstein in New 
York. 
177. Ultimately, JP Morgan financially benefited by earning millions of 
dollars for its participation in the Epstein sex-trafficking venture. 
178. Throughout its relationship with Epstein, JP Morgan violated numerous 
banking laws and regulations in order to conceal and continue its lucrative venture 
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facilitating the Epstein sexual abuse and sex-trafficking scheme. 
179. For example, JP Morgan allowed Epstein and his agents to "structure" 
cash withdrawals to further the sex-trafficking venture. 
180. As another example, JP Morgan failed to file with the federal 
government the required SARs that financial institutions must file with the Financial 
Crimes Enforcement Network ("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. While JP Morgan was providing Epstein vast 
sums of cash each year, it was required to timely file SARs about Epstein's 
suspicious and unusual cash transactions. 
181. JP Morgan's failure to timely file SARs about Epstein's sex-trafficking 
venture, in spite of numerous red flags, was wrongful and purposeful. 
182. A recent amended complaint filed by the government of the U.S. Virgin 
Islands against JP Morgan in this Court describes some of the red flags JP Morgan 
simply ignored: 
Between 2003 and 2013, Epstein and/or his associates 
used Epstein's accounts to make numerous payments to 
individual women and related companies. Among the 
recipients of these payments were numerous women with 
Eastern European surnames who were publicly and 
internally identified as Epstein recruiters and/or victims. 
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For example, Epstein paid more than $600,0000 to Jane 
Doe 1, a woman who—according to news reports 
contained in JP Morgan's due diligence reports—Epstein 
purchased at the age of 14. Like other women who 
received payments from Epstein, Jane Doe I listed 
Epstein's apartments on 66th Street in New York City as 
her address, which should have been a red flag to JP 
Morgan. 
Epstein and/or his associates also made significant cash 
withdrawals and 95 foreign remittances with no known 
payee. For example, Hyperion Air, Inc.—the Epstein-
controlled company that owned Epstein's private jet—
issued over $547,000 in checks payable to cash 
purportedly for "fuel expenses when traveling to foreign 
countries." Additionally, between January 2012 and June 
2013, Hyperion converted more than $120,000 into 
foreign currency. Many of these cash withdrawals either 
exceeded the $10,000 reporting threshold or were 
seemingly structured to avoid triggering the reporting 
requirement. This is particularly significant since it is well 
known that Epstein paid his victims in cash. 
In addition, Epstein and/or his representatives appeared to 
be misusing JP Morgan accounts for Epstein's purported 
charitable 
organizations, 
including 
the 
C.O.U.Q. 
Foundation and Enhanced Education. Epstein made 
payments from these accounts with no clear nexus to the 
organization's charitable purpose. For example, Epstein 
and/or his representative used the C.O.U.Q. Foundation 
account to pay $29,464.66 to three young women, 
including two known victims, and over $20,000 to a 
company called Phoenix Realty Home Inc. 
Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., 
Case No. 22-cv-10904-JSR, Amended Complaint (Dkt. 16) at 16-17 (S.D.N.Y. 
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Jan. 10, 2023).' 
183. In taking the steps described above, JP Morgan obstructed, attempted 
to obstruct, and interfered with the federal government's enforcement of the TVPA, 
including the U.S. Attorney's Office for the Southern District of Florida's criminal 
investigation of Epstein in and around 2006 to 2008 and the U.S. Attorney's Office 
for the Southern District of New York's criminal investigation leading to his 
indictment in 2019. 
184. Over the many years of the venture between JP Morgan and Epstein, 
numerous JP Morgan executives, and several compliance officers, demanded that JP 
Morgan sever ties with Epstein and his criminal organization due to the public sex-
trafficking allegations against Epstein. But JP Morgan's leaders and those in control 
of those decisions were influenced by Staley to continue to support Epstein. Given 
all the surrounding circumstances and Staley's knowledge, JP Morgan's decisions 
to support Epstein were made with knowledge that he was operating a sex-trafficking 
' Jane Doe 1 hereby adopts by reference the substantive factual allegations 
regarding JP Morgan's participation in Epstein's sex-trafficking venture and 
conspiracy found the U.S. Virgin Islands' (USVI) Amended Complaint against JP 
Morgan into this Amended Complaint. See Fed. R. Civ. P. 10(c). A copy of that 
amended complaint is attached to this complaint as Exhibit 1. With regard to issues 
concerning the scope and duration of JP Morgan's participation in the venture and 
conspiracy, as well as the nature of the venture and conspiracy, Jane Doe 1 relies on 
her own complaint. Jane Doe 1 does not believe any of the substantive factual 
allegations by the USVI are inconsistent with hers. But, if any inconsistency exists, 
Jane Doe 1 relies solely on her allegations. 
