Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 1 of 130 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK JP Morgan Chase Bank, N.A., Defendant. Jane Doe 1, individually and on ) behalf of all others similarly ) CLASS ACTION COMPLAINT situated ) ) Plaintiffs, ) JURY TRIAL DEMANDED ) ) Vv. ) Case No.: 22-cv-10019-JSR ) ) ) ) / FIRST AMENDED INDIVIDUAL AND CLASS ACTION COMPLAINT Plaintiff Jane Doe | 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 seg.—the Trafficking Victim Protection Act (“TWPA”)—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 1 EFTA00162121

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 2 of 130 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 | makes the following allegations on information and belief and believes that substantial additional evidentiary support will exist for the allegations EFTA00162122

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 3 of 130 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 TVPA, 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 EFTA00162123

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 4 of 130 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-). II. PARTIES 7. Jane Doe | 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 | is also at serious risk of retaliatory harm because the co- conspirators who participated in the Epstein sex-trafficking venture had—and EFTA00162124

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 5 of 130 continue to possess—tremendous wealth and power and have demonstrated a clear ability to cause her serious harm. 10. Jane Doe 1’s safety, right to privacy, and security outweigh the public interest in her identification. 11. Jane Doe 1’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 | and also need to proceed anonymously for the same reasons. The identities of most of these other women are known to Defendant. 13. Defendant JP 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, EFTA00162125

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 6 of 130 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. Ill. 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, EFTA00162126

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 7 of 130 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 | 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 EFTA00162127

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 8 of 130 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, EFTA00162128

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 9 of 130 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 | 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, EFTA00162129

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 10 of 130 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 10 EFTA00162130

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 11 of 130 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. 11 EFTA00162131

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 12 of 130 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 12 EFTA00162132

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 13 of 130 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 13 EFTA00162133

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 14 of 130 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. Asaregistered 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 14 EFTA00162134

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 15 of 130 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 acommercial 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 ULS.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 15 EFTA00162135

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 16 of 130 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 | 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—.e., 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 16 EFTA00162136

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 17 of 130 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 17 EFTA00162137

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 18 of 130 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. 18 EFTA00162138

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 19 of 130 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. 19 EFTA00162139

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 20 of 130 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. Asanother 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. 20 EFTA00162140

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 21 of 130 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. Atall relevant times, Epstein maintained numerous apartment units at 301 East 66" 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 66" 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.C §§ 2422(b), 2423(f), 2423(b), 2424 (e); 18 U.S.C § 371; 18 U.S.C §§ 1591(c)(1), 1591(a)(1), 1591(a)(2); as well as state crimes in violation of Florida Statutes §§ 21 EFTA00162141

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 22 of 130 796.07 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. 22 EFTA00162142

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 23 of 130 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 23 EFTA00162143

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 24 of 130 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 24 EFTA00162144

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 25 of 130 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 1| was living with her mother when she met Jeffrey Epstein in 2006. 95. At that time, Jane Doe | 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 | 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 1. Epstein and his co-conspirators constantly reminded Jane Doe 1 how powerful and important Epstein was. Jane Doe 1 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 25 EFTA00162145

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 26 of 130 to believe what she was told. 97. The well-oiled Epstein sex abuse and trafficking venture included frequent statements to Jane Doe 1 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 1’s and other victims’ life necessities such as shelter or housing if she or they failed to perform those acts. 98. Jane Doe 1 was exceptionally vulnerable to being victimized by Epstein. His sex-trafficking venture targeted vulnerable young women and Jane Doe 1 was soon indoctrinated and unable to extricate herself. Jane Doe | 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 | 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 26 EFTA00162146

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 27 of 130 abused Jane Doe | 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 Plaintiffs 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 | 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 | to engage in commercial sex acts. 102. Epstein recruited Jane Doe | to cause and force her to engage in commercial sex acts in ways that were in and affecting interstate and foreign 27 EFTA00162147

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 28 of 130 commerce, including use of cell phones and means of interstate transportation (such as aircraft that he owned or controlled). 103. Epstein transported Jane Doe | 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 | 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 | 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 | to give massages to 28 EFTA00162148

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 29 of 130 certain of his powerful friends. During some of these massages Jane Doe | 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 | that he had Epstein’s permission to do what he wanted to her. Out of fear, Jane Doe | 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 | in many ways 29 EFTA00162149

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 30 of 130 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 | directly in cash obtained from JP Morgan for sex acts. 113. Epstein and his co-conspirators continued to coerce Jane Doe | in various ways until her ultimate escape around the end of 2013. 114. Epstein and his co-conspirators continued to coerce Jane Doe | 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 1’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 | 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 30 EFTA00162150

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 31 of 130 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 (“K YC”) 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 31 EFTA00162151

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 32 of 130 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 32 EFTA00162152

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 33 of 130 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 33 EFTA00162153

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 34 of 130 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 34 EFTA00162154

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 35 of 130 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 35 EFTA00162155

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 36 of 130 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, 36 EFTA00162156

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 37 of 130 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 37 EFTA00162157

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 38 of 130 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. IMPORTANT MESSAGE IMPORTANT MESSAGE 3 a 2 we EVE? (212) See nia MOBILE PLEASE CAL aaeeae = eae ceenet tae MESSAGE EFTA00162158

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 39 of 130 IMPORTANT MESSAGE IMPORTANT MESSAGE 7 7 RUSH =" Retunvep vouncaL| [sPecicarremion |_| aS ne nti Plezse Ca\\_me ——— ps os ae 149. On at least one occasion it appears Staley and Les Wexner called Epstein together. 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 39 EFTA00162159

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 40 of 130 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 EFTA00162160

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 41 of 130 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 41 EFTA00162161

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 42 of 130 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 | 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. 42 EFTA00162162

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 43 of 130 163. 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 43 EFTA00162163

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 44 of 130 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, 44 EFTA00162164

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 45 of 130 exclusively to JP Morgan because JP 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 45 EFTA00162165

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 46 of 130 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. 46 EFTA00162166

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 47 of 130 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 1 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. 47 EFTA00162167

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 48 of 130 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 | 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 | 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 | relies solely on her allegations. 48 EFTA00162168

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 49 of 130 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 | v. Deutsche Bank Aktiengesellschaft et al., Case No. 22-cv-10018-JSR, Amended Complaint (S.D.N.Y. Jan. 13, 2023). 49 EFTA00162169

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 50 of 130 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. 50 EFTA00162170

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 51 of 130 193. 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. 51 EFTA00162171

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 52 of 130 199. 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 JP Morgan 52 EFTA00162172

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 53 of 130 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. JP 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 53 EFTA00162173

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 54 of 130 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 54 EFTA00162174

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 55 of 130 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 55 EFTA00162175

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 56 of 130 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. 56 EFTA00162176

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 57 of 130 219. 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 57 EFTA00162177

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 58 of 130 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 58 EFTA00162178

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 59 of 130 at 301 East 66" 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 59 EFTA00162179

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 60 of 130 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 66" 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 60 EFTA00162180

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 61 of 130 capacity as an officer and employee of JP Morgan. All of the information contained in those emails is imputed to JP Morgan, including information about sexual and related topics. These emails show, among other things, the close personal relationship between Epstein and Staley, that Epstein and Staley communicated and visited while Epstein was incarcerated, and that Staley visited Epstein’s private island on multiple occasions. 234. Despite knowledge of Epstein’s illegal trafficking operation and the fact that one of JP Morgan’s top executives being so in bed with the operation, JP Morgan continued to aid Epstein in his sex trafficking enterprise. 235. JP Morgan, through its agents and employees such as Staley, had direct and specific knowledge that Epstein was operating a sex-trafficking venture and that he needed extraordinary banking infastructure from JP Morgan to successfully operate that illegal venture. 236. JP Morgan also knew that Sarah Kellen and Nadia Marcinkova, women with Epstein-facilitated bank accounts at JP Morgan whom Staley knew well, were involved in the trafficking. 237. Importantly, in January 2007, in the heart of the federal criminal investigation, Epstein trafficked Jane Doe | to the U.S. Virgin Islands where she was repeatedly raped. Not coincidentally, she was taken on Epstein’s private jet—the same one Staley traveled on—with Sarah Kellen and Nadia Marcinkova, the same 61 EFTA00162181

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 62 of 130 JP Morgan account-holding passengers Staley traveled with and who were identified by the U.S. Government as Epstein’s criminal co-conspirators. 238. JP Morgan also knew from the press that Epstein was a registered sex offender who was always surrounded by young girls. Even so, JP Morgan conspired with Epstein to assist him to operate the financial side of the sex-trafficking scheme. 239. JP Morgan knew, through Staley and other information, without any doubt that Epstein was a serial abuser and that sex-trafficking was his everyday lifestyle. JP Morgan also knew that without the bank’s complicity, Epstein could not pay for commercial sex acts, for co-conspirators, for his co-conspirators’ lawyers, for his own legal dream team, or for his private planes to traffic women to his New York mansion and island to abuse. 240. Numerous of Epstein’s co-conspirators had JP Morgan accounts tied to Epstein accounts. During the time when Kellen and Marcinkova were publicly outed as co-conspirators of Epstein’s, they each had JP Morgan accounts that were noted as Epstein-related accounts, putting JP Morgan on clear notice that the criminal organization Epstein was running through the bank was an expansive one of sexual abuse and trafficking. 241. MC2, the Epstein/Brunel modeling agency that was used to expand the trafficking scheme internationally, was funded through JP Morgan loans on Epstein accounts. This agency was started at a time when Brunel had already been publicly 62 EFTA00162182

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 63 of 130 ostracized from other known modeling agencies because he was a child sex abuser, a fact which JP Morgan was aware. 242. All of Epstein’s connections that were known to JP Morgan were either very wealthy individuals, companies that had no verifiable legitimate purpose, internationally known sex-abusing model scouts, publicly identified co-conspirators in the Epstein sex trafficking operation the crimes of which were identified in a public non-prosecution agreement, and young women and girls who could not possibly have a legal and legitimate connection to Epstein. JP Morgan knew all of this against the backdrop of their client—Epstein—having no professional expertise or legitimate business with legitimate banking needs. 243. JP Morgan worked with Epstein to open new accounts in the name of companies that had no plausible legitimate purpose, move money from one account to another to mask payments to sexual abuse victims or co-conspirators, make wire transfers to trafficking recruiters, and worked with Epstein’s agents to make his sex trafficking conspiracy less obvious to law enforcement authorities and others. 244. It is well known—and JP Morgan did know—that a large number of cash transactions by a customer can be an indicator of criminal activity generally and sex trafficking in particular, and JP Morgan knew Epstein was a sex trafficker constantly needing access to large amounts of cash. 245. Payments to victims of sex trafficking are often made in cash to avoid 63 EFTA00162183

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 64 of 130 leaving a “paper trail” for law enforcement or other investigators to follow. 246. Forced sexual exploitation of victims has been estimated to generate approximately $100 billion in yearly illicit profits, according to a recent study (2018) by the Financial Action Task Force entitled “Financial Flows from Human Trafficking.” 247. Given the illegal nature of sex trafficking, individuals perpetrating the crime, as well as laundering the proceeds of that crime, may be identifiable by observing financial transactions and information obtained by financial institutions in the course of conducting their customer due diligence and the behavior of offenders. 248. Sex trafficking organizations have the need for large amounts of cash because many illegal transactions are often necessary to keep the organization functioning. The techniques that financial institutions use to detect other criminal enterprises using their accounts can also be employed to detect sex trafficking. For example, sex trafficking organizations often use assets for money laundering (such as cash, real estate, cars, etc.) that other criminal organizations use. 249. Sex trafficking organizations may also make cash deposits and withdrawals below customer identification thresholds to avoid triggering additional scrutiny or bank reporting requirements. Sex trafficking organizations may also use multiple accounts to disguise the nature of their illegal transactions, thereby “laundering” the funds involved. 64 EFTA00162184

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 65 of 130 250. One indicator of sex trafficking can be media coverage of an account holder’s activities relating to sex trafficking. 251. Another indicator of sex trafficking can be recurring payments for transportation of logistics service in the late night or early morning. A similar indicator can be significant payments for transportation or logistics (car rental, taxi, and ride sharing service transactions). 4. Epstein used JP Morgan accounts for the sex-trafficking venture, and JP Morgan knowingly and directly benefits from the venture. 252. Over the course of the relationship, Epstein and his representatives used JP Morgan accounts to send dozens of wires, directly and indirectly, to co- conspirators in the sex-trafficking venture. 253. Over the course of the relationship, Epstein and his representatives also obtained vast sums of cash from JP Morgan to fund the sex-trafficking venture. 254. JP Morgan was aware that the recipients of some of these wire transfers and cash described in the previous paragraphs were to Epstein’s co-conspirators and that the wire and cash transfers were in furtherance of the Epstein sex-trafficking venture. 255. JP Morgan was aware that known co-conspirators of Epstein also had JP Morgan accounts. 256. Epstein used JP Morgan accounts to pay, through wire transfers and in cash, for coerced commercial sex acts by Jane Doe | and other Class Members. 65 EFTA00162185

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 66 of 130 257. Given JP Morgan’s knowledge about Epstein’s past sex trafficking, its continuation of its financial relationship with Epstein was, at a minimum, in reckless disregard of the fact that Epstein was using means of force, threats of force, fraud, coercion (and a combination of such means) to cause Epstein’s victims to engage in commercial sex acts. 258. Ifa financial institution decides to do business with a high-risk client, that institution is required to conduct due diligence commensurate with that risk and to tailor its transaction monitoring to detect suspicious or unlawful activity based on what the risk is. JP Morgan knowingly, intentionally, deliberately, and maliciously failed to do so with regard to its relationship with Epstein. 259. JP Morgan was well aware not only that Epstein had pled guilty and served prison time for engaging in sex with a minor but also that there were public allegations that his conduct was facilitated by several named co-conspirators. 260. Despite its knowledge, JP Morgan deliberately did little or nothing to inquire into or block numerous payments to named co-conspirators, and to or on behalf of numerous young women, or to inquire how Epstein was using hundreds of thousands of dollars per year in cash. JP Morgan intentionally failed to conduct this basic inquiry, knowing that an inquiry would reveal the sex-trafficking scheme. Instead, it chose to continue to financially benefit from its relationship with Epstein and his co-conspirators. 66 EFTA00162186

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 67 of 130 261. Hush money, financial compensation to recruiters, and compensation to victims was integral to Epstein’s scheme, without which his sex-trafficking conspiracy could not effectively operate. The ability to send wire transfers and cash to young females was critical to Epstein’s ability to coerce his victims into commercial sex acts. 262. Suspicious wire transfers and withdrawals of millions of dollars in cash are basic hallmarks of any major criminal enterprise. A bank that would allow Epstein to operate in this blatant criminal fashion was necessary for him to continue to operate his sex-trafficking conspiracy and for the continued abuse of hundreds of young women. 263. In January 2013 —the year JP Morgan terminated Epstein’s accounts— the Office of the Comptroller of the Currency (“OCC”) entered into a consent order with JP Morgan regarding deficiencies in the bank’s overall program for BSA/AML compliance. The OCC found that JP Morgan failed to develop adequate due diligence on customers and failed to comply with federal banking regulations. In fact, the OCC noted that JP Morgan “failed to identify significant volumes of suspicious activity.” 264. Before JP Morgan became Epstein’s banker, Epstein was only able to 2 See NYSDFA Consent Order at 2-4 (Jan. 14, 2013), https://occ.treas.gov/news-issuances/news-releases/2013/nr-occ-2013-8a.pdf. 67 EFTA00162187

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 68 of 130 abuse young women sporadically and in fear of being caught. Once JP Morgan became Epstein’s banker, it eliminated that fear, agreeing and conspiring with Epstein to ensure that the suspicious money trail that would reveal Epstein’s operation would be concealed. 265. JP Morgan’s desire to maintain its profitable relationship with Epstein led it to avoid taking steps that would have documented its involvement in Epstein’s sex-trafficking venture. 266. JP Morgan knowingly and intentionally benefited financially and in other ways from its participation in Epstein’s sex-trafficking venture, with knowledge, or with reckless disregard of the fact, that Epstein used means of force, threats of force, fraud, and coercion (and combinations thereof) to force young women and girls into engaging in commercial sex acts. 267. As recounted throughout this complaint, JP Morgan financially benefited by earning millions of dollars from its participation in the Epstein-sex- trafficking venture. The benefits that JP Morgan received came directly from its participation in the sex-trafficking venture and because of its participation in that venture. In other words, there was a causal relationship between JP Morgan’s conduct furthering Epstein’s sex-trafficking venture and its receipt of the financial benefits with actual (and constructive) knowledge of that causal relationship. 268. By facilitating and financing Epstein’s commercial sex acts in interstate 68 EFTA00162188

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 69 of 130 and foreign commerce, JP Morgan earned interest, commissions, fees, and other financial benefits directly from its connection with Epstein, Epstein-related entities, and others acting in concert with Epstein. Epstein provided those financial benefits to JP Morgan precisely because it was facilitating his sex-trafficking venture—and JP Morgan knew that was the reason that Epstein was providing them with those financial benefits. 269. JP Morgan benefited by receiving things of value from its participation in the Epstein sex-trafficking venture. Among the various things of value it received were (1) connections with Jeffrey Epstein, his co-conspirators, and his wealthy friends and associates; (2) additional deposits from Epstein, his co-conspirators, and his wealthy friends and associates; (3) the opportunity to earn financial benefits from the funds that had been deposited with it. JP Morgan knowingly and intentionally received these things of value as a direct result of its participation in the Epstein sex- trafficking venture and because it was furthering Epstein’s sex-trafficking venture. 270. JP Morgan knowingly and intentionally financed Epstein’s illegal sex- trafficking venture. JP Morgan knew that if it did not finance Epstein’s illegal sex- trafficking venture, then it would lose valuable Epstein-related accounts. Faced with the choice between profiting from Epstein’s sex-trafficking venture or following the law, JP Morgan chose to profit. 271. In violation of various banking laws and regulations, including various 69 EFTA00162189

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 70 of 130 “Know Your Customer” and anti-structuring laws, JP Morgan regularly authorized cash withdrawals and deposits for the Epstein sex-trafficking venture, which allowed Epstein, his co-conspirators, and those they directed to conduct the business of the sex-trafficking venture. 272. JP Morgan’s knowing and intentional banking law violations allowed Epstein and his various corporations to stay “under the radar” and continue the sex trafficking operation without close scrutiny or interference. 273. Among the young women and girls whose sex trafficking and sex abuse JP Morgan participated in, benefited from, aided and abetted, and furthered were Jane Doe | and the Class Members. D. The Statute of Limitations 274. The statute of limitations under the TVPA is ten years after the cause of action arose, or ten years after the victim reaches eighteen years of age, if the victim was a minor at the time of the alleged offense. 18 U.S.C. § 1595(c)(1), (2). The TVPA causes of actions for Jane Doe 1, and the other Class Members, arose within ten years of the filing of this complaint. Epstein’s sex-trafficking venture constituted a criminal conspiracy and a sex-trafficking venture that operated continuously from around 1998, through and including September 2013, and up to and following Epstein’s death in 2019. The conspiracy and venture undertook criminal actions in violation of the TVPA throughout those years, including 2013 70 EFTA00162190

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 71 of 130 and after, thereby automatically bringing all actions in furtherance of the conspiracy and venture within TVPA’s statute of limitations. 275. The New York Adult Survivors Act has opened up a one-year revival window for the statute of limitations regarding intentional and negligent torts connected to violations of the New York Penal Law Chapter 130. See New York State, Governor Hochul Signs Adult Survivors Act, Governor Kathy Hochul (May 24, 2022), — https://www.governor.ny.gov/news/governor-hochul-signs-adult- survivors-act (“For many survivors, it may take years to come to terms with the trauma of sexual assault and feel ready to seek just.”’). VI. CLASS ACTION ALLEGATIONS 276. Jane Doe 1 brings this action pursuant to Federal Rule of Civil Procedure 23(b)(3) and 23(c)(4) on behalf of herself and the following Class: All women who were sexually abused or trafficked by Jeffrey Epstein during the time when JP Morgan maintained bank accounts for Epstein and/or Epstein related-entities, which included January 1, 1998, through in or about August 2013, both dates inclusive, and continuing to the time of Epstein’s death on August 10, 2019 (the “Class Period”). 277. Jane Doe | reserves the right to seek leave to modify this definition, including the addition of one or more subclasses, after having the opportunity to conduct discovery. 278. Numerosity: The Class consists of dozens of women, making joinder impracticable, in satisfaction of Fed. R. Civ. P. 23(a)(1). The exact size of the Class 71 EFTA00162191

