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and force Jane Doe 1, as well as other Members of the Class, to engage in 
commercial sex acts. 
379. JP Morgan, through its employees and agents (including Staley), 
actively participated in the sex trafficking conspiracy and led Jane Doe I, as well as 
other Class Members, to believe that they would be rewarded if they cooperated and 
acquiesced to Epstein's coercive demands. 
380. JP Morgan's affirmative conduct was committed knowingly, and in 
reckless disregard of the facts, that Epstein would use cash and financial support 
provided by JP Morgan as a means of defrauding, forcing, and coercing sex acts 
from Jane Doe 1 as well as other Members of the Class. JP Morgan's conduct was 
outrageous and intentional. 
381. In addition to actual knowledge that it was participating in and 
facilitating the Epstein sex-trafficking venture, JP Morgan also should have known 
that it was participating in and facilitating a venture that had engaged in coercive sex 
trafficking, as covered by 18 U.S.C. § 1595(a). 
382. In exchange for facilitating and covering up Epstein's commercial sex 
trafficking, the JP Morgan's officers and employees (including Staley) advanced in 
their careers at JP Morgan and received financial benefits therefrom by securing the 
JP Morgan-Epstein relationship. 
383. Facilitating and covering up Epstein's sexual trafficking and 
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misconduct was a means of obtaining economic success and promotion within the 
JP Morgan hierarchy. 
384. JP Morgan's knowing and intentional conduct has caused Jane Doe 1 
and the other Members of the Class serious harm including, without limitation, 
physical, psychological, emotional, financial, and reputational harm. 
385. JP Morgan's knowing and intentional conduct has caused Jane Doe 1 
and the other Members of the Class harm that is sufficiently serious, under all the 
surrounding circumstances, to compel a reasonable person of the same background 
and in the same circumstances to perform or to continue performing commercial 
sexual activity, in order to avoid incurring that harm. 
386. This case does not involve mere fraud. Instead, JP Morgan's criminal 
conduct in violating the TVPA was outrageous and intentional, because it was in 
deliberate furtherance of a widespread and dangerous criminal sex trafficking 
organization. JP Morgan's criminal conduct 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 criminal conduct was directed 
specifically at Jane Doe I and other members of the Class, who were the victims of 
Epstein's sexual abuse and sex trafficking organization. 
387. JP Morgan's outrageous and intentional conduct in this case is part of 
a pattern and practice of JP Morgan profiting by undertaking illegal "high risk, high 
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reward" clients. 
388. By virtue of these knowing and intentional violations of 18 U.S.C. §§ 
1591(a)(2), 1595, JP Morgan is liable to Jane Doe 1 and the other Members of the 
Class for the damages they sustained and reasonable attorneys' fees. 
389. By virtue of these intentional and outrageous violations of 18 U.S.C. §§ 
1591(a)(2), 1595, JP Morgan is liable to Jane Doe 1 and other members of the Class 
for punitive damages. 
COUNT VI 
PARTICIPATING IN A SEX-TRAFFICKING VENTURE IN VIOLATION 
OF THE TRAFFICKING VICTIMS PROTECTION ACT, 
18 U.S.C. §§ 1591(a)(1),1595 
390. Plaintiff Jane Doe I realleges and incorporates by reference paragraphs 
1 — 285, as if fully set forth in this Count. 
391. Jane Doe 1 brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
392. JP Morgan knowingly and intentionally, through various means, 
participated in, perpetrated, assisted, supported, facilitated a sex-trafficking venture 
that was in and affecting interstate and foreign commerce, together and with others, 
in violation of 18 U.S.C. § 1591(a)(1). 
393. Among other things, JP Morgan knowingly and intentionally, through 
various means, recruited, enticed, provided, obtained, advertised, and solicited by 
various means Jane Doe 1, as well as other Class Members, knowing that Epstein 
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would use means of force, threats of force, fraud, coercion, and a combination of 
such means to cause Jane Doe 1, as well as other Class Members, some of whom 
were under the age of eighteen, to engage in commercial sex acts. 
394. JP Morgan and its officers and employees (including Staley) had actual 
knowledge that they were perpetrating and facilitating Epstein's sexual abuse and 
sex trafficking conspiracy to recruit, solicit, entice, coerce, harbor, transport, obtain 
and provide Jane Doe 1 as well as other Members of the Class, into commercial sex 
acts, through the means of force, threats of force, fraud, abuse of process, and 
coercion. 