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venture and conspiracy. 
185. 
In 2013, due to the overwhelming publicity about Epstein's illegal 
sexual activities, and the departure of Staley from JP Morgan, JP Morgan realized 
that its claims to not knowing what Epstein was doing were no longer facially 
plausible. Accordingly, and reluctantly, JP Morgan stopped being Epstein's banker. 
186. While JP Morgan stopped being Epstein's banker, it did not make a 
clean break of things by disclosing its actions in support of the conspiracy to the 
authorities. Nor did it communicate its abandonment of its conspiring with Epstein 
and others in a manner reasonably calculated to reach Epstein's co-conspirators. 
187. While JP Morgan stopped being Epstein's banker, it continued to take 
subsequent actions to promote the venture and conspiracy. 
For example, it 
deliberately and willfully continued to fail to timely file SARs about the suspicious 
activities it had seen. And it continued to recommend Epstein as good client to 
others how inquired. 
188. After losing Staley, Epstein no longer had his primary protector at JP 
Morgan. In order to continue to operate, Epstein would need to find a new bank. As 
alleged in greater detail in another complaint pending before this Court, Epstein 
found that new bank to facilitate his sex trafficking venture—Deutsche Bank. See 
Jane Doe 1 v. Deutsche Bank Aktiengesellschaft et al., Case No. 22-cv-10018-JSR, 
Amended Complaint (S.D.N.Y. Jan. 13, 2023). 
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3. JP Morgan's knew about Epstein's sex-trafficking venture and conspiracy. 
189. As explained above, between (at least) 2000 and 2005, Epstein 
provided clients to JP Morgan and, in exchange, JP Morgan allowed Epstein to do 
as he pleased with his JP Morgan accounts. JP Morgan directly aided Epstein's sex 
trafficking venture by allowing Epstein to engage in structuring violations and other 
financial maneuvers required to maintain and conceal his criminal enterprise. JP 
Morgan financially benefited from allowing Epstein to use his JP Morgan accounts 
to run his sex trafficking venture. 
190. However, in 2006, Epstein's relationship with JP Morgan hit a snag 
when Epstein was publicly exposed for sexually abusing dozens of young women 
and girls, several as young as 14 years old. There were hundreds of pages of police 
reports and news articles revealing that Epstein was a serial sexual abuser and 
trafficker, and that his operation depended on his accessing nearly unlimited cash to 
use as payments to his victims. 
191. With respect to the specific discoveries, the authorities found that some 
of the victims "went to Mr. Epstein's house only once, some went there as much as 
100 times or more." 
192. It was publicly revealed in the investigation that Epstein was sexually 
abusing three to four young females every single day of his life and that he was 
paying each victim hundreds of dollars in hush money, usually in cash. 
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193. The criminal investigation also publicly revealed that Epstein was 
paying countless recruiters to constantly bring him more victims, making clear that 
quick access to cash at a financial institution was the lifeblood for his sex-trafficking 
venture. 
194. The money trail into Epstein's accounts was a dead giveaway that 
Epstein was engaging in crimes and the recipients of his money exposed the type of 
crimes. 
195. At this point (and earlier), JP Morgan knew that Jeffrey Epstein was an 
international sex trafficker. To the extent JP Morgan could publicly feign plausible 
deniability before Epstein's arrest in 2006, thereafter its ability to play dumb 
thereafter was eviscerated, as the details of his daily sexual abuse of young females 
came to public light and when he ultimately was required to register as a sex 
offender. 