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 72 of 130 and the identities of the individual Class members are ascertainable through records maintained by the Epstein Estate and JP Morgan, including but not limited to JP Morgan’s records for Epstein-related accounts (e.g., account ledgers reflecting payments from Epstein to Class members). 279. Typicality: Jane Doe 1’s claims are typical of the claims of the other Class members she seeks to represent. The claims of Jane Doe | and the other Class members are based on the same legal theories and arise from the same unlawful pattern and practice of JP Morgan’s participation in, conspiring to join in, and funding of the Epstein’s sexual abuse and Epstein’s sex-trafficking venture. 280. Commonality: There are many questions of law and fact common to the claims of Jane Doe 1 and the other Class members, and those questions predominate over any questions that may affect only individual Class members, within the meaning of Fed. R. Civ. P. 23(a)(2) and (b)(3). Class treatment of common issues under Fed. R. Civ. P. 23(c)(4) will materially advance the litigation. 281. Common questions of fact and law affecting Class members include, but are not limited to, the following: a. Whether the Epstein sex-trafficking venture and conspiracy caused its victims to engage in commercial sex acts in violation of Trafficking Victims Protection Act, 18 U.S.C. § 1591(a)(1); b. Whether the Epstein sex-trafficking venture and conspiracy recruited, 72 EFTA00162192

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 73 of 130 enticed, solicited, harbored, provided, obtained, and transported victims in ways that were in or affecting interstate or foreign commerce; . Whether Epstein and his co-conspirators used means of force, fraud, coercion, and abuse of legal process, or a combination of such means, to sexually abuse the victims and to cause victims to engage in commercial sex acts; . Whether JP Morgan knowingly and intentionally assisted, facilitated, and supported the Epstein sex-trafficking venture’s pattern and practice of coercively forcing victims to engage in commercial sex acts; . Whether JP Morgan benefited financially or by receiving things of value from its participation in a venture which has engaged in sex trafficking in violation of TVPA, 18 U.S.C. § 1591(a)(1); . Whether JP Morgan knew or should have known that the Epstein sex- trafficking venture had engaged in violations of the TVPA, 18 U.S.C. § 1591(a); . Whether JP Morgan was part of conspiracy to violate 18 U.S.C. § 1591 (a), in violation of 18 U.S.C. § 1594(c); and . Whether JP Morgan committed intentional and negligent acts or omissions that facilitated sexual abuse which would constitute a sexual offense as defined in article 130 of New York Penal Law committed 73 EFTA00162193

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 74 of 130 against such persons who were eighteen years of age or older. 282. Absent a class action, most of the Class members would find the cost of litigating their claims to be cost-prohibitive and will have no effective remedy. The class treatment of common questions of law and fact is also superior to multiple individual actions or piecemeal litigation, in that it conserves the resources of the courts and the litigants and promotes consistency and efficiency of adjudication. 283. Adequacy: Jane Doe | will fairly and adequately represent and protect the interests of the other Class members she seeks to represent. Jane Doe 1 has retained counsel with substantial experience in prosecuting complex litigation and class actions. Jane Doe | and her counsel are committed to vigorously prosecuting this action on behalf of the other Class members and have the financial resources to do so. Neither Jane Doe | nor her counsel have any interests adverse to those of the other Class members. 284. This action has been brought and may properly be maintained as a class action against JP Morgan pursuant to Rule 23 of the Federal Rules of Civil Procedure because there is a well-defined community of interest in the litigation and the proposed Class is easily ascertainable from JP Morgan’s records. 285. Superiority: A class action is superior to all other available methods for the fair and efficient adjudication of this controversy because: a. Joinder of all Class Members is impracticable; 74 EFTA00162194

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 75 of 130 b. The prosecution of individual remedies by members of the Class will tend to establish inconsistent standards of conduct for JP Morgan and result in the impairment of Class Member’s rights and the disposition of their interests through actions to which they were not parties; . Class action treatment will permit a large number of similarly-situated persons to prosecute their common claims in a single forum simultaneously, efficiently, and without the unnecessary duplication of effort and expense that numerous individual actions would engender; . Absent a class action, Class Members will continue to suffer losses and be aggrieved and JP Morgan will escape liability for its criminal and tortious conduct and be able to continue to violate New York and federal law without remedy; . Class treatment of this action will cause an orderly and expeditious administration of class claims, economies of time, effort and expense will be fostered, and uniformity of decisions will be ensured; . Jane Doe | and her counsel are unaware of any class action brought against JP Morgan by victims for the violations alleged in this action; . The forum is desirable because Jane Doe 1 conducted the subject business with Jeffrey Epstein in this District and Class Members were consequently trafficked in this District; and, 75 EFTA00162195

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 76 of 130 h. This action presents no difficulty that would impede its management by the Court as a class action. VIL. CAUSES OF ACTION COUNT I AIDING, ABETTING, AND FACILITATING BATTERY 286. Plaintiff Jane Doe | realleges and incorporates by paragraphs | — 285, as if fully set forth in this Count. 287. Jane Doe | brings this Count individually and on behalf of the other Class Members she respectively seeks to represent. 288. Between about 1998 and 2013, in this District in New York, Jeffrey Epstein intentionally committed batteries and other intentional tortious conduct, including crimes in violation of New York Penal Law Chapter 130 such as New York Penal Law §§ 130.20, 130.35, 130.50, 130.52, and 130.66 (hereinafter “Chapter 130 crimes”), against Jane Doe | and the Class Members. Epstein committed the intentional tortious conduct and crimes against Jane Doe | and Class Members and when they were 18 or older. As described throughout this complaint, Epstein intentionally and non-consensually touched Jane Doe 1 and the Class Members in a harmful and offensive manner that resulted in substantial injuries, including damages from physical and psychological injury, extreme emotional distress, humiliation, fear, psychological trauma, loss of dignity and self-esteem, and 76 EFTA00162196

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 77 of 130 invasion of privacy. 289. The resulting injuries that Jane Doe 1 and the Class Members suffered include injuries directly and proximately suffered as a result of sex offenses committed by Epstein and other co-conspirators and criminalized under article 130 of the New York Penal Laws. The offenses included sexual intercourse without consent and oral sexual conduct without consent, forbidden by New York Penal Law § 130.20. The offenses included forcible touching of sexual or other intimate parts without consent, forbidden by New York Penal Law §§ 130.20, 130.35, 130.50, 130.52, and 130.66. 290. Regardless of when the tortious conduct (e.g., battery) and Chapter 130 Crimes were committed by Epstein, the conduct and crimes are now civilly actionable, regardless of any statute of limitations to the contrary, because they are covered by the one-year “look back” window in New York Adult Survivors Act. See N.Y. C.P.L.R. § 214-). 291. Between about 1998 and 2013, JP Morgan knowingly and intentionally aided, abetted, and facilitated Epstein’s intentional tortious conduct (e.g., battery), through Chapter 130 Crimes recounted in the preceding paragraphs of this Count. Because JP Morgan criminally aided, abetted, and facilitated Epstein’s conduct and crimes in violation of Chapter 130, it is vicariously and otherwise liable for damages caused by the conduct and crimes. 77 EFTA00162197

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 78 of 130 292. Between about 2000 and 2013, when it provided substantial assistance to Epstein, JP Morgan was well aware of its important and substantial role as a part of Epstein’s intentionally tortious and illegal activity in committing Chapter 130 Crimes. 293. As a direct and proximate result of Epstein’s tortious conduct and crimes, which JP Morgan knowingly and intentionally aided, abetted, and facilitated, Jane Doe | and the Class Members have in the past suffered, and in the future will continue to suffer, substantial damages, including damages from physical and psychological injury, extreme emotional distress, humiliation, fear, psychological trauma, loss of dignity and self-esteem, and invasion of her privacy. 294. At the time of Epstein’s batteries, intentionally tortious conduct, and crimes against Jane Doe | and the Class Members, JP Morgan was well aware of Epstein’s sex-trafficking venture and that its concrete steps in furtherance of the venture were aiding, abetting, and facilitating his batteries, tortious conduct, and crimes. 295. At the time of Epstein’s crimes against Jane Doe | and the Class Members, JP Morgan knowingly provided substantial assistance in Epstein’s tortious conduct and crimes. That knowing substantial assistance went beyond mere knowledge and approval of Epstein’s wrongdoing. For example, JP Morgan knowingly and intentionally provided the cash and the financial support that made 78 EFTA00162198

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 79 of 130 it possible for Epstein to commit the coercive sex offenses described in the preceding paragraphs in this Count. Without that cash and financial support, Epstein could not have committed his tortious conduct and crimes—a fact that JP Morgan knew. 296. JP Morgan knowingly and intentionally committed both substantial acts in support of Epstein and substantial deliberate omissions in support of Epstein. For example, JP Morgan deliberately omitted to take important steps (such as timely filing SARs) that substantially assisted Epstein to commit his crimes against Jane Doe 1 and Class Members in violation of New York Penal Law Chapter 130. 297. In aiding, abetting, and facilitating Epstein’s intentional tortious conduct and crimes, JP Morgan could readily foresee direct and proximate injury to Jane Doe | and the Class Member. JP Morgan should have foreseen direct and proximate injury from its actions and inactions to Jane Doe and the Class Members. Indeed, JP Morgan did foresee injury to Epstein’s victims, including Jane Doe 1 and Class Members. 298. In aiding, abetting, and facilitating Epstein’s tortious conduct and crimes, JP Morgan committed intentional torts directed against Jane Doe 1 and the Class Members. JP Morgan’s aiding, abetting, and facilitating Epstein’s tortious conduct and crimes were its own wrongful acts and omissions. JP Morgan had a duty not to commit tortious conduct and crimes—specifically aiding, abetting, and facilitating New York sex crimes as described above— directed against Jane 1 and 79 EFTA00162199

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 80 of 130 the Class Members. 299. Asaresult of the foregoing, JP Morgan is liable civilly for damages it directly, tortiously, and criminally caused to Jane Doe | and the Class Members. Jane Doe 1 and the Class Members according are entitled to bring a cause of action for damages for physical, psychological, or other injury or condition suffered as a direct and proximate result of JP Morgan’s aiding, abetting, and facilitating Epstein’s tortious conduct and crimes described above and for damages for physical, psychological, or other injury or condition suffered as a direct and proximate result of Epstein’s tortious conduct and crimes. 300. By virtue of acting intentionally, outrageously, and with a high degree of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal indifference to civil obligations, JP Morgan is liable to Jane Doe 1 and other Members of the Class for punitive damages. COUNT I INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 301. Plaintiff Jane Doe | realleges and incorporates by paragraphs | — 285, as if fully set forth in this Count. 302. Jane Doe | brings this Count individually and on behalf of the other Class Members she respectively seeks to represent. 303. As a direct and proximate result of aiding, abetting, and facilitating Epstein’s tortious conduct and sex crimes in violation of Chapter 130, JP Morgan 80 EFTA00162200

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 81 of 130 intentionally inflicted emotional distress against Jane Doe | and the Class Members. 304. JP Morgan’s actions, described above, constitute extreme and outrageous conduct that shocks the conscience. For example, JP Morgan intentionally and knowingly participated in Epstein’s sex-trafficking venture, as outlined above. JP Morgan had a legal duty not to participate in, facilitate, or aid and abet Epstein’s sex-trafficking venture and Epstein’s Chapter 130 Crimes. 305. JP Morgan’s conduct was especially extreme and outrageous due to Jane Doe 1 and the Class Members’ particular vulnerabilities as targets of a sex- trafficking venture. 306. JP Morgan intended to cause, and did cause, Jane Doe 1 and the Class Members severe emotional distress. At the very least, JP Morgan recklessly disregarded a substantial probability that its actions in aiding, abetting, and facilitating Epstein’s sex crimes would cause Jane Doe 1 and the Class Members severe emotional distress. 307. Because JP Morgan intentionally inflicted extreme emotional distress on Jane Doe | and the Class Members, it is liable to Jane Doe | and the Class Members for damages they suffered as a direct and proximate result. 308. As a direct and proximate result of JP Morgan’s conduct, Jane Doe 1 and the Class Members have in the past and will in the future continue to suffer substantial damages from psychological and physical injury, including extreme 81 EFTA00162201

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 82 of 130 emotional distress, humiliation, fear, psychological trauma, loss of dignity and self- esteem, and invasion of privacy. JP Morgan’s aiding, abetting, and facilitating Epstein’s sex crimes in violation of Chapter 130 directly and proximately caused Epstein’s sex crimes. 309. By virtue of acting intentionally, outrageously, and with a high degree of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal indifference to civil obligations, JP Morgan is liable to Jane Doe 1 and other Members of the Class for punitive damages. COUNT Il NEGLIGENT FAILURE TO EXERCISE REASONABLE CARE TO PREVENT PHYSICAL HARM 310. Plaintiff Jane Doe | realleges and incorporates by reference paragraphs 1 — 285, as if fully set forth in this Count. 311. Jane Doe 1 brings this Count individually and on behalf of the other Class Members she respectively seeks to represent. 312. In addition to any duties that might arise as a financial institution (alleged in the next Count, below), JP Morgan owed a duty to Jane Doe 1| and the Class Members to exercise reasonable care to avoid conduct that created a risk of physical harm to them. JP Morgan’s duties included a duty to exercise reasonable care to avoid conduct that would combine with Epstein’s crimes, and permit Epstein’s crimes, in violation of Chapter 130. 82 EFTA00162202

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 83 of 130 313. JP Morgan’s own conduct in providing financial and other support for Epstein’s sex trafficking venture set forces in motion that directly and proximately injured and caused physical harm to Jane Doe | and the Class Members. These forces that JP Morgan set in motion caused Epstein’s intentional tortious conduct and Chapter 130 Crimes against Jane Doe 1 and the Class Members, causing physical harm and in themselves constituted physical harm to Jane Doe | and the Class Members. JP Morgan owed Jane Doe | and the Class Members a duty not to set those forces in motion because they unreasonably created a risk of physical harm. 314. JP Morgan reasonably could foresee, and did in fact foresee, that its negligent failure to prevent physical harm would result in physical harm to Jane Doe 1 and the Class Members. JP Morgan owed a duty to prevent that physical harm. 315. JP Morgan failed to act objectively reasonably in failing to take precautions to prevent Epstein’s intentional tortious conduct and sex-trafficking and sex crimes in violation of Chapter 130, which were committed against Jane Doe 1 and the Class Members. If JP Morgan had acted reasonably to prevent physical harm, it would not have supported and allowed Epstein’s tortious conduct and sex- trafficking and sex crimes to occur. JP Morgan owed Jane Doe | and the Class members a duty to act objectively reasonably. 316. At the time of JP Morgan’s own negligent conduct, JP Morgan both realized and should have realized the likelihood that it was creating an opportunity 83 EFTA00162203

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 84 of 130 for Epstein to commit intentional tortious conduct and Chapter 130 Crimes against Jane Doe | and the Class Members. Indeed, JP Morgan knew that its own conduct was necessary to create Epstein’s opportunities to engage in that conduct and commit those crimes. JP Morgan owed Jane Doe | and the Class Members a duty not to create those opportunities for Epstein. 317. JP Morgan’s breaches of its legal duties were the direct—i.e., the but- for—cause of physical and psychological injuries to Jane Doe 1 and the Class Members. Without JP Morgan’s breaches of legal duties, those injuries would not have occurred. The injuries that occurred were readily foreseeable to JP Morgan. 318. Jane Doe 1 and the Class Members were easily within the zone of foreseeable harm from the JP Morgan’s negligent acts and omissions. JP Morgan’s negligent acts and omissions foreseeably created substantial risk of Jeffrey Epstein and his co-conspirators committing sex crimes against young women with whom he was in contact. Tragically, Jane Doe 1 and the Class Members fell within that zone. 319. Because of JP Morgan’s negligent failure to prevent physical harm to Jane Doe | and the Class Members, it is liable to Jane Doe 1 and the Class Members for damages suffered as a direct and proximate result. 320. As a direct and proximate result of JP Morgan’s negligent failure to prevent physical harm, Jane Doe | and the Class Members have in the past and will in the future continue to suffer substantial damages from psychological and physical 84 EFTA00162204

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 85 of 130 injury, including extreme emotional distress, humiliation, fear, psychological trauma, loss of dignity and self-esteem, and invasion of privacy. JP Morgan’s aiding, abetting, and facilitating Epstein’s tortious conduct and sex crimes in violation of Chapter 130 directly and proximately caused Epstein’s sex crimes. 321. By virtue of acting intentionally, outrageously, and with a high degree of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal indifference to civil obligations, JP Morgan is liable to Jane Doe | and other Members of the Class for punitive damages. COUNT IV NEGLIGENT FAILURE TO EXERCISE REASONABLE CARE AS A BANKING INSTITUTION PROVIDING NON-ROUTINE BANKING 322. Plaintiff Jane Doe | realleges and incorporates by reference paragraphs 1 — 285, as if fully set forth in this Count. 323. Jane Doe | brings this Count individually and on behalf of the other Class Members she respectively seeks to represent. 324. JP Morgan owed a duty to Jane Doe | and the Class Members not to knowingly provide non-routine banking support and assistance for Epstein that it knew, and reason to know, would lead to and support intentional tortious conduct and Chapter 130 Crimes by Epstein against Jane Doe 1 and the Class Members. 325. As described in detail above, JP Morgan did not merely provide routine banking support for Epstein. Instead, it participated in, aided and abetted, and 85 EFTA00162205

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 86 of 130 facilitating his sex-trafficking venture and his commission of intentional tortious conduct and Chapter 130 crimes. JP Morgan also knew, and was willfully blind to the fact, that it was going beyond providing routine banking support but instead facilitating Epstein’s sex-trafficking venture and his commission of tortious conduct and Chapter 130 crimes. 326. As an example, in providing hundreds of thousands of dollars in cash to Epstein and his co-conspirators in circumstances where it knew that the cash would be used to facilitate coercive sex acts, JP Morgan took substantial actions outside the scope of a routine, lawful, and ordinary customer relationship. 327. As another example, JP Morgan deliberately failed to follow numerous banking requirements in connection with financial dealings with Epstein, including AML rules, KYC rules, and anti-structing rules. In deliberately ignoring and failing to follow those rules, JP Morgan acted in a non-routine way to facilitate and support Epstein’s and his co-conspirators’ intentional torts, sex-trafficking, and commission of Chapter 130 Crimes. JP Morgan, through Staley, knew that Epstein was abusing females sexually on a daily basis and through that knowledge, developed a special relationship with Epstein. As a banking institution providing the necessary infrastructure to the sex trafficking operation, JP Morgan developed a special relationship with Epstein and thus undertook an obligation to protect others from his abuse. 86 EFTA00162206

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 87 of 130 328. Likewise, JP Morgan, acting through Staley, having observed Jane Doe 1 in circumstances indicating sexual abuse and trafficking, and whose relationship with Epstein was always maintained for the benefit of JP Morgan, owed a duty to protect the victims from the abuse of Jeffrey Epstein about which Staley, on behalf of JP Morgan, was well aware. 329. JP Morgan also owed Jane Doe | and the Class Members a duty of care because it affirmatively and intentionally chose not to investigate Epstein’s suspicious banking activities even after being confronted with explicit information that Epstein was using JP Morgan to further a sex-trafficking venture harming Jane Doe | and the Class Members. JP Morgan chose not to do so because it knew what the investigation would reveal, and that it would need to end its lucrative relationship with Epstein as a result of the investigation. Once JP Morgan had information about Epstein’s use of JP Morgan for a sex-trafficking venture, and once it knew or has reason to know that it was providing material support to that venture, it owed a duty of care to investigate suspicious banking activity. 330. But for JP Morgan, Epstein could not have successfully run and expanded his sexual abuse organization. Epstein could not have abused the hundreds of victims that he did without JP Morgan. 331. JP Morgan failed to act objectively reasonably by failing to comply with relevant banking laws and regulations with regard to its interactions with 87 EFTA00162207