395. Despite such knowledge, JP Morgan intentionally paid for, facilitated, 
perpetrated, and participated in Epstein's violations of 18 U.S.C. § 1591(a)(1), which 
JP Morgan knew, and were in reckless disregard of the fact that, Epstein would 
coerce, defraud, and force Jane Doe 1, as well as other Class Members, to engage in 
commercial sex acts. 
396. As part of perpetrating TVPA violations and enticing and recruiting 
victims, between on or about 2000 and August 2013, JP Morgan concealed its 
delivery of vast sums of cash to Epstein and his associates. 
397. As part of perpetrating TVPA violations, JP Morgan also willfully 
failed to file required SARs with the federal government. 
398. JP Morgan's affirmative conduct was committed knowing, and in 
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reckless disregard of the facts, that Epstein would use cash and the financial support 
provided by JP Morgan as a means of defrauding, forcing, and coercing sex acts 
from Jane Doe I as well as other Class Members. JP Morgan's conduct was 
outrageous and intentional. 
399. JP Morgan's knowing and intentional conduct has caused Jane Doe 1 
and the other Class Members serious harm including, without limitation, physical, 
psychological, emotional, financial, and reputational harm. 
400. JP Morgan's knowing and intentional conduct has caused Jane Doe 1 
and the other Members of the Class harm that is sufficiently serious, under all the 
surrounding circumstances, to compel a reasonable person of the same background 
and in the same circumstances to perform or to continue performing commercial 
sexual activity, in order to avoid incurring that harm. 
401. This case does not involve mere fraud. Instead, JP Morgan's criminal 
conduct in perpetrating TVPA violations was outrageous and intentional, because it 
was in deliberate furtherance of a widespread and dangerous criminal sex trafficking 
organization. JP Morgan's criminal conduct (including Staley conduct on behalf of 
JP Morgan) 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 criminal conduct was directed specifically at Jane Doe 1 and other 
members of the Class, who were the victims of Epstein's sexual abuse and sex-
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trafficking organization. 
402. JP Morgan's outrageous and intentional conduct in this case is part of 
a pattern and practice of JP Morgan profiting by undertaking illegal and "high risk, 
high reward" clients. 
403. By virtue of its knowing and intentional violations of 18 U.S.C. §§ 
1591(a)(1), 1595, JP Morgan is liable to Jane Doe 1 and the other Members of the 
Class for the damages they sustained and reasonable attorneys' fees. 
404. By virtue of these intentional and outrageous violations of 18 U.S.C. §§ 
1591(a)(1), 1595, JP Morgan is liable to Jane Doe 1 and other members of the Class 
for punitive damages. 
COUNT VII 
AIDING, ABETTING, AND INDUCING A SEX-TRAFFICKING VENTURE 
IN VIOLATION OF THE TRAFFICKING VICTIMS PROTECTION ACT, 
18 U.S.C. §§ 2, 1591(a)(1) & (2), 1595 
405. PlaintiffJane Doe 1 realleges and incorporates by reference paragraphs 
1 - 285, as if fully set forth in this Count. 
406. Jane Doe I brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
407. Acting through its officers and employees (including Staley), in) 
Morgan aided, abetted, and induced Epstein's sex-trafficking venture that was in and 
affecting interstate and foreign commerce, together and with others, in violation of 
18 U.S.C. §§ 2, 1591(a)(1) & (a)(2). 
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408. Under 18 U.S.C. § 2, JP Morgan is punishable as a principal under 18 
U.S.C. §§ 1591(a)(1) & (a)(2) and thereby committed and perpetrated violations of 
Chapter 77, Title 18, U.S. Code, when it aided, abetted, procured, and induced 
Epstein's sex-trafficking venture and sex trafficking of Jane Doe 1, as well as other 
Class Members. 
409. Under 18 U.S.C. § 2, JP Morgan committed and perpetrated crimes in 
violation of 18 U.S.C. §§ 1591(a)(1) & (a)(2) by aiding, abetting, and inducing 
Epstein's and his conspirators sex-trafficking venture and sex trafficking of Jane 
Doe 1, as well as other Class Members. As a consequence, Jane Doe 1, as well as 
other members of the Class, are victims of JP Morgan's criminally aiding, abetting, 
and inducing Epstein's violations of 18 U.S.C. §§ 1591(a)(1) & (a)(2). These actions 
were in and affecting interstate and foreign commerce. 