196. JP Morgan undoubtedly knew about Epstein's arrest in 2006. 
197. Because Epstein was so publicly exposed as a sex trafficker and abuser, 
one of his primary financial engines, Les Wexner, abandoned him and separated 
himself from Epstein. 
198. The federal criminal case against Epstein was under investigation from 
(at least) 2006 through 2008, when Epstein eventually entered his guilty plea, 
registered as a sex offender, and went to jail. 
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199. In the summer of 2008, Epstein's Non-Prosecution Agreement 
("NPA") with the U.S. Department of Justice was made public when it was unsealed 
in connection with a challenge to the NPA by two of his victims. Among other 
things, the agreement outlined the possible federal sex offense charges that could 
have resulted from the investigation, including TVPA charges. 
200. Epstein's legal team also garnered significant publicity between 2006 
and 2008, not only because of their well-known names but also the unusual number 
of them. Epstein hired Roy Black, Ken Starr, Jay Lefkowitz, Guy Lewis, Michael 
Tien, Lily Ann Sanchez, Gerald Lefcourt, Guy Fronstein, Jack Goldberger, and 
more. All of these lawyers were now on Epstein's payroll and millions of dollars 
were being shelled out to these attorneys from JP Morgan accounts to pay for his 
legal defense of the most heinous of sexual abuse allegations. Not only was JP 
Morgan (through Staley) well aware of the allegations, but JP Morgan (through 
Staley) knew the identities of co-conspirators and many of the victims. Staley had 
observed victims personally, and he was aware that Epstein was shelling out millions 
of dollars to attorneys to take on these well-founded allegations. 
201. In 2008, around the same time Epstein was pleading guilty to felony 
sex offenses and registering as a lifetime sex offender, JP Morgan learned that 
another of its high value clients, Bernie Madoff, was running the largest Ponzi-
scheme in modern history through his accounts at JP Morgan. This led to .n) Morgan 
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reviewing its clientele with the directive of severing ties with any problematic 
customers. 
202. With indisputable publicly available knowledge that Epstein was a 
sexual offender who was using his wealth to run a sexual abuse and trafficking 
operation, any responsible bank providing only routine banking support would have 
cut ties with Epstein. 
203. However, rather than cut ties with Epstein, Staley, acting on behalf of 
JP Morgan and within the scope of his actual and apparent employment, personally 
visited Epstein when he was serving his jail sentence in Florida and arranged for an 
even tighter connection between JP Morgan and Epstein. 
204. After Epstein was released from his Florida incarceration, he picked up 
right where he left off—abusing young women on a daily basis, paying recruiters, 
and paying hush money to victims. .n) Morgan continued its supporting actions as 
well, continuing its role in Epstein's sex trafficking conspiracy and allowing it to 
continue to flourish. Epstein continued abusing and trafficking with the same 
frequency as he had been for years, and he could do so because he had a bank that, 
even though it knew what he was doing, would not turn on him. 
205. After Staley went to visit Epstein in Florida while Epstein was 
incarcerated on sex offenses, Epstein and JP Morgan's relationship continued to 
grow through Staley. Ultimately, after Epstein's release from jail, Staley and 
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Epstein spent significant time together at Epstein's townhouse in New York City. 
Staley also visited Epstein on his private island in the United States Virgin Islands—
an island commonly dubbed "Pedophile Island." These visits were within the actual 
and apparent scope of Staley's employment at JP Morgan. 
206. Acting through Staley and to protect its financial benefits from dealing 
with Epstein, JP Morgan made clear to Epstein that he could continue to fund his 
sexual abuse operation through JP Morgan and it would continue to conceal the 
illegal operation. JP Morgan and Epstein agreed, tacitly and otherwise, that Epstein 
could continue to fund his sex-trafficking venture through JP Morgan and JP Morgan 
would reap the financial benefits from its connection with Epstein. 
207. After his arrest in 2008, dozens of public lawsuits were filed against 
Epstein, revealing greater details of Epstein's sexual abuse of young women. 
208. The lawsuits detailed millions in payments that Epstein was making to 
recruiters, co-conspirators, cover-guys (such as his longtime fixer/lawyer and 
fixer/accountant), and his victims. 