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 88 of 130 Epstein and his co-conspirators. JP Morgan owed a duty to Jane Doe | and the Class Members to act objectively reasonably in its interactions with Epstein and his co- conspirators and to exercise reasonable care to prevent them from engaging in foreseeable tortious and criminal activity by using JP Morgan’s exceptional and non- routine banking infrastructure. 332. JP Morgan owed a legal duty to Jane Doe | and the Class Members to act objectively reasonably and to not deliberately ignore banking obligations, including KYC and AML laws and regulations described above, so as to provide Epstein and others with an opportunity to engage in tortious conduct, coercive sex- trafficking and Chapter 130 Crimes. 333. Under KYC, AML, and related laws and regulations, JP Morgan had special duties not ignore tortious conduct and crimes being committed by its customers—duties above and beyond any duties that the general public may have. The inquiries that banks must make include duties to inquire about specific individuals who banks know are being harmed. The regulations establish a duty of care that must be followed by banks, including JP Morgan. These duties exist at least in situations where a bank is knowingly going beyond offering routine banking for its customers and instead offers banking infrastructure specially adapted to facilitate tortious conduct and crimes. 334. JP Morgan also owed Jane Doe | and the Class Members a duty of care 88 EFTA00162208

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 89 of 130 because it knew, and had reason to know, that Epstein and his co-conspirators were using JP Morgan to facilitate a sex-trafficking venture, raising a duty to make a reasonable inquiry about suspicious activity. 335. JP Morgan owed Jane Doe 1 and the Class Member a duty not to deliberately and purposely fail to file SARs—filings which would have alerted federal authorities to Epstein’s and his co-conspirators’ illegal activities, including committing Chapter 130 Crimes. 336. JP Morgan also owed Jane Doe | and the Class Members a duty to prevent physical harm to them when confronted with explicit information that Epstein and his co-conspirators were using JP Morgan’s non-routine banking to further a sex-trafficking venture harming Jane Doe | and the Class Members. Once JP Morgan had information about Epstein’s use of JP Morgan for a sex-trafficking venture that was physically harming Jane Doe | and the Class Members, it owed them a duty of care to investigate and prevent Epstein’s and his co-conspirators’ suspicious, tortious, and criminal activities. 337. In the exercise of reasonable care, JP Morgan and its employees knew, and should have known, of the dangerous propensities of Jeffrey Epstein and his co- conspirators to commit intentional torts and violations of article 130 of New York Penal Law against women and girls with whom he was in close proximity, including Jane Doe | and the Class Members. 89 EFTA00162209

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 90 of 130 338. JP Morgan breached its legal duties to Jane Doe | and the Class Members as described above. JP Morgan’s breach of its duties led to it failing to prevent Epstein from committing intentional torts and Chapter 130 Crimes against Jane Doe 1 and the Class Members. JP Morgan realized that Epstein were committing intentional torts and Chapter 130 Crimes against Jane Doe | and the Class Members. The criminal activity that harmed Jane Doe 1 and the Class Members included foreseeable intentional torts as well as TVPA and Chapter 130 Crimes committed by the Epstein. 339. As a direct and proximate result of the breach of legal duties by JP Morgan, Jane Doe | and the Class Members repeatedly suffered direct and foreseeable injuries from Epstein and his co-conspirators, including injuries from federal and state sexual offenses (including sexual assaults) and resulting emotional distress, mental pain and suffering, and other physical, psychological, and other injuries. 340. The breaches of JP Morgan’s legal duties were the direct—i.e., the but- for—cause of these physical and psychological injuries to Jane Doe | and the Class Members. Without JP Morgan’s breaches of its legal duties, those injuries would not have occurred. The injuries that occurred were readily foreseeable to JP Morgan. 341. The injuries that Jane Doe 1 and the Class Members suffered included injuries directly and proximately suffered while they were adults who were present 90 EFTA00162210

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 91 of 130 in this District. These injuries are permanent in nature and Jane Doe | and the other Class Members will continue to suffer these losses in the future. 342. JP Morgan could reasonably foresee that their actions and omissions in facilitating Epstein’s sex trafficking enterprise would lead to intentional torts and sex offenses against Jane Doe land the Class Members. Indeed, JP Morgan was aware, and should have been aware, that Epstein was a high risk to commit sex offenses against young women and girls. 343. Jane Doe 1 and the Class Members were easily within the zone of foreseeable harm from JP Morgan’s negligent acts and omissions. JP Morgan’s acts and omissions foreseeably created substantial risk of Jeffrey Epstein and his co- conspirators committing intentional torts and sex crimes against young women with whom he was in contact. Tragically, Jane Doe 1 and the Class Members fell within that zone. 344. While the foregoing allegations easily make out a clear case of negligence, this case does not involve mere negligence. Instead, Defendants’ tortious conduct in this case evinced a high degree of moral turpitude and demonstrated such wanton dishonesty as to imply a criminal indifference to civil obligations. It also involved outrageous and intentional acts and omissions, because it was a deliberate attempt to further the crimes of a widespread and dangerous criminal sex trafficking organization. JP Morgan’s tortious conduct was directed 91 EFTA00162211

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 92 of 130 specifically at Jane Doe | and other Members of the Class, who were the victims of Epstein’s sexual abuse and sex trafficking organization. 345. Asa result of JP Morgan’s negligent actions and omissions described in this Count, Jane Doe 1 and the Class Members have sustained both general and specifical damages from physical and psychological injury in substantial amounts. 346. By virtue of acting intentionally, outrageously, and with a high degree of moral turpitude and demonstrating such wanton dishonesty as to imply a criminal indifference to civil obligations, JP Morgan is liable to Jane Doe 1 and other Members of the Class for punitive damages. COUNT V KNOWING BENEFICIARY IN A SEX-TRAFFICKING VENTURE IN VIOLATION OF THE TRAFFICKING VICTIMS PROTECTION ACT, 18 U.S.C. §§ 1591(a)(2), 1595 347. Plaintiff Jane Doe | realleges and incorporates by reference paragraphs 1 — 285, as if fully set forth in this Count. 348. Jane Doe | brings this Count individually and on behalf of the other Class Members she respectively seeks to represent. 349. JP Morgan knowingly and intentionally benefitted, financially and by receiving things of value, from participating in, assisting, supporting, and facilitating an illegal coercive 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)(2). 350. JP Morgan took many concrete steps to aid and participate in Epstein’s 92 EFTA00162212

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 93 of 130 sex-trafficking venture. Among the concrete steps that JP Morgan took to aid Epstein was providing vast sums of cash, which made the sex-trafficking venture possible. Providing Epstein with large sum of U.S. currency caused JP Morgan to receive financial benefits. JP Morgan’s willingness to provide large amounts of cash to Epstein was the quid pro quo for it receiving financial benefits from Epstein. 351. The cash that JP Morgan provided was necessary for Epstein to coerce Jane Doe | as well as other Class Members to engage in commercial sex acts. The cash directly formed part of the commercial nature of the sex acts. The cash was also a necessary and required part of Epstein’s recruitment of Jane Doe | and other victims of his sex-trafficking venture. By providing cash that JP Morgan knew would be used to fund the sex trafficking venture, JP Morgan actively participated in the recruitment of victims of the venture. 352. The cash that JP Morgan provided went far beyond providing routine banking opportunities for a client. It was far from routine for JP Morgan to provide substantial sums of cash per year to Epstein, who did not have an apparent legitimate need for such extravagant sums. Moreover, the circumstances in which Epstein was requesting such large amounts were far from routine and raised numerous “red flags”—taking it well outside routine circumstances. 353. JP Morgan providing large sums of cash to Epstein, under the circumstances of this case, was entirely inconsistent with the ordinary duties of a 93 EFTA00162213

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 94 of 130 bank or its employees. 354. The reason that JP Morgan ignored the numerous red flags about Epstein was to receive financial benefits from Epstein and his sex-trafficking venture. JP Morgan knew that it would gain far-from-routine financial benefits by ignoring the red flags associated with Epstein and by participating in his sex- trafficking venture. 355. Among the concrete steps that JP Morgan took to aid and participate in the Epstein sex-trafficking venture were opening up numerous accounts at JP Morgan for Epstein, his related entities, and associates. By opening these accounts, JP Morgan received many benefits from participating in Epstein’s venture. The opening of these accounts was affirmative conduct that caused JP Morgan to receive those benefits. 356. Among the concrete steps that JP Morgan took to aid the Epstein sex- trafficking venture, between about 2000 and continuing through about August 2013, JP Morgan concealed its delivery of vast sums of cash (likely hundreds of thousands of dollars) to Epstein and his associates. In order to benefit from the Epstein sex- trafficking venture, JP Morgan willfully failed to timely file required SARs with the federal government, because doing so would imperil its ability to profit from the sex-trafficking venture. JP Morgan’s concealment of the cash transactions caused it to receive financial benefits through continuation of the Epstein sex-trafficking 94 EFTA00162214

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 95 of 130 venture. 357. Among the concrete steps that JP Morgan took to aid the Epstein sex- trafficking venture were its failure to follow AML requirements. This failure was not just passive facilitation, but a deliberate omission by JP Morgan. This omission was specific act of concealment, which allowed Epstein to continue funding his sex- trafficking venture through suspicious transactions that would have otherwise been prevented. 358. By taking the concrete steps outlined above (along with the others alleged in this complaint), JP Morgan knowingly participated in sex trafficking and furthered the Epstein sex-trafficking venture. The concrete steps above constituted taking part in the sex-trafficking venture and were necessary for its success. The concrete steps above constituted active engagement by JP Morgan in Epstein’s sex- trafficking venture. 359. JP Morgan knowingly and intentionally benefited financially from, and received value for, its participation in the sex-trafficking venture, in which Epstein, with JP Morgan’s knowledge, or its reckless disregard of the fact, 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. 360. JP Morgan actually knew, through Staley and other officers and 95 EFTA00162215

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 96 of 130 employees, that it was participating in a particular sex-trafficking venture—i.e., the coercive Epstein sex-trafficking venture outlined above. JP Morgan’s knowledge went far beyond having an abstract awareness of sex trafficking in general. Indeed, JP Morgan discussed internally Epstein’s specific sex trafficking and the large amounts of cash that JP Morgan was giving him. Thus, JP Morgan did not simply fail to adequately detect signs of Epstein’s sex trafficking; it did detect multiple signs of Epstein’s coercive sex-trafficking venture and continued to participate in the venture. JP Morgan knew that the venture was on-going, which was why Epstein required vast sums of cash. 361. JP Morgan’s actions extend well beyond a situation of failing to train its staff about recognizing the warning signs of sex trafficking. JP Morgan’s employees did recognize the signs of Epstein’s sex trafficking. Indeed, JP Morgan’s employees knew about Epstein’s sex-trafficking venture. But JP Morgan decided to continue facilitating the Epstein sex-trafficking venture rather than ending its participation in the venture. 362. Among the signs that JP Morgan was facilitating Epstein’s sex trafficking venture were those facts that came to the attention of JP Morgan’s employees discussed above, which caused those employees to escalate issues regarding Epstein’s coercive sex-trafficking venture to more senior levels. 363. Among the signs that JP Morgan was facilitating Epstein’s sex 96 EFTA00162216

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 97 of 130 trafficking venture were those facts that came to the attention of JP Morgan were those facts that came to its attention through Jes Staley’s observations of Epstein’s sex trafficking. Because of those observations, Staley—and JP Morgan—knew toa certainty that Epstein was engaged in sex trafficking. 364. JP Morgan’s actual knowledge extended to the fact that specific individual women and girls were being coercively sex trafficked by Epstein between the time of his on-boarding and the termination of its relationship with Epstein. Even if JP Morgan did not know all the names of Epstein’s victims, it knew that specific victims (e.g., Jane Doe 1) of a specific trafficker (Epstein) at a specific time period (various dates between 2000-2013 and following) existed and were being forced to engage in commercial sex acts. It also knew that some of the victims had eastern European surnames. JP Morgan was on notice, and knew, that such victims were being coercively trafficked by Epstein’s sex-trafficking venture. 365. One of JP Morgan’s officers, Jes Staley, also knew the names of the many of Epstein’s sex trafficking victims. 366. JP Morgan helped to conceal the names of Epstein’s victims from the public and from law enforcement and prosecuting agencies by helping to conceal the existence of the sex-trafficking venture. Among the ways in which JP Morgan helped to conceal the venture’s existence was by providing the cash necessary for the venture to avoid leaving a visible “paper trail.” 97 EFTA00162217

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 98 of 130 367. JP Morgan’s concealment included failing to follow through on enhanced monitoring that was required for someone like Epstein. JP Morgan failed to implement that enhanced monitoring specifically to help conceal Epstein’s ongoing sex-trafficking. JP Morgan knew that if it implemented that enhanced monitoring, it would have to stop providing Epstein with the cash needed to run his sex-trafficking venture. 368. JP Morgan’s concealment included failing to file required SARs for Epstein’s suspicious cash transactions. 369. In addition to having actual knowledge that it was participating in Epstein’s sex trafficking venture, JP Morgan had constructive knowledge that it was participating in Epstein’s sex trafficking venture. JP Morgan also had constructive knowledge that Jane Doe 1, as well as other Members of the Class, were being coercively sex trafficked by Epstein. Its constructive knowledge extended to the names of Epstein’s victims, because Epstein and his associates knew the names of the victims. Staley also the knew the names of many of the victims. 370. JP Morgan had constructive knowledge of Epstein’s sex-trafficking venture because of specific acts by Epstein that put it on notice of a particular and ongoing sex trafficking venture. Among the specific acts were Epstein’s use of vast sums of cash in circumstances that prompted JP Morgan employees to specifically raise questions about Epstein’s sex-trafficking. 98 EFTA00162218

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 99 of 130 371. Also among the specific acts giving rise to constructive knowledge were the facts that associates of Epstein made numerous cash withdrawals from JP Morgan accounts. The circumstances of these withdrawals gave the bank notice that “structuring” was occurring to avoid alerting federal authorities. 372. Among the financial benefits that the JP Morgan received for participating in and facilitating Epstein’s sex-trafficking venture were the deposit of funds that Epstein and Epstein-controlled entities made to JP Morgan. JP Morgan profited from the use of these deposits. Epstein and Epstein-controlled entities deposited these funds in exchange for JP Morgan’s facilitation and participation in the sex trafficking venture, including its willingness to provide large amounts of cash in suspicious circumstances and to allow “structuring” of withdrawals to avoid triggering reporting requirements. 373. Among the financial benefits that JP Morgan received for participating in Epstein’s sex-trafficking venture was referral of business opportunities from Epstein and his co-conspirators. JP Morgan profited from these referred business opportunities. Epstein referred business entities and business opportunities to JP Morgan in exchange for its facilitation and participation in the sex trafficking venture. These referrals were a quid pro quo for JP Morgan’s participation in the sex-trafficking venture. 374. JP Morgan financially profited from the deposits made by Epstein and 99 EFTA00162219

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 100 of 130 Epstein-controlled entities and from the business opportunities referred to JP Morgan by Epstein in exchange for its facilitation and participation in Epstein’s sex trafficking venture. 375. JP Morgan knowingly received financial benefits in return for its assistance, support, and facilitation of Epstein’s sex-trafficking venture. JP Morgan knew that if it stopped providing assistance, support, and facilitation of Epstein’s sex-trafficking venture, it would no longer receive those benefits. 376. JP Morgan knew, and was in reckless disregard of the fact, that it was Epstein’s pattern and practice to use the channels and instrumentalities of interstate and foreign commerce, to entice, recruit, solicit, harbor, provide, obtain, and transport young women and underage girls for purposes of causing commercial sex acts, in violation of 18 U.S.C. § 1591(a)(1). 377. JP Morgan and its employees had actual knowledge that they were facilitating Epstein’s sexual abuse and sex trafficking conspiracy to recruit, solicit, entice, coerce, harbor, transport, obtain and provide Jane Doe | 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, and a combination of all these means. 378. Despite such knowledge, JP Morgan intentionally paid for, facilitated, 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, 100 EFTA00162220

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 101 of 130 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 1, 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 101 EFTA00162221

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 102 of 130 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 | 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 102 EFTA00162222

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 103 of 130 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 | 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 | 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 | realleges and incorporates by reference paragraphs 1 — 285, as if fully set forth in this Count. 391. Jane Doe | 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 103 EFTA00162223

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 104 of 130 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 | 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 104 EFTA00162224

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 105 of 130 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 1 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- 105 EFTA00162225

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 106 of 130 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 | 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. Plaintiff Jane Doe | realleges and incorporates by reference paragraphs 1 — 285, as if fully set forth in this Count. 406. Jane Doe | 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), JP 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). 106 EFTA00162226

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 107 of 130 408. 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 107 EFTA00162227

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 108 of 130 financially include Ghislaine Maxwell, Lesley Groff, 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 108 EFTA00162228

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 109 of 130 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 | 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 109 EFTA00162229

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 110 of 130 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 | 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 110 EFTA00162230

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 111 of 130 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 | 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 VII CONSPIRACY TO COMMIT VIOLATIONS OF THE TRAFFICKING VICTIM PROTECTION ACT, 18 U.S.C. §§ 1594(c), 1591, 1595 425. Plaintiff Jane Doe | realleges and incorporates by reference paragraphs 1 — 285, as if fully set forth in this Count. 426. Jane Doe | 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 | and other Class Members, all in 111 EFTA00162231

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 112 of 130 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 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 | 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 | 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 112 EFTA00162232

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 113 of 130 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 113 EFTA00162233

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 114 of 130 the recruiting, enticing, coercing, harboring, transporting, and inducing and forcibly causing Jane Doe | 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. 114 EFTA00162234

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 115 of 130 438. 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 115 EFTA00162235

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 116 of 130 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 | 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 | 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 1’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 116 EFTA00162236

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 117 of 130 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 | 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 | 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. 117 EFTA00162237

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 118 of 130 450. By virtue of these violations of 18 U.S.C. § 1594(c) JP Morgan is liable to Jane Doe | 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 | 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 | realleges and incorporates by reference paragraphs 1 — 285, as if fully set forth in this Count. 453. Jane Doe | 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 | 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 118 EFTA00162238

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 119 of 130 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 119 EFTA00162239

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 120 of 130 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 120 EFTA00162240

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 121 of 130 high degree of moral turpitude and demonstrated such wanton dishonesty as to imply a criminal indifference to civil obligations. JP Morgan’s criminal attempt was directed specifically at Jane Doe 1 and other members of the Class, who were the victims of Epstein’s sex trafficking organization. 465. JP Morgan’s conduct has caused Jane Doe 1 and other Class Members serious harm, including, without limitation, physical, psychological, financial, and reputational harm. This harm was a direct, proximate, and foreseeable result of JP Morgan’s attempt in violation of 18 U.S.C. § 1594(a). 466. By virtue of these violations of 18 U.S.C. § 1594(a), JP Morgan is liable to Jane Doe | and the other Members of the Class for the damages they sustained and reasonable attorneys’ fees under 18 U.S.C. § 1595. 467. By virtue of its intentional and outrageous attempt to violate 18 U.S.C. § 1594(a), JP Morgan is liable to Jane Doe 1 and other members of the Class for punitive damages under 18 U.S.C. § 1595. COUNT X OBSTRUCTION OF THE ENFORCEMENT OF THE TRAFFICKING VICTIM PROTECTION ACT, 18 U.S.C. § 1591(d) 468. Plaintiff Jane Doe | realleges and incorporates by reference paragraphs 1 — 285, as if fully set forth in this Count. 469. Jane Doe 1 brings this Count individually and on behalf of the other Class Members she respectively seeks to represent. 121 EFTA00162241

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 122 of 130 470. JP Morgan and its officers and employees (including Staley) knowingly and intentionally obstructed, attempted to obstruct, interfered with, and prevented the enforcement of 18 U.S.C. §§ 1591(a)(1) & (a)(2), all in violation of 18 U.S.C. § 1591(d). This activity is hereinafter referred to collectively simply as “obstruction.” 471. JP Morgan’s obstruction of the enforcement of 18 U.S.C. §§ 1591(a)(1) and (a)(2) was forbidden by 18 U.S.C. § 1591(d), and JP Morgan thereby violated Chapter 77, Title 18. JP Morgan’s obstruction described here and in the preceding paragraph directly, proximately, and foreseeably harmed Jane Doe 1, as well as other members of the Class, by directly resulting in them coercively being caused to engage in commercial sex acts and in other ways. 472. As outlined above, the United States Department of Justice (including the U.S. Attorney’s Office for the Southern District of New York and the U.S. Attorney’s Office for the Southern District of Florida) was investigating Epstein’s federal criminal liability for violating (among other laws) the TVPA up to and following the return of an indictment against Epstein on or about July 8, 2019. On or about that date, the U.S. Attorney’s Office for the Southern District of New York indicted Epstein (and unnamed “associates”) for violating the TVPA. Later, on about June 29, 2020, the same Office indicted Epstein’s co-conspirator, Ghislaine Maxwell, for conspiracy to entice minor victims to travel to be abused by Epstein. The federal criminal investigation of Maxwell included investigation of possible 122 EFTA00162242