410. The crimes that JP Morgan aided and abetted are (1) Epstein's 
perpetrating of coercive sex trafficking, in violation of 18 U.S.C. § 1591(a)(1), and 
(2) Epstein's co-conspirators' knowingly benefitting from coercive sex trafficking, 
in violation of 18 U.S.C. § 1591(a)(2). These crimes were in and affecting interstate 
and foreign commerce. 
411. Epstein's co-conspirators benefitted financially and received things of 
value from their participation in the Epstein sex-trafficking venture, including 
payments and other compensation from Epstein. The co-conspirators who benefitted 
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financially include Ghislaine Maxwell, Lesley Grog Sarah Kellen, Adriana Ross, 
and Nadia Marcinkova. 
412. Acting through its officers and employees (including Staley), JP 
Morgan itself directly committed and perpetrated violations of Chapter 77, Title 18, 
U.S. Code, including 18 U.S.C. §§ 1591(a)(1) & (a)(2), by aiding, abetting, and 
inducing a sex-trafficking venture and the sex trafficking of Jane Doe 1, as well as 
other Class Members. JP Morgan itself directly violated Chapter 77 by committing 
and perpetrating these violations. 
413. Among other things, JP Morgan aided, abetted, and induced Epstein's 
sex-trafficking venture and sex trafficking of Jane Doe 1, as well as other Class 
Members, knowing that Epstein would use means of force, threats of force, fraud, 
coercion, and a combination of such means to cause Jane Doe 1, as well as other 
Class Members, some of whom were under the age of eighteen, to engage in 
commercial sex acts. 
414. By aiding, abetting, and inducing Epstein's sex-trafficking venture and 
sex trafficking of Jane Doe 1, as well as other Class Members, JP Morgan knowingly 
benefited, both financially and by receiving things of value, from participating in 
Epstein's sex-trafficking venture. 
415. JP Morgan and its officers and employees had actual knowledge that 
they were aiding, abetting, and inducing Epstein's sexual abuse and sex trafficking 
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conspiracy to recruit, solicit, entice, coerce, harbor, transport, obtain and provide 
Jane Doe 1 as well as other Members of the Class, into commercial sex acts, through 
the means of force, threats of force, fraud, abuse of process, and coercion. JP 
Morgan knew, and should have known, that Epstein had engaged in acts in violation 
of the TVPA. 
416. Despite such knowledge, JP Morgan intentionally paid for and aided, 
abetted, procured, and induced Epstein's and his co-conspirators violations of 18 
U.S.C. §§ 1591(a)(1) & (a)(2), which constituted perpetrating violations of those 
laws under 18 U.S.C. § 2. JP Morgan knew, and acted in reckless disregard of the 
fact that, Epstein would coerce, defraud, and force Jane Doe 1, as well as other Class 
Members, to engage in commercial sex acts. 
417. JP Morgan's affirmative conduct of aiding, abetting, procuring, and 
inducing Epstein's and his co-conspirators' violations was committed knowingly, 
and in reckless disregard of the facts, that Epstein would use cash and financial 
supported provided by JP Morgan as a means of defrauding, forcing, and coercing 
sex acts from Jane Doe 1 as well as other Class Members. JP Morgan's conduct was 
outrageous and intentional. 
418. Acting within this District and in attempting to further the Epstein sex-
trafficking venture, after various times between about 1998 and 2013, JP Morgan 
knowingly and intentionally took substantial and significant steps to aid and abet 
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Epstein's sex trafficking venture, including opened various brokerage accounts for 
Epstein and Epstein-related individuals and entities. These accounts were in and 
affecting interstate and foreign commerce 
419. JP Morgan's knowing and intentional conduct of aiding, abetting, and 
inducing Epstein's violations has caused Jane Doe 1 and the other Class Members 
serious harm including, without limitation, physical, psychological, emotional, 
financial, and reputational harm. 
420. JP Morgan's knowing and intentional conduct of aiding, abetting, and 
inducing Epstein's violations has caused Jane Doe 1 and the other Class Members 
harm that is sufficiently serious, under all the surrounding circumstances, to compel 
a reasonable person of the same background and in the same circumstances to 
perform or to continue performing commercial sexual activity, in order to avoid 
incurring that harm. 
421. This case does not involve mere fraud. Instead, JP Morgan's criminal 
conduct in aiding, abetting, and inducing Epstein's TVPA violations was outrageous 
and intentional, because it was in deliberate furtherance of a widespread and 
dangerous criminal sex trafficking organization. JP Morgan's criminal conduct 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 criminal 
conduct was directed specifically at Jane Doe 1 and other members of the Class, who 
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were the victims of Epstein's sexual abuse and sex trafficking organization. 