209. Through the civil lawsuits, evidence (such as the previously referenced 
message pads) taken from Epstein's trash by police or through prior search warrants, 
as well as flight logs and black books began to publicly surface, shedding further 
public light on the expansiveness of Epstein's sex-trafficking operation. 
210. Through the lawsuits, other relevant information also became public 
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and was widely published: Epstein had no college degree, he had never obtained 
any specialized license, none of the companies with whom he was associated had 
any legitimate business structure or purpose, and he had no documented expertise 
that would provide the requisite skill or knowledge to amass his vast wealth. 
211. Epstein's victims' court challenge against Epstein's federal NPA also 
continued between 2008 and 2013 (and beyond) and attracted significant media 
attention. Indeed, between around 2006 and 2013, hundreds of press reports outlined 
the allegations underlying the NPA and to varying degrees detailed the involvement 
of Epstein's alleged co-conspirators, including Lesley Groff, Sarah Kellen, and 
Nadia Marcinkova. Some articles reported that Kellen and Marcinkova had invoked 
their Fifth Amendment right against self-incrimination. 
212. Additionally, press reports during this time noted allegations that 
Epstein was involved with Eastern European women in particular and that a 
modeling agency he helped develop with his friend and known sexual abuser, Jean 
Luc Brunel, brought "young girls . . . often from Eastern Europe" to the U.S. on 
Epstein's private jets. 
213. At all times material hereto, JP Morgan was aware of the foregoing 
information and more about Epstein's sex trafficking activities. When some 
executives on the board at JP Morgan recommended cutting ties with Epstein, Staley 
made strong and successful arguments, leading to JP Morgan keeping Epstein as a 
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customer. 
214. In support of maintaining its relationship with Epstein, JP Morgan's 
CEO of private banking, Mary Erdoes, argued that Epstein was too valuable of a 
client to let go and played a pivotal role in maintaining the relationship. 
215. Upon information and belief, internal documents also reflect JP 
Morgan's knowledge of the extensive publicly available information about Epstein's 
sex-trafficking scheme. 
216. JP Morgan, including its CEO Jamie Dimon and the highest levels of 
the bank, made the decision to monitor the public news being disseminated about 
Epstein, knew that Epstein had been arrested for sexual offenses against young 
women, knew that Epstein was a registered sex offender, knew that Epstein's co-
conspirators like Ghislaine Maxwell were involved in the sex trafficking operation, 
knew that Epstein had paid to settle a number of civil lawsuits related to sexual abuse 
of underage girls, and still made an intentional decision to keep Epstein on as a client. 
217. JP Morgan, including its CEO Jamie Dimon and the highest levels of 
the bank, knew of Jes Staley's personal involvement with Epstein and yet still 
allowed Staley to remain a decision maker for JP Morgan on Epstein accounts. 
218. Even before the sexual abuse investigation in Florida, media reports 
raised questions about the facts that nobody knew how Epstein made his fortune nor 
what he did to continue making the millions of dollars needed to support his life. 
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219. Media reports also appeared about Epstein's prior SEC violations in his 
job at Bear Stearns arose. 
A former business partner of Epstein's, Steven 
Hoffenberg, even explained how Epstein assisted him in running a massive Ponzi 
scheme that landed Hoffenberg in prison. JP Morgan was aware of these and other 
reports. 
220. Epstein, it was reported, claimed to be a financial bounty hunter and 
money manager to those who would entrust him with $1 billion or more, yet JP 
Morgan, with access to Epstein's accountants, knew Epstein's stated profession was 
a lie. 
221. Despite the false rumors he had created to conceal his true "business," 
Epstein was exposed as literally nothing other than a sex trafficker and abuser of 
young females, a fact easily discernible by any responsible financial institution with 
whom he was banking. 
222. For JP Morgan, a sophisticated financial institution legally responsible 
for complying with Know Your Customer laws and other banking obligations, the 
details of Epstein's sexual abuse and trafficking were not a surprise. Even so, JP 
Morgan never cooperated in any civil or criminal case against Epstein, because to 
do so would reveal JP Morgan's complicity in Epstein's operation. 
223. For example, in 2009, one of Jeffrey Epstein's sexual abuse victims 
served a subpoena on JP Morgan in connection with a civil case. JP Morgan refused 
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to comply with the subpoena, making it abundantly clear whose side JP Morgan was 
on. 