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 123 of 130 violations of the TVPA. 473. By providing financing for Epstein’s sex trafficking organization from about 2000 through about August 2013, and concealing its actions thereafter, JP Morgan obstructed, interfered with, and prevented the federal government's enforcement of the TVPA against Epstein. To the extent that the federal government was able to ultimately charge Epstein with TVPA violations, the filing of those charges was delayed by JP Morgan’s actions. Because of that delay, Jane Doe | as well as other members of the Class, were coercively caused to engage in commercial sex acts. 474. As one example of how JP Morgan obstructed, attempted to obstruct, interfered with, and prevented the federal government’s enforcement of the TVPA, JP Morgan provided large amounts of cash to Epstein and his associates so that the coercive commercial sex acts would escape the detection of federal law enforcement and prosecuting agencies. JP Morgan provided large amounts of cash to further the Epstein sex-trafficking venture and with the purpose of helping Epstein evade criminal liability for violating the TVPA. 475. As another example of how JP Morgan obstructed, attempted to obstruct, interfered with, and prevented the federal government’s enforcement of the TVPA, JP Morgan did not follow AML and anti-structuring reporting requirements found in the Banking Secrecy Act and other laws. These requirements included an 123 EFTA00162243

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 124 of 130 obligation that JP Morgan would review transactions in the Epstein’s JP Morgan accounts for a determination of whether they involved suspicious transactions. If JP Morgan had observed these requirement imposed by law, then it would have prevented many of the subsequent transactions committed by the Epstein sex- trafficking venture. JP Morgan knowingly did not follow these requirements because it knew that doing so would have prevented Epstein’s secret cash transactions that were necessary to his sex-trafficking operation escaping knowledge of federal investigative and prosecuting agencies. Without JP Morgan’s cash, Jane Doe 1, as well as other members of the Class, would not have been coercively forced to engage in commercial sex act. 476. As another example of how JP Morgan obstructed, attempted to obstruct, interfered with, and prevented the federal government’s enforcement of the TVPA, JP Morgan failed to timely file with the federal government the required SARs that financial institutions must file with FinCEN whenever there is a suspected case of money laundering or fraud. Timely filing of these reports is required by the Bank Secrecy Act and related laws and regulations. These reports are tools that the federal government uses to detect and prosecute, among other illegal activities, sex trafficking in violation of the TVPA. By failing to timely file the required SARs regarding Epstein’s cash transactions, JP Morgan obstructed, attempted to obstruct, interfered with, and prevented the federal government’s enforcement of the TVPA 124 EFTA00162244

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 125 of 130 by concealing from the federal government’s attention Epstein’s cash transaction in aid of sex trafficking. 477. JP Morgan can disclose its failure to file appropriate SARs without disclosing the existence of a SAR. JP Morgan is not protected from liability for failure to file a required SAR. 478. JP Morgan’s failure to timely file SARs about Epstein’s sex-trafficking venture, in spite of numerous red flags, was wrongful and purposeful. 479. If JP Morgan had filed timely required SARs about Epstein’s sex- trafficking venture with the federal government, the appropriate federal agencies would have been well positioned to investigate Epstein’s sex-trafficking venture’s TVPA violations. JP Morgan’s failure to timely file the required SARs obstructed the federal government’s ability to investigate those TVPA violations, including violations harming Jane Doe | and other Class Members. If JP Morgan had timely filed the required SARs, it would have prevented the continuation of Epstein’s sex trafficking venture, which required the ability to secretly use cash to payoff victims. 480. By providing large amounts of cash to Epstein and his associates, JP Morgan intended and knew that Epstein’s coercive commercial sex acts would escape the detection of federal law enforcement and prosecuting agencies for some period of time. JP Morgan provided large amounts of cash to further the Epstein sex-trafficking venture and with the purpose of helping Epstein evade criminal 125 EFTA00162245

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 126 of 130 liability for violating the TVPA. 481. JP Morgan’s obstruction, attempted obstruction, interference with, and prevention of the enforcement of the TVPA were all done intentionally and knowingly. For example, JP Morgan knew that Epstein was high risk—specifically, high risk to violate the TVPA through continuing criminal sex trafficking activities. 482. JP Morgan was well aware that Epstein had pleaded guilty and served prison time for engaging in sex with a minor—a crime closely connected with sex trafficking in violation of the TVPA. JP Morgan was also well aware that there were public allegations that his illegal conduct was facilitated by several named co- conspirators. But JP Morgan concealed from the federal government its numerous cash payments to those co-conspirators. JP Morgan continued its affirmative conduct of providing cash to Epstein so that he could make those cash payments to his co- conspirators with knowledge that such cash transaction did not produce a clear paper trail. JP Morgan’s intentional conduct obstructed, attempted to obstruct, in many ways interfered with, and prevented the enforcement of the TVPA by federal investigators and prosecuting agencies. 483. JP Morgan’s relationship with Epstein in providing to his sex- trafficking venture with vast sums of cash each year went far beyond a normal (and lawful) banking relationship. JP Morgan knew, and intended, that its relationship with Epstein would go far beyond a normal banking relationship. JP Morgan knew 126 EFTA00162246

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 127 of 130 that its decision to beyond a normal banking relationship with Epstein obstructed the ability of federal law enforcement and prosecuting agencies to enforce the TVPA. 484. JP Morgan’s obstruction of the federal government’s TVPA and other law enforcement efforts was intentional and willful and, therefore, JP Morgan intentionally and willfully caused Epstein’s commission of the forcible commercial sex acts with Jane Doe | and other Class Members through its obstruction supporting the concealment of Epstein’s sex-trafficking venture. JP Morgan knew that Epstein and his other co-conspirators would use means of force, threats of force fraud, coercion, and a combination of such means to cause Jane Doe | and Class Members to engage in commercial sex acts. 485. JP Morgan knew, acted in reckless disregard of the fact, and should have known, that its obstruction in violation of 18 U.S.C. § 1591(d) would directly and proximately lead to unlawful coercive commercial sex acts by Epstein with young women and girls, including Jane Doe | and other Class Members. 486. JP Morgan’s obstruction has caused Jane Doe 1 and other Class Members serious harm, including, without limitation, physical, psychological, financial, and reputational harm. That harm was directly and proximately caused by the obstruction and the harm resulting from obstruction was foreseeable. 487. JP Morgan’s obstruction has caused Jane Doe | harm that is sufficiently serious, under all the surrounding circumstances, to compel a reasonable person of 127 EFTA00162247

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 128 of 130 the same background and in the same circumstances to perform or to continue performing commercial sexual activity in order to avoid incurring that harm. 488. This case does not involve mere fraud. Instead, JP Morgan’s criminal conduct in obstructing enforcement of the TVPA was outrageous and intentional, because it was in deliberate furtherance of a widespread and dangerous criminal sex trafficking organization. JP Morgan’s obstruction also evinced a high degree of moral turpitude and demonstrated such wanton dishonesty as to imply a criminal indifference to civil obligations. JP Morgan’s obstruction was directed specifically at Jane Doe | and other members of the Class, who were the victims of Epstein’s sex trafficking organization. 489. By virtue of these violations of 18 U.S.C. § 1591(d), JP Morgan is liable to Jane Doe | and the other Members of the Class for the damages they sustained and reasonable attorneys’ fees by operation of 18 U.S.C. § 1595. JP Morgan perpetrated an obstruction of the TVPA, and therefore perpetrated a violation of Chapter 77, Title 18. 490. By virtue of its intentional and outrageous obstruction to prevent enforcement of the TVPA, in violation 18 U.S.C. § 1591(d), JP Morgan is liable to Jane Doe | and other members of the Class for punitive damages by operation of 18 U.S.C. § 1595. VIII. REQUEST FOR RELIEF 128 EFTA00162248

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 129 of 130 Jane Doe | respectfully requests that the Court enter judgment in her favor, and against JP Morgan, as follows: a. That the Court certify the Class, name Jane Doe 1 as Class Representative, and appoint her lawyers as Class Counsel; b. That the Court award Plaintiff and the other members of the Class compensatory, consequential, general, nominal, and punitive damages against Defendant in an amount to be determined at trial; c. That the Court award punitive and exemplary damages against Defendant in an amount to be determined at trial; d. That the Court award to Plaintiff the costs and disbursements of the action, along with reasonable attorneys’ fees, costs, and expenses; e. That the Court award pre- and post-judgment interest at the maximum legal rate; and f. That the Court grant all such other and further relief as it deems just and proper. JURY DEMAND Plaintiffs demand a trial by jury on all claims so triable. Dated: January 13, 2023 Respectfully Submitted, EDWARDS POTTINGER, LLC By: /s/ Bradley Edwards 129 EFTA00162249

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Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 130 of 130 130 Bradley J. Edwards 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954)-524-2820 Fax: (954)-524-2822 Email: brad@epllc.com EDWARDS POTTINGER Brittany N. Henderson 1501 Broadway Floor 12 New York, NY (954)-524-2820 Fax: (954)-524-2820 Email: brittany@epllc.com David Boies Boies Schiller Flexner LLP 55 Hudson Yards New York, New York Telephone: (212) 446-2300 Facsimile: (212) 446-2350 E-mail: dboies@bsfllp.com Sigrid McCawley Pro Hac Vice Boies Schiller Flexner LLP 401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL 33316 Telephone: (954) 356-0011 Facsimile: (954) 356-0022 Email: smccawley@bsfllp.com EFTA00162250

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Case 1:22-cv-10019-JSR Document 36-1 Filed 01/13/23 Page 1 of 123 Exhibit 1 To Plaintiff, Jane Doe’s Amended Complaint against JPMorgan Chase Bank, N.A. EFTA00162251

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Céss4:222.¢1.00PD49S8R Dinoumeted Aled OW/IG23 Page 2 af 323 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED ) Case Number: 1:22-cv-10904 JSR STATES VIRGIN ISLANDS ) ) ACTION FOR DAMAGES PLAINTIFF, ) ) JURY TRIAL DEMANDED V. ) ) JPMORGAN CHASE BANK, N.A. ) ) DEFENDANT. ) FIRST AMENDED COMPLAINT AND DEMAND FOR A JURY TRIAL Plaintiff Government of the United States Virgin Islands (“Government”) files this Complaint against JPMorgan Chase Bank, N.A. (“JP Morgan”) for violations of Trafficking Victims Protection Act, 18 U.S.C. $§ 1591 to 1595, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 600 to 614, and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A V.LC. §§ 301 to 336, and in support thereof alleges as follows: PARTIES 1. The Attorney General of the United States Virgin Islands (hereinafter “Virgin Islands”) brings this parens patriae action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 15 U.S.C. § 1595(d) and 3 V.LC. § 114 and her statutory authority to enforce the laws of the Virgin Islands and protect public safety. 2. The Attorney General, pursuant to her authority to represent the Government of the United States Virgin Islands, also acts on behalf of, and with the lawfully delegated authority of, the Virgin Islands Department of Licensing and Consumer Affairs under 12 V.I-C. § 327 in regard to Count Four of the Government’s Complaint alleging violations of the Virgin Islands Consumer EFTA00162252

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Céss4:222.¢1.00P049S8R Dinoumeted Aled OMWIG23 Page 2 af I23 Fraud and Deceptive Business Practices Act. 3. This action stems from an enforcement action the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey Epstein (“Epstein”), under the Virgin Islands’ Criminally Influenced and Corrupt Organizations Act (“CICO Act’), see Government of the U.S. Virgin Islands v. Indyke et al., Case No. ST-20- CV-14 (Super. Ct. V.I. Jan. 15, 2020). The Attorney General brings this action, after presenting her findings to JP Morgan in September 2022, in her ongoing effort to protect public safety and to hold accountable those who facilitated or participated in, directly or indirectly, the trafficking enterprise Epstein helmed. The investigation revealed that JP Morgan knowingly, negligently, and unlawfully provided and pulled the levers through which recruiters and victims were paid and was indispensable to the operation and concealment of the Epstein trafficking enterprise. Financial institutions can connect—or choke—human trafficking networks, and enforcement actions filed and injunctive relief obtained by attorneys general are essential to ensure that enterprises like Epstein’s cannot flourish in the future. 4. Defendant JPMorgan Chase Bank, N.A. is an American multinational investment bank and financial services company headquartered in New York City and incorporated in Delaware. 5. At all relevant times, JP Morgan engaged in business in the Virgin Islands, including, but not limited to, the acts and practices described herein. 6. As described below, based on documents reviewed and interviews conducted by the Government, JP Morgan knowingly facilitated, sustained, and concealed the human trafficking network operated by Jeffrey Epstein from his home and base in the Virgin Islands, and financially benefitted from this participation, directly or indirectly, by failing to comply with federal banking EFTA00162253

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Céss4:222\cL00PD40S8R DBnoureted Filed OWIG23 Page 3 afI23 regulations, BY JP Morgan facilitated and concealed wire and cash transactions that raised suspicion of—and were in fact part of—a criminal enterprise whose currency was the sexual servitude of dozens of women and girls in and beyond the Virgin Islands. Human trafficking was the principal business of the accounts Epstein maintained at JP Morgan. 7. Upon information and belief, JP Morgan turned a blind eye to evidence of human trafficking over more than a decade because of Epstein’s own financial footprint, and because of the deals and clients that Epstein brought and promised to bring to the bank. These decisions were advocated and approved at the senior levels of JP Morgan, including by the former chief executive of its asset management division and investment bank, whose inappropriate relationship with Epstein should have been evident to the bank. Indeed, it was only after Epstein’s death that JP Morgan belatedly complied with federal banking regulations regarding Epstein’s accounts. JURISDICTION, VENUE, AND RELATED CASE 8. This action is brought pursuant to and based on federal and Virgin Islands statutes, including the federal Trafficking Victims Protection Act, 18 U.S.C. §§ 1591 to 1595 (“TVPA”), and the federal Bank Secrecy Act, 31 U.S.C. §§ 5311 to 5336 and its implementing regulations (“BSA”). 9. This Court has federal question subject-matter jurisdiction pursuant to 28 U.S.C. § 1331 because the Government's TVPA and BSA-based causes of action arise under federal law. 10. This Court has supplemental jurisdiction over the Government's Virgin Islands law claims pursuant to 28 U.S.C. § 1367(a) because these claims are so related to those arising under or based on federal law as to form part of the same case or controversy under Article III of the United States Constitution. EFTA00162254

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Céss4:222.¢1.00PD4S8R Dinoumeted Aled OMWIG23 Page 5 af I23 11. This Court is an “appropriate district court of the United States” in which for the Government to obtain appropriate relief under 18 U.S.C. § 1595(d) and venue is proper under 28 U.S.C. § 1391(b)(2) because Defendant maintains its principal place of business within this judicial district, so that this Court may exercise general personal jurisdiction over Defendant, and because many of the alleged acts and omissions of Defendant giving rise to the Government's claims took place within this judicial district, so that this Court may exercise specific personal jurisdiction over Defendant. 12. Pursuant to Local Civil Rule 1.6(a), the undersigned believe that this action is related to Doe | v. JP Morgan Chase & Co., No. 1:22-cv-10019 (S.D.N.Y. Nov. 24, 2022), because both actions arise from a common nucleus of operative fact involving Defendant JP Morgan’s alleged participation, directly or indirectly, in Epstein’s sex-trafficking venture by facilitating payments to women and girls, channeling funds to Epstein to fund the operation, and concealing Epstein’s criminal conduct by failing to comply with federal banking regulations. BACKGROUND IL JP Morgan’s Federal and State Legal Requirements 13. JP Morgan is subject to federal laws, including the BSA and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, Pub. L. No. 107-56, 115 Stat. 272 (“USA PATRIOT Act”), which amended certain BSA regulations. 14. Under both the BSA and USA PATRIOT Act, JP Morgan is required to implement adequate, risk-based anti-money laundering (“AML”) policies and systems to detect and prevent money laundering or other use of the institution’s services to facilitate criminal activities. This includes, but is not limited to, maintaining a due diligence program, filing suspicious activity EFTA00162255

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Céss4:222.¢1.00P049S8R Donoumeted Aled OWIG23 Page 5 af 323 reports (“SARs”) when the financial institutions detect suspicious behavior and currency transaction reports (“CTRs”) for currency transactions or series of currency transactions that exceed $10,000 in a 24-hour period, preventing structuring or assistance with structuring of transactions undertaken for the purpose of evading federal reporting requirements, and maintaining systems to prevent money laundering. 15. The FDIC and the other federal banking regulators, including the Federal Reserve Board and Office of the Comptroller of the Currency, formed an interagency organization known as Federal Financial Institutions Examination Council (“FFIEC”). 16. To provide further guidance to banks on what BSA compliance requires, FFIEC published a Bank Secrecy Act/Anti-Money Laundering Examination Manual (“BSA Manual”). The BSA Manual explains that an effective SAR program is essential: Suspicious activity reporting forms the cornerstone of the BSA reporting system. It is critical to the United States’ ability to utilize financial information to combat terrorism, terrorist financing, money laundering and other financial crimes. Examiners and banks should recognize that the quality of SAR content is critical to the adequacy and effectiveness of the suspicious activity reporting system.! 17. Pursuant to the BSA Manual, “[p]roper monitoring and reporting processes are essential to ensuring that the bank has an adequate and effective BSA compliance program. Appropriate policies, procedures, and processes should be in place to monitor and identify unusual activity.” When a bank detects suspicious activity, it is required to report that information within 30 days to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”). The reporting requirement ensures that the government is able to monitor and act ' FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual, Suspicious Activity Reporting at 1 (2014) https://bsaaml.ffiec.gov/docs/manual/06_AssessingCompliance WithBSARegulatory Requirement s/04.pdf. 7 Id. at 2. EFTA00162256

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Céss4:222.¢1.00PD049S8R Donoumeted Aled OWIG23 Page ¢ af I23 when alerted to potential illegal conduct. 18. Appendix F of the BSA Manual includes examples of suspicious transactions that may indicate money laundering, terrorist financing, or fraud, including: a. Funds transfer activity is unexplained, repetitive, or shows unusual patterns; b. The currency transaction patterns of a business show a sudden change inconsistent with normal activities; c. Unusual transfers of funds occur among related accounts or among accounts that involve the same or related principals: d. Currency is deposited or withdrawn in amounts just below identification or reporting thresholds; e. Regarding nonprofit or charitable organizations, financial transactions occur for which there appears to be no logical economic purpose or in which there appears to be no link between the stated activity of the organization and the other parties in the transaction; f. Funds are sent or received via international transfers from or to higher-risk locations. 19. In addition, the CICO Act, 14 V.LC. § 600, incorporates violations of Virgin Islands Law and federal felonies, which includes the BSA’s criminal-liability provisions. IL. Jeffrey Epstein’s Criminal Conduct 20. Jeffrey Epstein was a resident of the Virgin Islands. 21. In 2008, Epstein pled guilty to one count of solicitation of prostitution with a minor in Palm Beach, Florida. As a result of that conviction, Epstein was forced to register as a sex offender in the Virgin Islands. EFTA00162257

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Céss4:2221¢1.00PD40S8R Donoumeted Ried OWIG23 Page B af I23 22. Epstein was a Tier | offender under Virgin Islands law based upon his Florida conviction of procuring a minor for prostitution. 23. On January 15, 2020, the Government filed a lawsuit against Jeffrey Epstein’s estate and related individuals and entities for violation of the CICO Act, 14 V.LC. §§ 600 to 614, and civil conspiracy, which the Government recently settled. As laid out in the Government's Second Amended Complaint, ST-20-CV-14, (“SAC”) (attached as Exhibit 1), Epstein created a network of companies and individuals who participated in, directly or indirectly, and conspired with him in a pattern of criminal activity related to the sex trafficking, forced labor, sexual assault, child abuse, and sexual servitude of these young women and children. SAC {{[ 43-75. Epstein and his associates trafficked underage girls to the Virgin Islands, held them captive, and sexually abused them, causing them grave physical, mental, and emotional injury. /d. 24. — To accomplish this criminal activity, Epstein formed an association in fact with both companies and non-profit organizations that he owned and operated, as well as individuals, who were willing to participate in, directly or indirectly, facilitate, and conceal Epstein's criminal activity in exchange for Epstein's bestowal of financial and other benefits, including sexual services and forced labor from victims. /d. {[ at 157-195. 25. —_ In October 2012, the Southern Trust Company—one of the companies Epstein owned—applied for economic benefits from the Virgin Islands Economic Development Commission (“EDC”) so the company could provide “cutting edge consulting services” in the area of “biomedical and financial informatics.” /d. J] 157-158. Southern Trust Company received a 10- year package of economic incentives running from February 1, 2013 until January 31, 2023 that included a 90% exemption from income taxes and 100% exemptions from gross receipts, excise, and withholding taxes in the Virgin Islands. /d. {[ 159. EFTA00162258