422. JP Morgan's outrageous and intentional conduct in this case is part of 
a pattern and practice of JP Morgan profiting by undertaking illegal "high risk, high 
reward" clients. 
423. By virtue of these knowing and intentional violations of 18 U.S.C. §§ 
1591(a)(1), 1595, JP Morgan is liable to Jane Doe 1 and the other members of the 
Class for the damages they sustained and reasonable attorneys' fees. 
424. By virtue of these intentional and outrageous violations of 18 U.S.C. §§ 
1591(a)(1), 1595, JP Morgan is liable to Jane Doe 1 and other members of the Class 
for punitive damages. 
COUNT VIII 
CONSPIRACY TO COMMIT VIOLATIONS OF THE TRAFFICKING 
VICTIM PROTECTION ACT, 18 U.S.C. §§ 1594(c), 1591, 1595 
425. Plaintiff Jane Doe I realleges and incorporates by reference paragraphs 
1 - 285, as if fully set forth in this Count. 
426. Jane Doe 1 brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
427. JP Morgan intentionally conspired with others, including Epstein and 
his other co-conspirators, by agreement and understanding, to violate 18 U.S.C. §§ 
1591(a)(1) & (a)(2) & 1591(d), and to further Epstein's sex-trafficking venture to 
coerce commercial sex acts from Jane Doe 1 and other Class Members, all in 
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violation of 18 U.S.C. § 1594(c). JP Morgan officers and employees (e.g., Staley) 
directly conspired with Epstein himself to further the sex-trafficking venture. 
428. JP Morgan's conspiracy to violate 18 U.S.C. 1591(a)(1) & (a)(2) was 
forbidden by 18 U.S.C. § 1594(c), and JP Morgan thereby violated Chapter 77, Title 
18. JP Morgan's conspiracy directly, proximately, and foreseeably harmed Jane Doe 
I, as well as other members of the Class, by directly leading to their forcibly being 
caused to engage in commercial sex acts and in other ways. JP Morgan's conspiracy 
victimized Jane Doe 1 and the other members of the Class. 
429. JP Morgan's conspiracy to violate 18 U.S.C. 1591(d) was forbidden by 
18 U.S.C. § 1594(c), and JP Morgan thereby violated Chapter 77, Title 18. JP 
Morgan's conspiracy directly, proximately, and foreseeably harmed Jane Doe 1, as 
well as other members of the Class, by directly leading to their forcibly being caused 
to engage in commercial sex acts and in other ways. JP Morgan's conspiracy 
victimized Jane Doe 1 and the other Members of the Class. 
430. JP Morgan conspired with Epstein and his other co-conspirators to 
further the Epstein sex-trafficking venture and with the purpose of facilitating 
Epstein's illegal sex trafficking. JP Morgan had actual knowledge of Epstein's sex-
trafficking venture. JP Morgan acted with the specific intent to violate 18 U.S.C. §§ 
1591(a)(1) & (a)(2), that is, with consciousness of the nature of Epstein's sex-
trafficking venture and with the specific intent to further venture. JP Morgan and 
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Epstein had a meeting of the minds as to the essential nature of the plan. 
431. JP Morgan's conspiracy with Epstein was part of its participation in his 
sex-trafficking venture. Without JP Morgan agreeing to facilitate the venture (by, 
for example, conspiring to keep the existence of cash disbursals secret), Epstein 
would not have been a position to move forward with his sex-trafficking venture and 
to recruit and entice victims of the venture. 
432. JP Morgan also conspired with Epstein and his other co-conspirators to 
obstruct, attempt to obstruct, to interfere with, and to prevent the enforcement of the 
TVPA, violating 18 U.S.C. § 1591(d). The conspiracy included an agreement to 
keep Epstein's sex-trafficking venture secret or, at least, concealed to the greatest 
extent possible. Among the means for keeping the venture secret were paying for 
the commercial sex acts in cash, structuring cash withdrawals in a way to avoid 
detection, and JP Morgan's failing to timely file SARs of Epstein's suspicious 
activities. 
433. Further actions regarding JP Morgan's conspiracy to obstruct TVPA 
enforcement are outlined in Count X (obstruction) below in paragraph 472-86, which 
are hereby incorporated by reference as if set forth in full in this Count. 