224. JP Morgan never timely filed required SARs about Epstein's suspicious 
transactions, including large cash transactions, which would have revealed to law 
enforcement authorities the sex-trafficking venture. 
225. Fearful that Epstein could turn on the bank for its participation in the 
sex-trafficking venture, JP Morgan (and its agent, Staley) remained incentivized to 
maintain and grow the relationship and to assist in concealing Epstein's suspicious 
and illegal banking practices. 
226. To be clear, during his years as a top executive at JP Morgan, Staley 
was not only one of Epstein's closest pals, but more importantly, he was a frequent 
visitor at Epstein's townhouse, including visiting the massage room; Staley met 
many of Epstein's trafficking victims, including Jane Doe 1; Staley visited the 
Epstein-owned victim stash house apartments at 301 East 66 Street, and Staley 
personally observed the sexual abuse of young women, including Jane Doe 1. These 
actions were within the scope of Staley's employment at JP Morgan. 
227. Staley was well aware that Epstein was running a sex trafficking 
venture, based on that facts that he: (1) went to Epstein's house in New York many 
times; (2) personally spent time with young girls whom he met through Epstein on 
several occasions; (3) personally visited young girls at Epstein's apartments located 
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at 301 East 66th Street; (4) personally visited Epstein on his island; (5) was frequently 
calling and emailing with Epstein; (6) personally observed Epstein around young 
girls, (7) personally observed Epstein sexually grab young women in front of him; 
and (8) even visited Epstein in Florida while Epstein was serving his jail sentence. 
All of these circumstances, and more, gave Staley direct and actual knowledge that 
Epstein was engaged in sex-trafficking venture. 
228. As a result of Staley's direct and actual knowledge of Epstein's sex-
trafficking venture, JP Morgan had direct and actual knowledge of Epstein's sex-
trafficking venture. 
229. Due to Staley's knowledge, JP Morgan knew that Epstein had no job 
and still helped open dozens of accounts for Epstein, allowing him to transfer money 
with no underlying legitimate business operation. 
230. Through Staley and other officers and employees, JP Morgan saw that 
Epstein's JP Morgan accounts were almost exclusively used to pay for: (1) living 
and travel expenses; (2) expenses related to apparent criminal activity; (3) lawyers 
relating to his Florida criminal case; (4) lawyers defending civil lawsuits (including 
paying for all of the witnesses' and co-conspirators' attorneys); (5) sex-abuse victim 
settlements; (6) private investigators to investigate sex abuse victims; and (7) 
extravagant lifestyles for his many co-conspirators. 
231. Through Staley and other officers and employees, JP Morgan: (1) knew 
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that Epstein was always surrounded by young women and girls; (2) knew Epstein's 
stated public profession of financial advisor was false; (3) knew Epstein had no real 
expertise in business investing; (4) knew that his accounts, including many business 
accounts, had underlying legitimate business activity; (4) saw Epstein's regular, 
suspicious, and large cash withdrawals; (5) saw Epstein's frequent payments to 
known co-conspirators; (6) knew that Epstein was funding a modeling agency with 
Jean-Luc Brunel (an already exposed sexual abuser); (7) knew that Epstein was 
making regular transfers in even, hundred-dollar increments; (8) knew that Epstein 
was arrested in Florida and required to register as a sex-offender; (9) knew that 
Epstein's co-conspirators had bank accounts at JP Morgan associated with his 
accounts; and (10) knew that Epstein's madame, Ghislaine Maxwell, was paid 
millions of dollars by Epstein. 
232. JP Morgan had awareness of all the facts listed in the previous 
paragraphs because, among other things, Staley, in the course his employment at JP 
Morgan, regularly visited Epstein's home in Manhattan, Epstein's Island, and 
Epstein's victim stash house on East 66th Street. 
233. During a 2019 investigation by the UK Financial Conduct Authority 
into Staley's relationship with Epstein, JP Morgan produced more than 1,200 emails 
exchanged between Staley and Epstein between 2008 and the end of Staley's tenure 
at JP Morgan. These emails were accessible to JP Morgan and written in Staley's 
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