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Céss4:222.¢1.00PD49S8R Dinoumeted Aled OMVIG23 Page 8 af 323 26. Southern Trust, in fact, appeared to perform no informatics or data-mining services during this period. Instead, Southern Trust funded the Epstein Enterprise (defined below), acting as a conduit for payment to foreign women, credit cards, airplanes and other instrumentalities. /d. ql 167-173. 27. This illicit association of Epstein, businesses, and his associates constitutes what is referred to herein as the “Epstein Enterprise.” Specifically included in the Epstein Enterprise were the following companies and non-profit organizations, all of which had accounts with JP Morgan: 2013 Butterfly Trust, Coatue Enterprises, LLC, C.O.U.Q. Foundation, Enhanced Education, Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, LLC, NES, LLC, Plan D, LLC, Southern Financial, LLC, and Southern Trust Company. 28. Epstein used his wealth and power to create the Epstein Enterprise, which engaged in a pattern of criminal activity by repeatedly procuring and subjecting underage girls and young women to unlawful sexual conduct, sex trafficking, and forced labor. 29. Many of these women, particularly after Epstein’s conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to marry other Epstein victims in order to maintain their immigration status and their availability to Epstein. /d. J{[ 62- 63, 78, 86. 30. — Asalso alleged in the Second Amended Complaint, recruiters and victims were paid in cash or through entities set up by Epstein and/or his associates. /d. {| 100. Many of these companies were shell companies, that existed merely to transfer money to other accounts, or to shelter Epstein’s assets from judgment. /d. {[ 116. 31. Epstein’s lawyer, Darren K. Indyke, and accountant, Richard Kahn, now the Co- Executors of Epstein’s Estate, authorized or directed many of the transactions in JP Morgan accounts EFTA00162259

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CeBaska22@veLOD0904SFS RD dhoouwnes616 Filed 01/18/23 Page 20ob82123 held by Epstein or related entities. /d. {| 8-10, 76-117. 32. Epstein and the Epstein Enterprise continued trafficking and sexually abusing young women and female children until Epstein was arrested by federal law enforcement authorities on July 6, 2019 on federal charges for the sex trafficking of minors. 33. Epstein was found dead on August 10, 2019 while in custody in a federal detention center in New York on charges for sex-trafficking crimes. Id. {[ 7. ALLEGATIONS IL Jeffrey Epstein Was an Extremely High-Risk Customer 34. Jeffrey Epstein’s reputation as a sex trafficker and abuser of women and girls was well-known and well-publicized for more than a decade before his death. 35. Between 2005 and 2013, there were numerous press reports that Epstein sexually abused women and girls. 36. — In March 2005, there were press reports that Epstein paid a 14-year old girl in Palm Beach, Florida for a “massage” and then molested her. Following these allegations, multiple underage girls, many of them high school students, told police that Epstein also hired them to give sexual massages. 37. | Throughout 2006—when Epstein was arrested in Palm Beach, Florida for solicitation of a minor—there was extensive press regarding the nature and extent of Epstein’s sexual offenses, including the existence of dozens of victims. 38. In 2008, Epstein pled guilty to sexual offenses in Palm Beach, Florida, including solicitating a minor for prostitution. Epstein was sentenced to 18 months in jail and was required to register as a sex offender. 39. — In 2009, the non-prosecution agreement between Epstein and the United States EFTA00162260

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Céssé 222.c1002P949B8R Dinoueated Filled OWIGI23 Page 10 of 323 became public. It revealed allegations that Epstein may have used interstate commerce to induce minors to engage in prostitution, engaged in illicit sexual conduct with minors, and trafficked minors. 40. In 2010, press reports noted allegations that Epstein was involved with Eastern European women in particular and that a modeling agency he helped fund brought “young girls . . . often from Eastern Europe” to the United States on Epstein’s private jets.* Il. JP Morgan Knew Epstein Was a Felon, Registered Sex Offender, and Alleged Child Trafficker 41. JP Morgan did business with Jeffrey Epstein from as early as 1998 to 2013. In that time, JP Morgan serviced approximately fifty-five Epstein-related accounts collectively worth hundreds of millions of dollars. P= N * Conchita Sarnoff, Jeffrey Epstein Pedophile Billionaire and His Sex Den, The Daily Beast (July 22, 2010), https://www.thedailybeast.com/jeffrey-epstein-pedophile-billionaire-and-his-sex-den. 10 EFTA00162261

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+ + + + + + EFTA00162262

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a Ss = tT va a) EFTA00162263

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Céssé 222.c1002P949SBR Dinoneated Filled OWIG23 Page 13 af 23 II. Head of JP Morgan’s Private Bank Had Close Personal Relationship With Epstein 52. Former senior executive, Jes Staley (“Staley”), developed a close relationship with Epstein when Staley was the head of JP Morgan’s Private Bank, which is a segment of JP Morgan’s business dedicated to extremely wealthy clients with at least $10 million in assets. 53. Between 2008 and 2012, Staley exchanged approximately 1,200 emails with Epstein from his JP Morgan email account. These communications show a close personal relationship and “profound” friendship between the two men and even suggest that Staley may have been involved in Epstein’s sex-trafficking operation. They also reveal that Staley corresponded with Epstein while Epstein was incarcerated and visited Epstein’s Virgin Islands residence on multiple occasions. an - a al wn a EFTA00162264

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Céssé 222\c\L00P0495B8R Dinousatad Filled OW/IG/23 Page 14 af I23 357 14 EFTA00162265

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Céssé 222\c\L00P049SB8R Dinousatad Filled OV/IG/23 Page 15 af 23 ee 60. 62. None of the emails between Epstein and Staley were flagged in connection with risk reviews of Epstein’s accounts. Moreover, JP Morgan allowed Staley to remain a decision- maker on Epstein’s accounts. JP Morgan even tasked Staley to discuss the human trafficking allegations with Epstein. 63. In July 2013—several months after Staley left JP Morgan to join another financial institution—JP Morgan’s Compliance Officer terminated JP Morgan’s relationship with Epstein. 64. At the time of Epstein’s death in 2019, Staley was the Chief Executive Officer of Barclays; however, Staley stepped down from that position in November 2021 after British EFTA00162266

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Céssé 222.c\.002D49SBR Dinoumatad Filled OM/I1G/23 Page 1¢ af I23 financial regulators concluded an investigation into Staley’s characterization of his relationship with Epstein. IV. JP Morgan Ignored Obvious Red Flags Relating to Epstein’s Accounts 65. Despite JP Morgan’s claims that it would closely monitor Epstein’s accounts, JP Morgan ignored numerous red flags related to Epstein’s accounts and failed to comply with federal banking regulations. 66. — 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. 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 | listed Epstein’s apartments on 66th Street in New York City as her address, which should have been a red flag to JP Morgan. 67. 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. SAC {| 100. 68. In addition, Epstein and/or his representatives appeared to be misusing JP Morgan EFTA00162267

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Céssé 222.c1002PD49SBR Dinoneated Ailed OW/IGI23 Page 1B af 23 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.0.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. Similarly, Epstein and/or his representative used the Enhanced Education fund to pay $124,232 to Leslie Wexner and $15,000 to Po and a. a firm owned by Epstein’s reportedly prior girlfriend. 69. Each of these red flags was serious; together, they suggest a pattern of potentially illegal conduct that should have prompted action by JP Morgan. < Epstein Brought Additional High Net Worth Clients to JP Morgan 71. In addition to his own holdings with JP Morgan, Epstein helped, or promised to help, Staley recruit ultrawealthy clients to JP Morgan. A few examples are laid out below. 72. In 2004, Epstein introduced Staley to Glenn Dubin, the owner of Highbridge Capital Management—one of the country’s largest hedge funds. This laid the groundwork for JP EFTA00162268

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Céssé 222.c1002P9498R Dinoneated Ailed OWIG23 Page 19 af 23 Morgan’s acquisition of Highbridge—a move that helped catapult Staley’s career. 73. In 2011, Epstein and Staley had extensive discussions regarding the creation of a “very HIGH profile” donor advised fund (“DAF”), which is an investment account established to support charitable organizations, headed by the a. Epstein pitched the Zz DAF as an “exclusive club” with a minimum $100 million donation where JP Morgan would act as the fiduciary. < I. JP Morgan’s Reveals Systematic Failures ~l > ~~ at ~~ an EFTA00162269

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Céssé 222.c1002P949BR Dinoueated Ailled OWIGI23 Page PD af I23 77. JP Morgan also seemingly did no due diligence on the nature of the various business entities for which it held accounts for Epstein, which appear to have no legitimate business purpose and, upon information and belief, were part of Epstein’s criminal enterprise in the Virgin Islands. 78. In January 2013—the year JP Morgan terminated Epstein’s accounts—the Office of the Comptroller of the Currency (“OCC”) entered into a consent order with JP Morgan regarding deficiencies in the bank’s overall program for BSA/AML compliance. The OCC found— consistent with the Government's findings here—that JP Morgan failed to develop adequate due diligence on customers and failed to comply with federal banking regulations. In fact, the OCC noted that JP Morgan “failed to identify significant volumes of suspicious activity”.* 79. After JP Morgan terminated Epstein’s accounts, Epstein moved his accounts to * NYSDFS Consent Order at 2-4 (Jan. 14, 2013), https://www.occ.treas.gov/news- issuances/news-releases/2013/nr-occ-2013-8a.pdf. 19 EFTA00162270

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Céssé 222.61.002D4SBR Dinounattad Filled OM/IG/23 Page 20 af I23 Deutsche Bank from 2013 to 2018. 80. The New York State Department of Financial Services (“NYSDFS”) investigated Deutsche Bank for failures to monitor Epstein’s accounts. On July 6, 2020, the NYSDFS and Deutsche Bank entered into a Consent Order with a $150 million penalty, which stated, in relevant parts: a. “The Bank’s fundamental failure was that, although the Bank properly classified Mr. Epstein as high-risk, the Bank failed to scrutinize the activity in the accounts for the kinds of activity that were obviously implicated by Mr. Epstein’s past. The Bank was well aware not only that Mr. Epstein had pled guilty and served prison time for engaging in sex with a minor but also that there were public allegations that his conduct was facilitated by several named co-conspirators. Despite this knowledge, the Bank did little or nothing to inquire into or block numerous payments to named co- conspirators, and to or on behalf of numerous young women, or to inquire how Mr. Epstein was using, on average, more than $200,000 per year in cash.” b. “Whether or to what extent those payments or that cash was used by Mr. Epstein to cover up old crimes, to facilitate new ones, or for some other purpose are questions that must be left to the criminal authorities, but the fact that they were suspicious should have been obvious to Bank personnel at various levels. The Bank's failure to recognize this risk constitutes a major compliance failure.” c. “These errors are unacceptable in the context of a major international bank 20 EFTA00162271

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Céssé 222.c1002P949SB8R Dinoneated Filled OWIG23 Page 22 af 323 and inexcusable in the context of the heightened scrutiny that should have occurred in the monitoring of a high-risk customer.” 81. The NYSDFS also found fault with Deutsche Bank’s failure to obtain answers regarding Epstein’s use of his accounts to pay women with Eastern European surnames: “In a May 2018 email, a compliance officer submitted an inquiry . .. about payments to the accounts of women with Eastern European surnames at a Russian bank, and asking for an explanation of the purpose of the wire transactions and Epstein’s relationship with the counterparties.”° 82. JP Morgan’s failures to appropriately monitor Epstein’s accounts and comply with federal banking regulations are even more egregious than Deutsche Bank’s failures because JP Morgan failed to demonstrate even basic due diligence and continued its relationship with Epstein for over a decade, despite the glaring indications of criminal activity. 83. 84. VII. JP Morgan Fraudulently Concealed Its Continuing Violations 85. JP Morgan’s continuous illegal conduct has caused repeated and continuous injury. 86. JP Morgan knew—including at the highest level of the bank—that Epstein was an extremely high-risk client. Between 2005 and 2013, there were myriad reports that Epstein sexually abused women and girls. In 2008, Epstein pled guilty to sexual offenses and registered as > Id. at 15. EFTA00162272

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Céssé 222.6\.002D49BR Dinousat tad Filled OM/IG/23 Page 22 af 323 a sex offender. Despite JP Morgan’s acknowledgement that it needed to closely monitor Epstein, JP Morgan ignored numerous red flags and failed to comply with federal banking regulations until years later after JP Morgan was no longer benefiting from Epstein’s business. 87. JP Morgan also engaged in a course of conduct aimed at fraudulently concealing its illegal conduct, including by failing to timely comply with federal banking regulations in order to profit from Epstein’s wealth and connections. 88. A key purpose of federal banking regulations is to give law enforcement real-time information so that it can act to detect violations of the law and protect public safety. 89. | The Government of the Virgin Islands did not know, and could not have known, that Epstein used JP Morgan to facilitate his trafficking enterprise or that JP Morgan turned a blind eye to unusual cash transactions and wires and failed to carry out or follow up on basic due diligence and to timely comply with federal banking regulations, as required by the law. 90. Over more than a decade, JP Morgan clearly knew it was not complying with federal regulations in regard to Epstein-related accounts as evidenced by its too-little too-late efforts after Epstein was arrested on federal sex trafficking charges and shortly after his death, when JP Morgan belatedly complied with federal law. 91. The continued illegal conduct by JP Morgan has caused repeated and continuous injury. JP Morgan’s illegal conduct was not completed nor were all damages incurred until the wrongdoing ceased in August 2019 when JP Morgan began belatedly complying with federal banking regulations in regard to Epstein-related accounts. 22 EFTA00162273

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Céssé 222.61.002D49BR Danone tad Filled OM/IG/23 Page 24 af I23 CAUSES OF ACTION COUNT ONE Participating in a Sex-Trafficking Venture Violation of Trafficking Victims Protection Act 18 U.S.C. §§ 1591(a)(2), 1595(d) (Parens Patriae) 92. The Government restates and realleges paragraphs | to 91 of this Complaint as if fully set forth herein. 93. The Government brings this Count as parents patriae on behalf of the residents and visitors of the United States Virgin Islands and pursuant to the Attorney General’s express statutory authority. 94. JP Morgan knowingly and intentionally participated in 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. § 1591(a)(2) by facilitating payments to women and girls, channeling funds to Epstein to fund the operation, and concealing Epstein’s criminal conduct by failing to comply with federal banking law. 95. JP Morgan knowingly and intentionally benefitted financially from and received value for its participation in the sex-trafficking venture in which Epstein and his co-conspirators, with JP Morgan’s knowledge or reckless disregard of the fact, would use means of force, threats of force, fraud, coercion, and a combination of such means to sexually abuse young women and underage girls, including by causing them to engage in commercial sex acts, in the Virgin Islands and elsewhere. 96. Among the financial benefits that JP Morgan received for participating in and facilitating Epstein’s sex-trafficking venture was the deposit of funds that Epstein—a Virgin Islands resident—and Epstein-controlled entities located in the Virgin Islands made to JP Morgan. JP Morgan profited from the use of these deposits. Epstein and Epstein-controlled entities located 23 EFTA00162274

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Céssé 222.41.002D49BR Danone tad Ailled OM/IG/23 Page 25 af I23 in the Virgin Islands deposited these funds in exchange for JP Morgan’s facilitation of and participation in Epstein’s sex-trafficking venture. 97. Also, among the financial benefits that JP Morgan received for participating in and facilitating Epstein’s sex-trafficking venture were referrals of business opportunities from Epstein and his co-conspirators. JP Morgan profited from, or expected to profit from, these referred business opportunities. Epstein referred business entities and business opportunities to JP Morgan in exchange for its facilitation of and participation in Epstein’s sex-trafficking venture. 98. JP Morgan financially profited from the deposits made by Epstein and Epstein- controlled entities located in the Virgin Islands and from the business opportunities referred to JP Morgan by Epstein and his co-conspirators in exchange for its known facilitation of and implicit participation in Epstein’s sex trafficking venture. 99. JP Morgan knew and recklessly disregarded and concealed the fact that it was Epstein’s pattern and practice to use the channels and instrumentalities of interstate and foreign commerce to recruit, entice, harbor, transport, provide, obtain, and maintain young women and underage girls for purposes of causing them to engage in commercial sex acts in violation of 18 U.S.C. § 1591(a)(1). 100. JP Morgan and its employees had actual knowledge that they were facilitating Epstein’s sexual abuse and sex-trafficking conspiracy to recruit, entice, harbor, transport, provide, obtain, and maintain young women and underage girls to engage in commercial sex acts through the means of force, threats of force, fraud, abuse of process, and coercion. 101. Despite this knowledge, JP Morgan intentionally paid for, concealed, facilitated, and participated in Epstein’s and his co-conspirators’ violations of 18 U.S.C. § 1591(a), which JP Morgan knew and was in reckless disregard of the fact that Epstein and his co-conspirators would 24 EFTA00162275

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Céssé 222.c\.002D49SBR Dinouma tad Filled OM/I1G/23 Page 25 aff I23 use its bank accounts and financial transactions to coerce, defraud, and force young women and underage girls to engage in commercial sex acts. 102. JP Morgan, through its employees and agents and their role in facilitating the financial aspect of Epstein’s enterprise, actively facilitated or participated in the sex-trafficking conspiracy in which Epstein and his co-conspirators led young women and underage girls in the Virgin Islands and elsewhere to believe that they would be rewarded if they cooperated with Epstein and his co-conspirators and acquiesced to their demands. 103. JP Morgan committed this affirmative conduct knowing or in reckless disregard of the fact that Epstein would use cash transactions and financial support provided by JP Morgan as a means to defraud, force, and coerce commercial sex acts from young women and underage girls. 104. In addition to having actual knowledge that it was participating in and facilitating the Epstein sex-trafficking venture, JP Morgan also knew that it was participating in and facilitating a venture that was engaged in coercive sex trafficking in violation of 18 U.S.C. § 1591(a)(1). 105. In exchange for facilitating and covering up Epstein’s commercial sex trafficking, JP Morgan’s employees received financial benefits and career advancement from JP Morgan. 106. Facilitating and covering up Epstein’s sex trafficking venture was a means for JP Morgan employees to obtain economic success and promotion within JP Morgan. 107. JP Morgan’s knowing and intentional conduct has caused serious harm to the Virgin Islands and its residents, including without limitation financial harm, by facilitating the commission of sexual abuse against young women and underage girls, including their engagement in commercial sex acts, in the Virgin Islands. 25 EFTA00162276

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Céssé 222.c\.002949SBR Dinoumatad Aled OMV/IG/23 Page 27 af I23 108. JP Morgan’s tortious conduct in violating the TVPA was outrageous and intentional because it was in deliberate furtherance of a widespread and dangerous criminal sex-trafficking venture operated in and from the Virgin Islands. JP Morgan’s tortious conduct also evidenced a high degree of moral turpitude and demonstrated such wanton disregard for the safety of young women and underage girls in the Virgin Islands and elsewhere as to imply a deliberate indifference to its legal obligations. 109. By virtue of these knowing and intentional violations of 18 U.S.C. § 1591(a)(2), JP Morgan is liable to the Government for all appropriate relief under 18 U.S.C. § 1595(d), including damages suffered by the Government and/or Epstein’s victims, punitive damages, restitution, appropriate injunctive relief, fines, reasonable attorneys’ fees, and all such other relief as the Court deems appropriate. COUNT TWO Criminal Activity—Participating, Directly or Indirectly, in a Sex-Trafficking Venture Violation of Trafficking Victims Protection Act, 18 U.S.C. § 1591(a)(2), actionable under Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.LC. §§ 604(e) and 605(a) 110. The Government restates and realleges paragraphs | to 109 of this Complaint as if funny set forth herein. 111. The Virgin Islands Legislature enacted the CICO Act with the purpose to “curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies.” 14 V.L.C. § 601. 112. At all times material herein, JP Morgan was a “person” identified in 14 V.LC. § 604(1). 26 EFTA00162277