434. Within this District, JP Morgan intentionally committed overt acts in 
furtherance of the conspiracy, agreement, and understanding to violate 18 U.S.C. § 
1591(a) by knowingly playing an active role in assisting, supporting, and facilitating 
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the recruiting, enticing, coercing, harboring, transporting, and inducing and forcibly 
causing Jane Doe 1 and other Class Members to engage in commercial sex acts, 
through providing financial support for the Epstein sex-trafficking venture. A 
number of those acts were committed by JP Morgan's officer, Jes Staley, acting 
within the actual and apparent scope of his employment to further JP Morgan's 
interests. 
435. Among the many overt acts intentionally committed by JP Morgan in 
furtherance of the sex-trafficking venture were creating and maintaining a special 
and unusual financial relationship between JP Morgan and Epstein within this 
District designed to facilitate Epstein's sex-trafficking. The relationship went far 
beyond providing routine banking opportunities. 
436. Acting within this District and in furtherance of the Epstein sex-
trafficking venture, on or about August 19, 2013, JP Morgan opened various 
brokerage accounts for Epstein-related companies. JP Morgan knew, and should 
have known, that opening these accounts would facilitate Epstein's coercive sex 
trafficking. 
437. In furtherance of the Epstein sex-trafficking venture, between about 
200 and August 2013, JP Morgan opened numerous financial accounts for Epstein, 
his related entities, and associates. The accounts were in and affecting interstate and 
foreign commerce. These accounts were opened within this District. 
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438. In furtherance of the Epstein sex-trafficking venture, between about 
2000 and August 2013 and following, JP Morgan concealed its delivery of vast sums 
of cash to Epstein and his associates. Among its affirmative acts of concealment, JP 
Morgan willfully failed to timely file required SARs with the federal government. 
439. JP Morgan deliberately and purposely omitted to timely file appropriate 
SARs about Epstein's cash transactions, wrongful omissions that were actions in 
furtherance of its conspiracy. 
440. JP Morgan's actions in furtherance of Epstein's conspiracy were 
intertwined with Epstein's sex-trafficking venture, as the funding for the sex-
trafficking venture (and particularly cash for the venture) were essential tools for 
Epstein to commit coercive commercial sex acts. 
441. It was part of the conspiracy that JP Morgan would financially benefit 
from providing financial support for the Epstein sex-trafficking venture. JP Morgan 
did financially benefit from its participation in the venture, including receiving 
valuable deposits and business opportunities from Epstein. 
442. JP Morgan's participation in furthering Epstein's sex-trafficking 
venture 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 affirmative and overt acts supporting 
Epstein. JP Morgan knew, and was in reckless disregard of the fact, that means of 
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force, threats of force, fraud, coercion, and a combination of such means would be 
used by Epstein and his other co-conspirators to cause Jane Doe 1 and other Class 
Members to engage in commercial sex acts. 
443. JP Morgan knew, acted in reckless disregard of the fact, and should 
have known, that its conspiracy 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. 
444. The conspiracy that JP Morgan joined had specific knowledge that Jane 
Doe 1, as well as other Members of the Class, were being coercively sex trafficked 
by Epstein. The conspiracy's knowledge extended to the names of Epstein's victims, 
because Epstein and his co-conspirators knew the names of the victims, including 
Jane Doe l's name. JP Morgan, through its officer Jes Staley, also new many of the 
names of the victims. 
445. JP Morgan conspired to violate 18 U.S.C. § 1591(a) with Epstein and 
through its affirmative acts and substantial support to Epstein committed, 
perpetrated, and directly and proximately caused Jane Doe 1 and other Class 
Members to engage in commercial sex acts through means of force, threats of force, 
fraud, coercion, and a combination of such means. 
446. In addition to acting with knowledge that they were conspiring to 
support the Epstein sex-trafficking venture, JP Morgan benefited financially from 
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conspiring to participate in the Epstein sex-trafficking venture, which JP Morgan 
knew and should have known that had engaged in coercive sex trafficking in 
violation of 18 U.S.C. § 1591(a)(1) & (a)(2), as well as obstruction of the 
enforcement of the TVPA in violation of 18 U.S.C. § 1591(d). 
447. JP Morgan's conspiracy 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 conspiracy and the harm resulting from conspiracy was foreseeable. 
448. JP Morgan's conspiracy has caused Jane Doe 1 harm that is sufficiently 
serious, under all the surrounding circumstances, to compel a reasonable person of 
the same background and in the same circumstances to perform or to continue 
performing commercial sexual activity in order to avoid incurring that harm. 
449. This case does not involve mere fraud. Instead, JP Morgan's criminal 
conduct in conspiring to violate the TVPA was outrageous and intentional, because 
it was in deliberate furtherance of a widespread and dangerous criminal sex 
trafficking organization. JP Morgan's conspiracy 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 conspiracy was directed specifically 
at Jane Doe 1 and other members of the Class, who were the victims of Epstein's 
sex trafficking organization. 
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450. By virtue of these violations of 18 U.S.C. § 1594(c) 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. 
451. By virtue of its intentional and outrageous conspiracy to violate 18 
U.S.C. §§ 1594(c), JP Morgan is liable to Jane Doe 1 and other members of the Class 
for punitive damages under 18 U.S.C. § 1595. 
COUNT IX 
ATTEMPT TO COMMIT VIOLATIONS OF THE TRAFFICKING VICTIM 
PROTECTION ACT, 18 U.S.C. §§ 1594(a), 1591, 1595 
452. Plaintiff Jane Doe 1 realleges and incorporates by reference paragraphs 
1 - 285, as if fully set forth in this Count. 
453. Jane Doe 1 brings this Count individually and on behalf of the other 
Class Members she respectively seeks to represent. 
454. JP Morgan intentionally attempted to violate 18 U.S.C. § 1591(a)(1) 
and (a)(2), and to further Epstein's sex-trafficking venture to coerce commercial sex 
acts from Jane Doe 1 and other Class Members, all in violation of 18 U.S.C. § 
1594(a). 
455. JP Morgan officers and employees, including Staley, deliberately took 
substantial steps to attempt to violate 18 U.S.C. § 1591(a)(1) & (a)(2) within this 
District. 
456. JP Morgan deliberately took substantial steps toward attempting to 
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violate 18 U.S.C. § 1591(a)(1) & (a)(2), by providing substantial financial support 
for the Epstein sex-trafficking venture. The financial support included hundreds of 
thousands of dollars in cash. 
457. Among the many substantial steps taken by JP Morgan to deliberately 
attempt to violate 18 U.S.C. § 1591(a)(1) & (a)(2) were creating a special and 
unusual financial relationship between JP Morgan and Epstein within this District 
that was designed to, and did, facilitate Epstein's sex-trafficking venture and the sex 
trafficking of Jane Doe 1, as well as other Members of the Class. 
458. In attempting to further the Epstein sex-trafficking venture, between 
about 2000 and August 2013, JP Morgan opened numerous accounts for Epstein, his 
related entities, and associates. The accounts were in and affecting interstate and 
foreign commerce. JP Morgan opened the accounts within this District for the 
purpose of attempting to facilitate Epstein's sex-trafficking venture. 
459. In opening numerous accounts for Epstein, his related entities, and 
associates, JP Morgan took a substantial step toward benefitting from participating 
in Epstein's sex-trafficking venture. JP Morgan also took other substantial, concrete 
steps toward benefitting from the venture. 
460. It was part of the attempt to violate 18 U.S.C. 1591(a) that JP Morgan 
would financially benefit from participating in and providing financial support for 
the Epstein sex-trafficking venture. JP Morgan did financially benefit from its 
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participation in the venture, including receiving valuable deposits from Epstein and 
Epstein-related entities into JP Morgan. 
461. JP Morgan's attempt to violate the TVPA by furthering Epstein's sex-
trafficking venture was intentional and willful and, therefore, JP Morgan 
intentionally and willfully caused Epstein's commission of sexual abuse and 
commercial sex acts with Jane Doe 1 and other Class Members through its 
affirmative and overt acts supporting Epstein. 
462. JP Morgan knew and acted in reckless disregard of the fact, that its acts 
and conduct attempting to support and facilitate Epstein would lead to sexual abuse 
and unlawful coercive commercial sex acts by Epstein with young women and girls, 
including Jane Doe 1 and other Class Members. 
463. In addition to acting intentionally and with knowledge that they were 
supporting the Epstein sex-trafficking venture, JP Morgan benefited financially from 
attempting to participate in the Epstein sex-trafficking venture which JP Morgan 
should have known that had engaged in coercive sex trafficking in violation of 18 
U.S.C. § 1591(a)(1) & (a)(2). 
464. This case does not involve mere fraud. Instead, JP Morgan's criminal 
conduct in attempting to violate the TVPA was outrageous and intentional, because 
it was a deliberate attempt to further the crimes of a widespread and dangerous 
criminal sex trafficking organization. JP Morgan's criminal attempts also evinced a 
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