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Céssé 222.4\.002D4SBR Dinoumattad Filled OM/1G/23 Page ZB af I23 113. At all times material herein, Epstein and his co-conspirators were engaged in an illicit sex-trafficking “enterprise” as defined in 14 V.I.C. § 604(h). 114. At all times material herein, JP Morgan supported and/or was associated with the Epstein sex-trafficking enterprise by providing banking and payment-processing services to Epstein, who resided in the Virgin Islands, and Epstein-controlled entities that were located and/or incorporated in the Virgin Islands. 115. In providing banking and payment-processing services to Epstein and Epstein- controlled entities in return for profits realized both from Epstein’s and Epstein-controlled entities’ accounts and from receiving referrals by Epstein of other high-value banking clients, JP Morgan knowingly, intentionally, and willfully benefitted financially and by receiving things of value from its participation, directly or indirectly, in Epstein’s sex-trafficking venture and enterprise, in violation of 18 U.S.C. § 1591(a)(2). 116. JP Morgan’s knowing, intentional, and willful receipt of financial benefits and things of value from its facilitation and participation in Epstein’s sex-trafficking venture and enterprise through the financial infrastructure it provided and concealed constitutes a felony under 18 U.S.C. § 1591(b) and “criminal activity” as defined in 14 V.LC. § 604(e). 117. By knowingly, intentionally, and willfully receiving financial benefits and things of value from its participation, directly or indirectly, via financing in Epstein’s sex-trafficking venture and enterprise, JP Morgan enabled Epstein to have ready and reliable access to and use of resources with which to recruit, entice, harbor, transport, provide, obtain, and maintain young women and underage girls for purposes of causing them to engage in commercial sex acts in the Virgin Islands and elsewhere. JP Morgan thereby unlawfully conducted and/or participated in, 27 EFTA00162278

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Céssé 222\\L00294958R Dinoumated Aled OWIG23 Page 28 af 323 directly or indirectly, the affairs of the Epstein sex-trafficking enterprise through a pattern of illegal activity in violation of 14 V.LC. § 605(a). 118. JP Morgan’s illegal activity has caused serious harm to the Virgin Islands and its residents, including without limitation financial harm, by facilitating the commission of sexual abuse against young women and underage girls, including their facilitation and participation, directly or indirectly, in commercial sex acts, in the Virgin Islands. 119. By virtue of this pattern of illegal activity in furtherance of the Epstein sex- trafficking enterprise, JP Morgan is liable to the Government for all appropriate civil remedies under 14 V.I.C. § 607, including treble damages suffered by the Government and/or Epstein’s victims, civil penalties, restitution and/or disgorgement of ill-gotten gains, appropriate injunctive relief, attorneys’ fees and costs, and all such other relief as the Court deems appropriate. COUNT THREE Criminal Activity—Willfully Failing To Comply With Federal Banking Law, Violation of Bank Secrecy Act, 31 U.S.C. § 5322(a), as it incorporates actionable under Virgin Islands Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. §§ 604(e) and 605(a) 120. The Government restates and realleges paragraphs | to 119 of this Complaint as if fully set forth herein. 121. The Virgin Islands Legislature enacted the CICO Act with the purpose to “curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies.” 14 V.L.C. § 601. 122. At all times material herein, JP Morgan was a “person” as defined in 14 V.LC. EFTA00162279

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Céssé 222.c1002P949BR Dinoueated Riled OWIGI23 Page 2D af 323 123. At all times material herein, Epstein and his co-conspirators were engaged in an illicit sex-trafficking “enterprise” as defined in 14 V.I.C. § 604(h). 124. At all times material herein, JP Morgan was employed by and/or associated with the Epstein sex-trafficking enterprise by providing banking and payment-processing services to Epstein, who resided in the Virgin Islands, and Epstein-controlled entities that were located and/or incorporated in the Virgin Islands. 125. In providing banking and payment-processing services to Epstein and Epstein- controlled entities, JP Morgan knowingly, intentionally, and willfully failed to comply with federal banking regulations in violation of 31 U.S.C. § 5322(a), ee. From accounts maintained and served at JP Morgan, Epstein and Epstein-controlled entities received payments of large dollar amounts for no apparent business or other lawful purpose and made repeated cash payments, sometimes in amounts and patterns designed to evade federal reporting requirements, to young women and/or underage girls who were sexually abused and coerced into engaging in commercial sexual acts in the Virgin Islands and elsewhere. 126. JP Morgan’s knowing, intentional, and willful failure to comply with federal banking regulations constitutes a felony under 31 U.S.C. § 5322(a) and “criminal activity” as defined in 14 V.LC. § 604(e). EFTA00162280

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Céssé 222.c\.002D49BR Danone tad Filled OM/IG/23 Page 31 af 323 127. By knowingly, intentionally, and willfully failing to comply with federal banking regulations, JP Morgan enabled Epstein to have ready and reliable access to and use of resources with which to recruit, entice, harbor, transport, provide, obtain, and maintain young women and underage girls for purposes of causing them to engage in commercial sex acts in the Virgin Islands and elsewhere. JP Morgan thereby unlawfully conducted and/or participated in, directly or indirectly, the affairs of the Epstein sex-trafficking enterprise through a pattern of illegal activity in violation of 14 V.LC. § 605(a). 128. JP Morgan’s illegal activity has caused serious harm to the Virgin Islands and its residents, including without limitation financial harm, by facilitating the commission of sexual abuse against young women and underage girls, including their engagement in commercial sex acts, in the Virgin Islands. 129. By virtue of this pattern of illegal activity in furtherance of the Epstein sex- trafficking enterprise, JP Morgan is liable to the Government for all appropriate civil remedies under 14 V.I.C. § 607, including treble damages suffered by the Government and/or Epstein’s victims, civil penalties, restitution and/or disgorgement of ill-gotten gains, appropriate injunctive relief, attorneys’ fees and costs, and all such other relief as the Court deems appropriate. COUNT FOUR Unfair Methods of Competition Violation of Virgin Islands Consumer Fraud and Deceptive Business Practices Act, 12A V.LC. § 304 130. The Government restates and realleges paragraphs | to 129 of this Complaint as if fully set forth herein. 131. Section 304 of Title 12A of the Virgin Islands Code provides that “[i]t is unlawful for any person to engage in unfair methods of competition . . . in the conduct of any trade or commerce.” 30 EFTA00162281

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Céssé 222.c\.002D49SBR Dinoumatad Filled OM/IG/23 Page BP aff 323 132. JP Morgan is a “person” as defined in 12A V.LC. § 303(h). 133. JP Morgan’s provision of banking services and payment processing for Epstein and Epstein-controlled entities constitutes “[t]rade or commerce” as defined in 12 V.LC. § 303(k). 134. In return for knowingly and intentionally participating in, directly or indirectly, facilitating, and concealing by failing to comply with federal banking regulations regarding Epstein-related accounts, JP Morgan both profited from the use of the funds in their accounts and received referrals of other high-value business opportunities from Epstein and his co-conspirators. 135. By receiving referrals of high-value business opportunities from Epstein and his co-conspirators in return for participating in, directly or indirectly, facilitating, and concealing by failing to comply with federal banking regulations regarding Epstein-related accounts, JP Morgan unlawfully and unjustly enriched itself at the expense of other banks that complied with their legal obligations. This conduct constitutes an unfair method of competition in violation of 12A V.LC. § 304. 136. By virtue of its knowing, intentional, and repeated acts constituting unfair competition, JP Morgan is liable to the Government for all appropriate civil remedies under 12A V.LC. §§ 328 and 332, including damages, civil penalties awarded on a per-violation basis pursuant to 12A V.LC. § 328(b), appropriate injunctive relief, attorneys’ fees and costs, and all such other relief as the Court deems appropriate. REQUEST FOR RELIEF The Government respectfully requests that the Court enter judgment in its favor, and against JP Morgan, as follows: 31 EFTA00162282

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Céssé 222.c\.002D49BR Dinoumattad Filled OM/IG/23 Page 32 aff I23 A. That the Court award the Government compensatory, consequential, general, and nominal damages, as suffered by the Government and/or Epstein’s victims, and punitive damages, all against JP Morgan in amounts to be awarded at trial; B. That the Court award the Government punitive and exemplary damages against JP Morgan in an amount to be determined at trial: Cc. That the Court order JP Morgan to pay appropriate fines to the Government pursuant to 18 U.S.C. § 1591(b) in amounts to be determined at trial; D. That the Court order JP Morgan to provide restitution of all ill-gotten gains to the Government pursuant to 18 U.S.C. § 1593 and 14 V.LC. § 607(a)(6) and pursuant to 14 V.LC. § 608(c)(4) to protect the rights of victims and innocent persons in the interest of justice and consistent with the purposes of the CICO Act, in amounts to be determined at trial; E. That the Court award the Government treble damages against JP Morgan pursuant to 14 V.LC. § 607(c) in an amount to be determined at trial; F. That the Court order JP Morgan to pay appropriate civil penalties to the Government pursuant to 14 V.LC. § 607(e) and 12A V.LC. § 328(b) and pursuant to 14 V.LC. § 608(c)(4) to protect the rights of victims and innocent persons in the interest of justice and consistent with the purposes of the CICO Act, in amounts to be determined at trial; G. That the Court enter an injunction pursuant to 14 V.LC. § 607(a)(2) and 12A V.LC. § 328(a)(2) to prevent further illegal conduct and any concealment of illegal conduct; 32 EFTA00162283

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Céssé 222.41.002D49SBR Dinoumattad Ailled OMV/IG/23 Page 34 af I23 H. That the Court order JP Morgan to provide disgorgement of all ill-gotten gains to the Government pursuant to 14 V.LC. § 607(a)(6) and pursuant to 14 V.LC. § 608(c)(4) to protect the rights of victims and innocent persons in the interest of justice and consistent with the purposes of the CICO Act, in amounts to be determined at trial; IL That the Court award the Government attorneys’ fees and costs pursuant to 18 U.S.C. § 1595, 14 V.LC. § 607(c), and 12A V.LC. § 332 in amounts to be determined after trial; and J. That the Court award the Government and order JP Morgan to provide all such other relief as the Court deems appropriate. JURY DEMAND The Government demands a jury trial on all issues so triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL /s/ David I. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 849-4962 dackerman@ motleyrice.com CAROL THOMAS-JACOBS (NYS Bar #2941300) Admitted Pro Hac Vice Acting Attorney General of the United States Virgin Islands Virgin Islands Department of Justice 34-38 Kronprindsens Gade St. Thomas, U.S. Virgin Islands 00802 Tel.: (340) 774-5666 ext. 10101 carol jacobs @doj.vi.gov 33 EFTA00162284

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Céssé 222.4\.002D49SBR Dinoumat tad Filled OM/IG/23 Page 3 aff I23 LINDA SINGER (NYS Bar #2473403) Admitted Pro Hac Vice Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 232-5504 lsinger@ motleyrice.com PAIGE BOGGS Admitted Pro Hac Vice Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 386-9629 pboggs@ motleyrice.com 34 EFTA00162285

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Odasd 2227vi0020438R DDounreanhBSt1 FAdd@MOW32M23 PaggSé of 723 Exhibit 1 to Government’s Amended Complaint against JPMorgan Chase Bank, N.A. EFTA00162286

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it att Rt eam Odasel 22257vEM0204ISER DDcanraahBHel1 FRdd@Oi323 PAagg@Z of 723 FILED Noverber 30, 2022 12:02 OM 8T-2020-Cv-00014 TAMARA CHARLES CLERK OF THE COURT IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN SREEREEREEREEESEESE ESSE SEES EEE SE GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, Case No.: ST-20-CV-14 PLAINTIFF, ACTION FOR DAMAGES V. JURY TRIAL DEMANDED DARREN K. INDYKE, in his individual capacity and in his capacity as the EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN and ADMINISTRATOR OF THE 1953 TRUST; RICHARD D. KAHN, in his individual capacity and in his capacity as the EXECUTOR FOR THE ESTATE OF JEFFREY E. EPSTEIN, and ADMINISTRATOR OF THE 1953 TRUST; ESTATE OF JEFFREY E. EPSTEIN; THE 1953 TRUST; PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, Inc.; SOUTHERN TRUST COMPANY, INC.; CYPRESS, INC.; MAPLE, INC.; LAUREL, INC.; AND JOHN AND JANE DOES, DEFENDANTS. SECOND AMENDED COMPLAINT COMES NOW, the Government of the United States Virgin Islands ("Government") and files this Second Amended Complaint containing information that has become known through further investigation and third-party discovery and in support thereof, would show unto the Court as follows: JURISDICTION AND PARTIES 1. The Attorney General of the United States Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant EFTA00162287

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O@asd 2227vi009043ER DDounreanBSek1 Frdd@MOM3M@23 Paggss of 123 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 2 of 76 to 3 V.LC. § 114 and 14 V.L.C. §607 and her statutory authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of persons in the Virgin Islands. 2. This Court has subject matter jurisdiction over this civil matter pursuant to 4 V.LC. § 76 and 14 V.LC. § 607. 3. This Court has personal jurisdiction over the parties pursuant to 5 V.LC. § 4903. 4. The Virgin Islands is an unincorporated territory of the United States. It consists of St. Thomas, St. Croix, St. John, and Water Island, and more than 40 surrounding islands and Cays, some of which are privately owned. Among these privately owned islands are Little St. James and Great St. James. 5. Jeffrey E. Epstein ("Epstein") was a resident of the Virgin Islands and he maintained a residence on Little St. James, which he acquired in 1998 and in 2016 he also purchased Great St. James. 6. Epstein registered as a sex offender in the Virgin Islands in 2010. He was a Tier | offender under Virgin Islands law based upon his Florida conviction of procuring a minor for prostitution. As a Tier 1 offender, Epstein was required to register annually with the Virgin Islands Department of Justice ("WIDOJ") and give advance notice of his travel to and from the Virgin Islands. Epstein was also subject to random address verification by VIDOJ. 7. Epstein was found dead on August 10, 2019 while in custody in New York for sex crimes. 8. Defendant Darren K. Indyke ("Defendant Indyke") is co-executor of the Estate of Jeffrey E. Epstein and Administrator of The 1953 Trust and was and/or is a participant in the activity of the “Epstein Enterprise,” as set forth below. EFTA00162288

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Oaasd 2227vi009043ER DDounreanBSek1 FrddMOM3M@23 Paggsa of 123 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 3 of 76 9. Defendant Richard D. Kahn ("Defendant Kahn") is co-executor of The Estate of Jeffrey E. Epstein and Administrator of The 1953 Trust and was and/or is a participant in the activity of the “Epstein Enterprise,” as set forth below. 10. Defendants Indyke and Kahn, in addition to administering the Estate under the laws of the Virgin Islands, engaged in conduct in the Virgin Islands through their participation in businesses, financial transactions, and accounts registered, held, and operating in the Virgin Islands, and by filing documents with the Government of the Virgin Islands. 11. Defendant, the Estate of Jeffrey E. Epstein ("Estate"), created upon Epstein's death, is domiciled in the Virgin Islands. On August 15, 2019, Defendants Indyke and Kahn filed a Petition for Probate and Letters Testamentary which included Epstein's last will and testament with the Probate Division of the Superior Court of the Virgin Islands. 12. The Petition reported the value of the real and personal property in The Estate located in the Virgin Islands at $577,672,654.00 dollars. 13. According to the Petition, the assets in the Virgin Islands thus far included: a. $56.5 million in cash; b. $127 million in fixed income and equity investments: c. $195 million in hedge fund and private equity investments; and d. $18.5 million in planes, boats, and automobiles. The Estate did not originally value his fine arts, antiques, and other valuables. 14. The Estate also included shares of various corporate entities which hold residences and real property used by Epstein, namely: a. Brownstone in New York City valued at $56 million; b. Ranch in New Mexico valued at $72 million; EFTA00162289

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Odasd 2227 002043ER DDounreanBGek1 Frdd@MOM32M@23 Pagget6 of 123 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 4 of 76 c. Gated home in Palm Beach, Florida, valued at $12 million; d. Seven units in an apartment building in Paris, valued at $8 million; and e. Great St. James and Little St. James, collectively valued at $86 million. 15. At the time of this Second Amended Complaint filing, the Estate’s most recent accounting, filed February 1, 2021, valued its total assets at $240,782,955.84, which is almost 60% lower than the Estate’s starting valuation less than 18 months earlier when Defendants Indyke and Kahn began their Co-Executorship of the Estate. 16. The Estate is responsible to pay penalties and damages for the acts committed by Epstein and the Epstein Enterprise described below. 17. Defendant The 1953 Trust ("The Trust") was created by Epstein, who "amended and restated" its terms only two days before his suicide. That same day, Epstein revised his Last Will and Testament, transferring all of his "property, real and personal, wherever situated" to The Trust. The Trust also contains Epstein’s financial assets and is also responsible to pay damages for the acts committed by Epstein and the Epstein Enterprise described below. Defendants Indyke and Kahn, filed a Certificate of Trust in the Superior Court of the Virgin Islands for The Trust on August 26, 2019. 18. Epstein maintained a deliberately complex web of Virgin Islands corporations, limited liability companies, foundations, and other entities, not all of which are yet known to the Government of the Virgin Islands, through which he carried out and concealed his criminal conduct. 19. Epstein regularly created new entities in the territory and transferred properties and funds between them in order to preserve and shield Epstein's assets and to facilitate and conceal the unlawful acts described in this Complaint. EFTA00162290

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Oa@asd 2227 002043ER DDounreahBSek1 FrddMOM3M23 Paggetlé of 123 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 5 of 76 20. These entities held properties, including Little St. James and Great St. James, at which Epstein trafficked and sexually abused women and underage girls. Epstein owned and arranged for private planes, helicopters, boat and automobiles to transport victims to, from, and within the Virgin Islands, and provided money to pay these young women and underage girls. 21. — Epstein sat at the hub of this web, serving as president, member, manager, or director of each of the entities and, upon information and belief, directing their activities. 22. Defendant, Nautilus, Inc., is a corporation established and organized under the laws of the Virgin Islands. It was incorporated on November 22, 2011. 23. According to records of the Virgin Islands Recorder of Deeds, Nautilus, Inc. owns Little St. James, a/k/a Parcel Number 109803010100, a parcel of 3.1 million square feet valued at $3.2 million, with buildings and improvements valued at $4 million. 24. Epstein was president and director of Nautilus, Inc., which corporate filings describe as "holding property for personal use." Defendants Indyke and Kahn are the secretary and treasurer of Nautilus, Inc., respectively. The Estate values Epstein's holdings of Nautilus, Inc., which holds title to Little St. James at $63.9 million. 25. A deed recorded with the Virgin Islands Recorder of Deeds on December 30, 2011 reflects that the property was transferred from a Delaware entity, L.S.J., LLC, to Nautilus, Inc. for "TEN DOLLARS ($10.00) and other good and valuable consideration." The quitclaim deed lists Jeffrey Epstein as the sole member of L.S.J., LLC, which it acquired Little Saint James via a warranty deed dated April 27, 1998. 26. As described below, Epstein engaged in a pattern and practice of trafficking and sexually abusing young women and female children on this private, secluded island of Little St. James where Epstein and his associates could avoid detection of their illegal activity from Virgin EFTA00162291

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O@asd 2227 009043ER DDounreanBSek1 Frdd@MOM3M23 PaggelZ of 123 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 6 of 76 Islands and federal law enforcement and prevent these young women and underage girls from leaving freely and escaping the abuse. 27. Thus, Nautilus, Inc. participated in carrying out, facilitating and concealing Epstein's crimes, hence Little St. James became an instrumentality of those crimes. 28. Defendant, Great St. Jim, LLC, is a limited liability company established and organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26, 2015. Great St. Jim, LLC, according to records of the Virgin Islands Recorder of Deeds, owns at least three properties that make up Great St. James acquired on January 28, 2016: Parcel Number 109801010100, consisting of 3.5 million square feet and valued at $17.5 million; Parcel Number 109801010200, consisting of 450,000 square feet of land, valued at $2.8 million; and Parcel Number 109801010300, 1.2 million square feet of land, valued at $2.7 million. According to a warranty deed filed with the Virgin Islands Recorder of Deeds, Epstein, through Great St. Jim, LLC, acquired the last two parcels for $5 million each. 29. Epstein is listed as manager and a member of Great St. Jim, LLC and the nature of its business is described as "holding assets." Upon information and belief, Epstein purchased these Great St. James properties—the island with closest proximity to Little St. James—to further shield his conduct on Little St. James from view, prevent his detection by law enforcement or the public, and allow him to continue and conceal his criminal enterprise. Epstein's significant investment in the purchase of Great St. James demonstrates his intent to expand his illegal operation in the Virgin Islands for years to come. Thus, Great St. Jim, LLC participated in carrying out, concealing, facilitating and continuing Epstein's crimes, and Great St. James became an instrumentality of those crimes. EFTA00162292

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Cassel 22250v400904}SER DDounreanBSet1 FAddDOMW3M23 Paggels of 723 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 7 of 76 30. Defendant, Poplar, Inc., is a corporation established and organized under the laws of the Virgin Islands. Poplar, Inc. was incorporated on November 22, 2011. Epstein was president and director of Poplar, Inc., and its purpose was described in corporate filings as “holding property for personal use." Defendants Indyke and Kahn are secretary and treasurer of Poplar, Inc., respectively. 31. A certificate of incumbency provided to the Department of Planning and Natural Resources ("DPNR") also lists Epstein as president of Poplar, Inc. and expressly authorizes the incorporators to conduct "transactions related to permitting matters submitted on behalf of Great St. Jim, LLC." 32. Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim, LLC, and the signature appears to be Epstein's. The Petition for Probate and Letters Testamentary filed by The Estate lists Poplar, Inc. as holding title to Great St. James. Thus, Poplar, Inc. participated in carrying out, concealing, facilitating and continuing Epstein's crimes. 33. Defendant, Plan D, LLC is a limited liability company established and organized under the laws of the Virgin Islands. In its original Articles of Organization, filed October 19, 2012, and Annual Report filings, Epstein's pilot, Larry Visoski, was listed as Plan D, LLC's sole manager/member. However, the July 31, 2019 Annual Report revealed Epstein as the principal behind Plan D, LLC. 34. — Upon information and belief, Plan D, LLC owns one or more of the airplanes and helicopters that Epstein used to transport young women and children to and from the Virgin Islands to carry out the criminal pattern of activity described below. Among the airplanes owned by Plan D, LLC is a Gulfstream with N-number N212JE. Flight logs and travel notices indicate EFTA00162293

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Odasd 2227vi009043ER DDounreanBSek1 FAdd@MOM3M@23 Paggeld of 123 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 8 of 76 that Epstein used this plane to traffic and transport and young women and underage girls to the Virgin Islands. 35. Defendant, Hyperion Air, LLC is a limited liability company established and organized under the laws of the Virgin Islands on October 19, 2012. Jeffrey Epstein is a manager/member of Hyperion Air, LLC, along with his pilot, Larry Visoski. The purpose of Hyperion Air, LLC is listed in its Annual Report as "holding assets." 36. | Hyperion Air, LLC is the registered owner of a Bell helicopter with N-number N331JE and a Keystone helicopter with N-number N722JE. Upon information and belief, Epstein used these helicopters to transport young women and underage girls between St. Thomas and Little St. James. 37. Defendant Southern Trust Company, Inc. was originally incorporated in the Virgin Islands on November 18, 2011 as Financial Informatics, Inc., but changed its name to Southern Trust Company in September 2012. Southern Trust Company is a tenant at American Yacht Harbor in Red Hook, St. Thomas, and Epstein is a "passive investor" in IGY-AYH, d/b/a American Yacht Harbor. By the end of 2013, according to its corporate filings, Southern Trust Company has assets of $198.5 million; four years later, its assets reached $391.3 million. From 2011 until at least 2018, Jeffrey Epstein was the President/Director of Southern Trust Company, and Defendants Kahn and Indyke were Treasurer/Director and Secretary/Director, respectively. Epstein was the sole owner of Southern Trust Company. 38. Defendant Cypress, Inc. is a Virgin Islands corporation that was formed and first licensed in or about November 2011. As of December 31, 2018, Epstein was listed as President/Director and Defendants and Co-Executors Indyke and Kahn were listed, respectively, as Vice President/Secretary/Director and Treasurer/Director of Cypress, Inc. Cypress, Inc. owns EFTA00162294

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Case 22a JER MDomumreanttael FAO eB Pepe 4Dalf1Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 9 of 76 the property 49 Zorro Ranch Road in Stanley, New Mexico, which was transferred to it in or about December 2011, shortly after it was incorporated. 39. Defendant Maple, Inc. is a Virgin Islands corporation that was formed and first licensed in or about November 2011. As of December 31, 2018, Epstein was listed as President/Director and Defendants and Co-Executors Indyke and Kahn were listed, respectively, as Vice President/Secretary/Director and Treasurer/Director of Maple, Inc. Maple, Inc. owns the property 9 East 71st Street in New York, New York, which was transferred to it on or about December 23, 2011, shortly after it was incorporated. 40. Defendant Laurel, Inc. is a Virgin Islands corporation that was formed and first licensed in or about November 2011. As of December 31, 2018, Epstein was listed as President/ Director and Defendants and Co-Executors Indyke and Kahn were listed, respectively, as Vice President/Secretary/Director and Treasurer/Director of Laurel, Inc. Laurel, Inc. owns the property 358 Brillo Way in Palm Beach, Florida, which was transferred to it in or about December 2011, shortly after it was formed. 41. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. 42. The Attorney General brings this action to seek all remedies available to the Government of the Virgin Islands in enforcing its laws and protecting the public interest and public safety. These claims are distinct from, and are not intended to supplant, the claims of victims who were unconscionably harmed by Jeffrey Epstein and his associates. EFTA00162295

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Crane 122 ER DmumesnttSis ll. Pee Pepe BL aff 1728 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 10 of 76 FACTUAL ALLEGATIONS A. The Conduct of the "Epstein Enterprise" in the Virgin Islands 43. Epstein and his associates, including Defendants, identified and recruited female victims, including children, and transported them to the Virgin Islands where they were abused and injured. Epstein, through and in association with Defendants, trafficked, raped, sexually assaulted and held captive underage girls and young women at his properties in the Virgin Islands. 44. Epstein created a network of companies and individuals who participated in and conspired with him in a pattern of criminal activity related to the sex trafficking, forced labor, sexual assault, child abuse, and sexual servitude of these young women and children. Epstein and his associates trafficked underage girls to the Virgin Islands, held them captive, and sexually abused them, causing them grave physical, mental, and emotional injury. 45. To accomplish his illegal ends, Epstein formed an association in fact with multiple Defendants and others (both companies and individuals) who were willing to participate in, facilitate, and conceal Epstein's criminal activity in exchange for Epstein's bestowal of financial and other benefits, including sexual services and forced labor from victims. 46. This illicit association of Epstein, Defendants, and his associates constitute what is referred to herein as the "Epstein Enterprise." Epstein’s associates in the Epstein Enterprise, including, but not limited to, those named as Defendants knowingly facilitated, participated in, and concealed Epstein's illegal conduct. 47. Epstein used his wealth and power to create the Epstein Enterprise which engaged in a pattern of criminal activity in the Virgin Islands by repeatedly procuring and EFTA00162296

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Case 22a JER MomumesnttSeil FAO eB PReeged2aff 128 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 11 of 76 subjecting underage girls and young women to unlawful sexual conduct, sex trafficking, and forced labor. 48. The Epstein Enterprise engaged in a pattern of criminal activity in the Virgin Islands (and elsewhere) with the criminal purpose and goal of placing a steady supply of vulnerable female children and young women into sexual servitude in service of Epstein's desires, and those of his associates. The Epstein Enterprise maintained and made available young women and underage girls for the purpose of engaging them in forced labor and sexual activities and used coercion and deception to procure, abuse, and harbor its victims. 49. Flight logs and other sources establish that between 2001 and 2019 the Epstein Enterprise transported underage girls and young women to the Virgin Islands, who were then taken via helicopter or private vessel to Little St. James where they were then deceptively subjected to sexual servitude, forced to engage in sexual acts and coerced into commercial sexual activity and forced labor. 50. In furtherance of its criminal activities, the Epstein Enterprise used its aircrafts to transport the young women and underage girls to the Virgin Islands for purposes of sexual abuse and exploitation. 51. The Epstein Enterprise facilitated and participated in the sexual molestation and exploitation of numerous girls between the age of 12 and 17 years old. 52. On the pretext of providing modeling opportunities, careers and contracts, associates of the Epstein Enterprise, funded by the Epstein Enterprise, lured and recruited young women and underage girls to travel to locations including the Virgin Islands where, upon information and belief, based on the pattern and practice of the Epstein Enterprise, they were sexually abused and exploited. EFTA00162297

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Case 22a ER Domumesnttael PAO Pepe dal f 128 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 12 of 76 53. Associates in the Epstein Enterprise recruited both victims and abusers into the Epstein Enterprise, participated in sexual acts of rape and abuse of minors and witnessed Epstein and others engage in sexual acts with children. 54. As recent as 2018, air traffic controllers and other airport personnel reported seeing Epstein leave his plane with young girls some of whom appeared to be between the age of 11 and 18 years. 55. Upon information and belief, based on Epstein's pattern of trafficking and sexually abusing young girls, the Epstein Enterprise trafficked and abused these girls, and others, in the Virgin Islands through 2018. 56. When sued in civil court for committing sex trafficking and sex crimes, Epstein never denied engaging in sexual acts with underage females and procuring underage females for prostitution, but instead consistently invoked his Fifth Amendment privilege against self- incrimination. 57. Upon information and belief, the Epstein Enterprise kept a computerized list of underage girls who were in or proximate to the Virgin Islands, and able to be transported to Epstein's residence at Little St. James in the Virgin Islands. 58. The Epstein Enterprise engaged in a pattern of criminal conduct by trafficking children and young women and placing them in sexual servitude and forced labor in the Virgin Islands. The Epstein Enterprise repeatedly violated 14 V.LC. §§ 133 to 138, which prohibit trafficking and sexual abuse. The Epstein Enterprise also repeatedly violated laws against child abuse and neglect, including 14 V.LC. § 505, which defines the crime of child abuse as knowingly or recklessly causing "a child to suffer physical, mental, or emotional injury," or causing a child to be placed in a situation where such injury is foreseeable, and 14 V.LC. § 506, which applies, as EFTA00162298

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Crase 122 ESR DmurresttS6 il PAO Page dal 128 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 13 of 76 here, where the child suffers serious physical, mental, or emotional injury as a result of that abuse. The harm to Epstein's victims was both fully foreseeable and deeply damaging. 59. The Epstein Enterprise knowingly recruited, transported, transferred, harbored, received, procured, obtained, isolated, maintained, and enticed young women and girls to engage in forced labor (such as providing massages) and, ultimately, sexual servitude at his little St. James residence. 60. A 15-year old victim was forced into sexual acts with Epstein and others and then attempted to escape by swimming off the Little St. James Island. Epstein and others organized a search party that located her and kept her captive by, among other things, confiscating her passport. Another victim, who was first engaged in provide massages to Epstein, was then forced to perform sexual acts at Little St. James in the Virgin Islands. When she attempted to escape the "private island,” Epstein and a search party found her, returned her to his house, and suggested physical restraint or harm if she failed to cooperate. 61. Another victim was flown by Epstein and his associates to New York or Palm Beach and then to the Virgin Islands dozens of times from 2004, when she was age 20, to 2017. She was repeatedly abused by Epstein and also was pressed to have sex with Epstein’s business colleagues. 62. During the latter part of this period, she was forced into an arranged marriage to another victim that was facilitated by Defendant/Co-Executor Indyke to prevent the other victim from being deported. Indyke and a New York immigration lawyer retained by Epstein prepared the victim for communications with U.S. immigration officials almost immediately after the wedding. Defendant/Co-Executor Kahn provided a letter of reference for the immigration proceeding. When the victim inquired about ending the marriage and leaving Epstein’s circle, EFTA00162299

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Case 22a ER Momumesnttaeil Ale eB Pepe Sib aff1Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 14 of 76 Indyke repeatedly tried to talk her out of a divorce and threatened that she would lose Epstein’s and his associates’ protection. 63. The Epstein Enterprise forced at least three separate arranged marriages, in each case requiring American female victims to marry foreign victims to avoid their deportation. The victims were coerced into to participating in these arranged marriages, and understood that there would be consequences, including serious reputational and bodily harm, if they refused to enter a marriage or attempted to end it. In each instance, Indyke and Kahn knowingly facilitated the fraudulent and coerced marriages, performing and securing the legal and accounting work involved and enabling a fraud that would further bind Epstein’s victims to him and enable Epstein to continue to control and abuse these victims sexually. 64. The Epstein Enterprise deceptively lured underage girls and women into its sex trafficking ring with money and promises of employment, career opportunities and school assistance. The Epstein Enterprise preyed on their financial and other vulnerabilities, and promised victims money, shelter, gifts, employment, tuition and other items of value. For example, participants in the Epstein Enterprise targeted young and underage females under the pretext that they would be paid substantially merely to provide massages to him and others. However, once drawn in, victims were then pressured and coerced to engage in sexual acts. 65. The Epstein Enterprise forced underage victims to recruit others to perform services and engage in sexual acts—a trafficking pyramid scheme. 66. The Epstein Enterprise paid girls for each "meeting," with additional money if they brought additional girls. Epstein reportedly required three meetings per day. EFTA00162300

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Case 122 ESR Durrett Ate Page Slibalf 1728 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 15 of 76 67. The Epstein Enterprise used the term "work" as a code for sexual abuse, and, upon information and belief, reportedly kept computer records of the contact information for the victims. 68. Consistent with his creation and use of a complex web of entities to carry out and conceal the criminal trafficking enterprise in the Virgin Islands, the Epstein Enterprise sometimes paid young women and underage girls he exploited and trafficked through his charitable foundations. 69. Once the girls and women were recruited, participants in the Epstein Enterprise enforced their sexual servitude of victims by coercion, including but not limited to, confiscating passports, controlling and extinguishing external communications, and threatening violence. They also made fraudulent statements to family members of victims, claiming victims were being well cared for and supported financially in college and other educational opportunities. 70. One of the victims, who was flown by Epstein and his associates to the Virgin Islands dozens of times up until as late as 2017, described how Epstein exercised strict control over her and other victims’ activity. The girls had to give notice if they left the main residence and were kept to a rigid set of roles and rules. Epstein brought victims to business meetings, where they were often required to massage his feet or run errands. Victims had to use Epstein- approved doctors and sign consent forms for access to their medical records. Epstein also required them to give him their email passwords. Each of these was a means of demonstrating and reinforcing his control over the women and girls. 71. During this time period through 2017, this victim observed a succession of girls and young women who were transported to Little St. James and while there were called into Epstein’s office or sauna to engage in sexual acts. EFTA00162301

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Coase 122 ER DmumesnttSibl. Pee Pepe S27 of f 1728 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 16 of 76 72. Another victim, who was brought to Little St. James more than 50 times during the years 2000 to 2002, when she was 17 to 19 years old, was required to have sexual relations with “guests” of Epstein, and was subjected to sexual abuse virtually every day, and on some days, multiple times a day by Epstein or his guests. 73. This victim, too, observed a large number of young women and girls around Epstein at Little St. James. Many of them did not speak English, which was Epstein’s preference since they spoke less. 74. Epstein sent these victims out to night clubs or on shopping trips to try to identify and recruit other young women and girls, at times paying them a fee for each recruit. 75. The Epstein Enterprise transported, held, sexually abused, trafficked, and concealed women and children at his property in the Virgin Islands dozens of times over nearly two decades. B. Defendants and Co-Executors Indyke and Kahn were Instrumental to the Epstein Enterprise’s Human Trafficking and Financial Fraud. 76. Defendants Kahn and Indyke organized, controlled, and directed almost every aspect of the Epstein Enterprise. They were officers in virtually every corporate entity that Epstein created to fund and conceal his activities. They were deeply involved in the financial activities of the Epstein-owned entities, including those of Defendant Southern Trust Company, which made clear that Southern Trust did not provide the services described to the Government as the basis for tax incentives that allowed Epstein to fraudulently obtain more than $80 million from the Government. 77. Defendants Indyke and Kahn also directed, approved, enabled, and justified millions of dollars in payments that fueled the Epstein Enterprise’s sex trafficking, including EFTA00162302

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Case 22a ER Momumesnttail Ale eB Pepe SBalf1Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 17 of 76 payments to women who were forced to have sex with Epstein and/or recruited others to be victimized. Defendants Indyke and Kahn obtained large and frequent stocks of cash for Epstein which, based on public knowledge, would have funded Epstein’s cash payments for “massages”—code for forced sex. 78. Defendants Indyke and Kahn participated with Epstein in coercing his sex trafficking victims, in at least three cases, to enter into arranged and forced marriages in order to obtain immigration status for the foreign women so that they could continue to be available to Epstein for his abuse — a doubly-deep assault on their will and dignity. Defendant Kahn provided a letter of reference for at least one immigration application and tax services to the spouses, and Defendant Indyke paid the immigration lawyer who applied for citizenship for the women and threatened at least one who indicated that she would seek a divorce. They used their professional skills and authority to carry out this abhorrent scheme. 79. Indyke and Kahn were, in short, the indispensable captains of Epstein’s criminal enterprise, roles for which they were richly rewarded. 80. Defendants Kahn and Indyke controlled and directed the activities of the other entities and personal bank accounts of Epstein accounts after they were funded. One, and frequently both, of them were officers or directors of Butterfly Trust; of companies holding Epstein’s real property (as laid out below); and of PF | a. FT Real Estate Inc.; Gratitude America, Inc.; ee. J. Epstein Virgin Islands Foundation, Inc.; Jeepers, Inc.; Mort, Inc.; Nautilus, Inc.; and Zorro Development Corporation; among others. 81. Along with their officer and director roles, Defendants Kahn and/or Indyke also had signatory authority over virtually all of the accounts held by the Epstein Enterprise entities, EFTA00162303

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Case t22eavTe sR Douresnttail Pie OWMO 2S PeagesoaffIzZe8 GVI v. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 18 of 76 which allowed them to personally authorize and sign off on payments totaling hundreds of thousands of dollars to the Enterprise’s sex-trafficking and abuse victims, including those who also acted as recruiters, and other expenses including legal fees, apartment rent, and tuition. Further, they routinely withdrew cash in various ways, including ATMs, checks, or by converting U.S. Dollars to Euros. In many instances, Kahn and/or Indyke structured these transactions in order to evade the bank’s reporting requirements. 82. Defendant Kahn also oversaw the accounting and tax reporting for the other entities in the Epstein Enterprise. As discussed below the “Tree entities,” Laurel, Maple, and Cypress, filed materially false and misleading financial statements by not including the properties in other states they owned or related expenses. These financial statements were submitted to the Office of Lieutenant Governor of the Virgin Islands and signed by Defendant Kahn. In addition, in 2013, Defendant Kahn also directed the outside accountant not to report the properties on their respective tax returns. 83. The J. Epstein Virgin Islands Foundation, Inc. (the “Foundation”’) is a 501(c)(3) tax-exempt private foundation that was founded in June 2000 and registered in the Virgin Islands. 84. As of October 23, 2007, Indyke was listed as President of the Foundation. || ee 85. Between September 2015 and June 2019, Indyke Po a a cic over a period of more than three and a half years until the middle of 2019. EFTA00162304

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Case 22a R Domumesnttasil Piet OWM22S Page DDaffZe8 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 19 of 76 86. In November 2017, Indyke PO a ee re 87. These payments were inconsistent with the charitable purpose of the Foundation and designed to serve the private benefit and criminal activities of Epstein and the Epstein Enterprise. 88. Earlier in 2017, Indyke signed a Foundation check for $160,000 to resolve a fine Epstein had incurred for construction on Great St. James Island that violated Virgin Islands environmental regulations and attempted to make the payment appear to be a charitable donation. Over two years later, the Estate had to repay this amount to the Foundation after questions were raised to Epstein’s lawyer about the propriety of the Foundation payment. 89. With help from Indyke and Kahn, Epstein established and operated separate businesses through which he could pay victims and recruiters, and, upon information and belief, which he used to maintain their immigration status. 90. [ED is a New York Limited Liability Company, the Articles of Organization of which were filed in November 2014. The Articles list a. who was forced and coerced to have sex with Epstein, PY || was manipulated, exploited, and controlled by the Epstein Enterprise. 91. According to || operating agreement, Kahn was to be the initial Manager of the company, with full and complete authority, power, and discretion to do all things necessary or convenient to manage, control, and carry out the business. Kahn also had signatory authority for ia bank accounts. EFTA00162305

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Case 22a JER Domumesnttaed Ale 2B PRegge SB aff 1728 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 20 of 76 92. One of | | bank accounts was funded entirely with money transferred from Epstein’s personal bank accounts. 93. | | payroll was paid to two persons, one of whom was the listed sole owner. Kahn gave conflicting reports to iz bank about the second person on the company’s payroll and the reasons for its payments to her. Once, he described her as an a. which would justify the payments in light of | | purported line of business, but which appears to have been false. The other time, Kahn described this payroll recipient a. which would not justify fC payments to her, but which appears to be true. 94. LSJE, LLC is a Virgin Islands Limited Liability Company that was organized on October 27, 2011. Defendants Indyke and Kahn were authorized signatories on the company’s checking account. 95. Indyke and Kahn signed company checks for combined value of almost $300,000 made out personally to young women or to, again, the immigration lawyer in New York who was involved in one or more forced marriages arranged among Epstein’s victims to secure a victim’s immigration status. 96. Upon information and belief, after his guilty plea in Florida for soliciting prostitution from a minor, Epstein began to focus on procuring and abusing women from Eastern Europe. These women’s immigration status and language barriers made them more isolated, dependent, and vulnerable to Epstein’s abuse and manipulation. 97. The Butterfly Trust is a trust created for the benefit of numerous persons who performed work for Epstein, including numerous young women with Eastern European surnames and also including Indyke and Kahn themselves. Indyke and Kahn were authorized signatories on the Trust’s checking account. EFTA00162306

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Case 22a JER Domumesttail Ale Regge P2affIZB8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 21 of 76 98. Indyke and Kahn signed trust checks for combined value of over $1,000,000 made out personally to young women, or their associated entities, who in some instances were not beneficiaries of the trust. 99. Defendants and Co-Executors Indyke and Kahn also were deeply involved with transactions made in and out of Epstein’s personal accounts, for which Indyke had signatory authority, that were flagged by bank representatives and the New York Department of Financial Services as potentially suspicious. 100. Indyke also engaged in repeated transactions that seem designed to have provided Epstein with cash in small enough increments to avoid triggering financial reporting requirements. It is well known that Epstein paid girls and women in cash for sexual encounters that began as or were euphemistically described as massages, or for recruiting other girls to provide such massages. 101. On July 20, 2016, Indyke brought two checks to a branch teller window for withdrawal, one for $7,500 drawn on Epstein’s personal account and one for $4,000 drawn on Indyke’s business account. Indyke presented the $7,500 check for cashing and stated that he would be cashing the other check the next business day to avoid all the paperwork. On July 21, 2016, Indyke returned to cash the $4,000 check. 102. From June 2018 to February 2019, there was a series of 97 separate withdrawals of $1,000 made from this account at an ATM that is a short walk from Indyke’s law office. 103. From this same account, Indyke wrote 11 checks, between April 2016 and April 2019, for the purpose of converting U.S. dollars to Euros totaling over $126,000. Some of the checks contained the notation “Euros for safe.” EFTA00162307

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Case 22a JER OMomumesnttaeil PAO eB Regge SEB alf1Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 22 of 76 104. — Also, Indyke withdrew large amounts of cash in single transactions. For instance, on January 17, 2018, Indyke cashed a check for $100,000. Although Indyke cashed the check, Kahn arranged with the Bank representative to have the cash ready for pickup. 105. | Payments from this account, for which Indyke had signatory authority, totaling over $2,500,000 were made to dozens of women with Eastern European surnames, purportedly for hotel expenses, tuition, and rent, and to, again, the immigration lawyer in New York who was involved in one or more forced marriages arranged among Epstein’s victims to secure victims’ immigration status. 106. For another of Epstein’s personal accounts with the same bank, Indyke, from 2014 to 2016, made almost 45 separate check-cashing withdrawals at a pace of two to three per month, each for the amount of $7,500, which was the bank’s limit for third-party withdrawals. 107. From this same account, between June 2014 and September 2015, Indyke wrote eight checks for the purpose of converting U.S. dollars to Euros. Each of the checks to effectuate the conversion approximated $7,500, presumably in order to evade reporting requirements, with some containing the notation “Euros for safe.” 108. Payments from this account totaling over $1,000,000 were made to dozens of women with Eastern European surnames and to, again, the immigration lawyer in New York who was involved in one or more forced marriages arranged among Epstein’s victims to secure a victim’s immigration status. 109. Indyke made wire transfers from another of Epstein’s personal accounts with a different bank totaling almost | between November 2016 and July 2019 (just before Epstein’s arrest) (0 ee EFTA00162308

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Case 22a ER Douresnttaeil Pee Page S81 aff 128 GVI v. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 23 of 76 110. From another of Epstein’s personal accounts with another different bank, for which PY someone acting on Epstein’s behalf made a total of ee a 111. Payments from this account totaling almost PO a 112. | Upon information and belief, based on their authority for the accounts, their interactions with the relevant banks, and records indicating that they made or approved the transactions, these payments could have only been made with the knowledge and/or at the direction of Indyke and Kahn. 113. The sheer complexity of the infrastructure that Epstein set up and maintained with the participation of Kahn and Indyke suggest their unlawful purpose. Based on the Government’s current knowledge, Epstein, with Kahn and Indyke, held and managed at least 140 different bank accounts for Epstein and Epstein-owned entities, many of which existed only to transfer payments to other entities and accounts. 114. Kahn and Indyke profited substantially from their relationship with Epstein. The amount of their payments is further evidence of the illicit nature of the work they performed. 115. From 2011 to 2019, Epstein and Epstein-owned entities paid over FY | to Defendant/Co-Executor Indyke, and over FY to Defendant/Co-Executor Kahn. This includes PY Based on records obtained so far, Pe ee EFTA00162309

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Case 22a ER Momumesnttaeil Pl B Regge Gtbalf1Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 24 of 76 116. Indyke and Kahn were paid through multiple entities, including HBRK Associates, Inc. (Kahn), Coatue Enterprises, LLC (Kahn), Birch Tree BR, LLC (Indyke) Harlequin Dane, LLC (Indyke) and Darren K Indyke, PLLC, which functioned as shell companies and engaged in no activities other than to coordinate the activities of Epstein’s Enterprise, including the receiving and sending money to other entities they held. 117. Since they were appointed as Co-Executors of the Epstein Estate in 2019, Defendants Indyke and Kahn have approved the release of Estate funds to pay for the legal fees and costs of persons who—like the Co-Executors themselves—are alleged herein to have participated in the criminal activity of the Epstein Enterprise. C. The "Epstein Enterprise" Abused Privileges of Residency to Carry out its Criminal Scheme 118. The Epstein Enterprise in 1998 acquired Little St. James in the Virgin Islands as the perfect hideaway and haven for trafficking young women and underage girls for sexual servitude, child abuse and sexual assault. Little St. James is a secluded, private island, nearly two miles from St. Thomas with no other residents. It can be visited only by private boat or helicopter; no public or commercial transportation is available to carry persons on or off the island, and no bridge connects the island to St. Thomas. Epstein had easy access to Little St. James from the private airfield on St. Thomas, only 10 minutes away by his private helicopter, but the women and children he trafficked, abused, and held there were not able to leave without his permission and assistance, as it was too far and dangerous to swim to St. Thomas. 119. In 2016, upon information and belief, using a straw purchaser to hide Epstein's identity, the Epstein Enterprise acquired Great St. James the nearest island to Little St. James. By then, Epstein was a convicted sex offender. Upon information and belief, the Epstein Enterprise EFTA00162310

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Case 22a JER Domuneenttail Ale Regge @balf1Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 25 of 76 purchased the island for more than $20 million because its participants wanted to ensure that the island did not become a base from which others could view their activities or visitors. By acquiring ownership and control of Great St. James to the exclusion of others, the Epstein Enterprise created additional barriers to prevent those held involuntarily on Little St. James from escaping or obtaining help from others. 120. Great St. James and Little St. James are environmentally sensitive locations, with native coral and wildlife protected by federal and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and assessed thousands of dollars of fines for violations of the Virgin Islands construction code and environmental protection laws on both Little St. James and Great St. James—significant penalties to the agency and to the average resident of the Virgin Islands. But because of Epstein's enormous wealth, these fines had little effect in curbing or stopping the Epstein Enterprise's unlawful conduct or conforming its activities to the law. 121. As aresult of illegal construction activity of the Epstein Enterprise, the Virgin Islands has incurred, and will incur, significant expenses to remove the illegal construction or remediate its effects on natural resources in and around Little St. James and Great St. James. The extent of the potential environmental damage is unknown at this time as the illegal construction has not been removed or remediated. 122. The Epstein Enterprise continues to attempt to prevent or limit DPNR authorities from conducting random inspections on the Little St. James and Great St. James necessary to comply with Virgin Islands law. EFTA00162311

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Case 22a JER Momumesttail Ale eB Pege G77 aff 128 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 26 of 76 123. The Epstein Enterprise's violation of the construction and environmental laws was part of a pattern of behavior in flouting the laws of the Virgin Islands and holding itself above the law. Upon information and belief, as described above, the Epstein Enterprise undertook construction at Great St. James after 2016 to continue the scheme to carry out and conceal his trafficking and sexual abuse of young women and children in the Virgin Islands. These actions are also indicative of the Epstein Enterprise's disregard for Virgin Islands’ law. The Epstein Enterprise used the Virgin Islands’ land, resources, people, and laws for its illicit purposes. Rather than participating lawfully in this community, the Epstein Enterprise took advantage of the secluded nature of the islands in furtherance of its crimes. 124. As aresult of its deplorable and unlawful conduct, the Epstein Enterprise has subjected the Virgin Islands to public portrayals as a hiding place for human trafficking and sex crimes. D. The "Epstein Enterprise" Fraudulently Concealed its Conduct 125. The Epstein Enterprise fraudulently concealed its actions to prevent detection by the Government of the Virgin Islands. 126. The secluded properties at Little St. James and Great St. James were repeatedly used by the Epstein Enterprise as the locations for unlawfully soliciting, transporting, transferring, harboring, receiving, providing, isolating, patronizing, maintaining, deceiving, coercing, and sexually abusing young women and children and concealing these crimes. 127. The Epstein Enterprise was able to hide the trafficking ring from law enforcement, despite the fact that Epstein was a registered sex offender. Given the isolation of the Little St. James and Great St. James and the nature of the crimes and of the victims targeted by the Epstein Enterprise, the activities of the Epstein Enterprise were not readily detectable. EFTA00162312

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Case 22a ER Mounts PAletOU eS ReageeBalfIZe GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 27 of 76 Moreover, Epstein's great wealth and power likely made witnesses reluctant to report their observations to the local law enforcement. 128. Upon information and belief, the Epstein Enterprise prevented its employees from cooperating with law enforcement. Employees and others were required to sign confidentiality agreements that prohibited them from speaking to or sharing information with law enforcement. If they were contacted by law enforcement they were to notify the Epstein Enterprise and be represented by Epstein's counsel. 129. The employees were directed not to communicate or interact with guests visiting Little St. James and were also directed not to disclose to anyone events that occurred on the island. 130. Monitoring a sex offender with his own private islands and the resources to fly victims in and out on private planes and helicopters presented unique challenges and allowed the Epstein Enterprise to limit scrutiny by the Government of the Virgin Islands. 131. Sexual Offender Registration and Community Protection Act ("SORCPA") 14 V.LC. § 1721, et. seq. requires sex offenders to register in their resident jurisdictions and to make periodic in-person appearances to verify and update their registration information. 132. Epstein renewed his registration each year in the Virgin Islands. In addition, beyond this statutory requirement, the Virgin Islands periodically visited—or attempted to visit—Little St. James to conduct additional address verifications. 133. At his last verification in July 2018, Epstein refused to permit Virgin Islands Department of Justice Investigators, assisted by United States Marshals, to enter Little St. James beyond its dock, claiming that the dock was his "front door." Instead, Epstein arranged to be met at his office on St. Thomas. EFTA00162313

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Case 22 ER DomumesnttSis il PO Peg RDalf ZB GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 28 of 76 134. Epstein also misled the Government regarding his travel plans. On March 19, 2019, the Virgin Islands was notified that Epstein would be traveling to France for 10 days on the private plane owned by Plan D, LLC. His notification form did not disclose travel to any other countries. It was later found by law enforcement authorities that Epstein also travelled to Vienna and Monaco during that trip. 135. Similarly, the Epstein Enterprise sought to prevent DPNR from conducting routine site visits to inspect unpermitted and potentially damaging construction activity on Great St. James. The Epstein Enterprise repeatedly objected to DPNR's inspections referring to them as "invasions" of Epstein's constitutional right to privacy in his home, which he described defined as the entire island. These DPNR inspections are required for all construction and Virgin Islands residents are required to cooperate with the inspections to assure compliance with the law throughout the construction phases. 136. These efforts represent Epstein Enterprise's intent to conceal its unlawful activity on Little St. James and Great St. James. 137. The Epstein Enterprise also created numerous corporations and limited liability companies in the Virgin Islands to help conceal its unlawful activity. Most of these companies were created in 2011 and 2012, soon after Epstein registered as a sex offender in the Virgin Islands. 138. Epstein's pilot, Larry Visoski is identified as member or co-member in companies that serviced and maintained the planes that the Epstein Enterprise used to traffick young women and children — Freedom Air Petroleum, LLC (registered November 28, 2011 to hold assets): and JEGE, LLC (registered October 19, 2012 to hold assets). EFTA00162314

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Case 22a JER Momumeenttail Ale OUN eS RegpeealfIze8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 29 of 76 139. Other Epstein entities include LSJ Employees, LLC (registered October 27, 2011 to provide services); Southern Financial, LLC (registered February 25, 2013 to provide services) and LSJ Emergency, LLC (registered December 2, 2015 to provide services). 140. Some of these companies held considerable assets: Financial Informatics, Inc. (incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of approximately $391 million in 2015; and Financial Trust Company, Inc. (incorporated November 6, 1998) had assets of $212 million when it publicly filed its last balance sheet in 2012. 141. Though often absent in the original incorporation or registration documents or annual filings, Epstein ultimately appeared as president, director, manager, or sole member of each of these companies. Upon information and belief, the purpose of this complex array of corporate entities—some of which may still be discovered—was to allow Epstein to shelter his assets in order to fund, carry out, and conceal his identity and pattern of criminal conduct. 142. The Estate continues to engage in a course of conduct aimed at concealing the criminal activities of the Epstein Enterprise. On November 24, 2019, Epstein's Estate filed an Expedited Motion for Establishment of a Voluntary Claims Resolution Program in the Superior Court of the Virgin Islands. ("Motion"). According to the Motion, the proposed program was to be designed to “establish an independent and voluntary claims resolution program for purposes of resolving sexual abuse claims against Jeffrey E. Epstein." (Motion, at 1). 143. The program proposed by the Estate, whose executors are trustees of The 1953 Trust and officers in at least two Epstein entities, imposes confidentiality requirements and requires any claimant accepting an award under the program to sacrifice any other claims against “any person or entity arising from or related to Mr. Epstein's conduct." (Motion, at 5). It acts to EFTA00162315

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Coase 122 ER DmumresnttSib ll Pie Pepe GBLaff ZB GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 30 of 76 conceal the criminal activities of the Epstein Enterprise and shield its participants from liability and accountability for the injury they caused to the victims. 144. The Estate also refused to agree to preserve documents or to release individuals from the non-disclosure agreements. 145. Two days before his death, Epstein amended The Trust and his Last Will and Testament. Upon information and belief, he did so, as part of a pattern and ongoing effort to conceal and shield his assets from potential recovery by claimants. E. The "Epstein Enterprise" Violated Numerous Virgin Islands Laws 146. The pattern of criminal activity engaged in by Epstein and other participants in the Epstein Enterprise violated 14 V.LC. §§ 605 and 607 of the Criminally Influenced and Corrupt Organizations Act ("CICO"). 147. The Epstein Enterprise also violated Title 14, Chapter 3A, The Virgin Islands Uniform Prevention of and Remedies for Human Trafficking Act relating to Trafficking of Persons; Title 14, Chapter 24, relating to Child Protection and Child Abuse and Neglect; Title 14, Chapter 81, relating to Prostitution and Related Offenses; Title 18, Chapter 85, relating to Rape and Sexual Assault and other related offenses, as well as other Virgin Islands laws. 148. The Epstein Enterprise violated Virgin Islands laws by engaging in the human trafficking of underage girls and young women and commercial sex with young women and underage girls by force, fraud, enticement, or coercion, which serve as predicates to the Epstein Enterprise's violations of CICO. 149. — Certain participants who recruited women and underage girls to be trafficked and forced into sexual servitude themselves were sexually trafficked and abused by the Epstein Enterprise and may be afforded the protections of 14 V.LC. § 145. EFTA00162316

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Case 22a ER Momumeenttail Ale OUMe Reape e2aifize8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 31 of 76 150. Specifically, Plan D, LLC knowingly and intentionally facilitated the trafficking scheme by flying underage girls and young women into the Virgin Islands to be delivered into sexual servitude. Plan D LLC repeatedly made flights from the mainland to St. Thomas with Epstein and underage girls and young women for the purpose of engaging in sexual activity on Little St. James. On some occasions, they would transport Epstein and female children by helicopter to Little St. James. On other occasions, Epstein and the young women and girls would be transported by boat. 151. Great St. Jim, LLC and Nautilus, Inc. knowingly participated in the Epstein Enterprise and facilitated the trafficking and sexual servitude of young women and underage girls by providing the secluded properties at, from, or to which Epstein and his associates were able to transport, transfer, receive, maintain, isolate, harbor, provide, entice, deceive, coerce, and sexually abuse underage girls and young women. 152. The Epstein Enterprise engaged in a continuing course of unlawful conduct. 153. | After Epstein's suicide, the Epstein Enterprise continued to exist as each of the participants continued to conspire to prevent detection of the breadth and scope of the Epstein Enterprise's criminal wrongdoing and to prevent accountability. These conspiratorial acts are ongoing. 154. | The conduct of the Epstein Enterprise offends the core purpose of the Virgin Islands Uniform Prevention of and Remedies for Human Trafficking Act, 14 V.LC. §131 et seq, and violates CICO, enacted to “curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14 V.LC. § 601. EFTA00162317

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Case 22a JER Domuresttal Ale Pepe GBalf1Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 32 of 76 155. | The Epstein Enterprise is an illicit enterprise within the meaning of 14 V.LC. §§ 604 and 605. 156. |The Government is entitled to recover civil penalties, damages and other remedies and to extinguish and recoup from the Epstein Enterprise and its participants any and all financial and other benefits, and any personal and real property that was used during the course of, or intended for use in the Course of the conduct or criminal activity in violation of the laws of the Virgin Islands. The Government is entitled to obtain through divestiture, forfeiture, or other equitable relief all properties and instrumentalities used by the Epstein Enterprise in the criminal pattern of trafficking and sexual abuse in the Virgin Islands, including but not limited to Great St. James and Little St. James, and all other remedies and penalties permitted by law in the interest of justice. F. The Epstein Enterprise Used Corporate Entities to Defraud the Government and Fund its Criminal Activities 1. Defendant Southern Trust Company, Inc. 157. In October 2012, the Southern Trust Company applied for economic benefits from the Economic Development Commission ("EDC"). The EDC is a subsidiary of the Virgin Islands Economic Development Authority ("EDA"), a semi-autonomous governmental instrumentality created and governed pursuant to 29 VIC § 1101. 158. In sworn testimony at a public hearing on the tax incentive application conducted by the EDC on November 15, 2012, Epstein and his attorney, Ericka Kellerhals, described Southern Trust Company as providing "cutting edge consulting services" in the area of "biomedical and financial informatics." EFTA00162318

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Coase 122 ER DomumresnttSib ll. FeO Pepe GB af 1728 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 33 of 76 159. The EDC granted Southern Trust Company a 10-year package of economic incentives running from February 1, 2013 until January 31, 2023 that included a 90% exemption from income taxes and 100% exemptions from gross receipts, excise, and withholding taxes in the Virgin Islands. 160. Between 2013 and 2019, Southern Trust Company employed 13 different individuals (not including Epstein). Of those 13 individuals, 11 served in administrative or support roles: six as personal, administrative, or executive assistants, receptionists, or as a driver/helper, one as an office manager, one as a clerk, and three in accounting or payroll functions (though only one was licensed as a certified public accountant). There was one network administrator/IT manager, and a second who was added in 2019. 161. In fact, several of those individuals seemed to perform other personal services for Jeffrey Epstein. Though he was reported by Southern Trust Company to be resident of the Virgin Islands, the network administrator/IT manager was issued a Florida driver's license, which listed an address in Miami. Further, he appears, in fact, to have served as Epstein's driver and picked up luggage and cargo from Epstein's private planes on his behalf. 162. Another executive assistant lived at 301 E. 66th Street, Apartment 11B, New York, New York. Epstein's address book lists various units in this building as providing "Apt. for models" and she is publicly identified as a model. As noted above, the Epstein Enterprise used modeling opportunities and contracts as a pretext for recruiting underage girls and young women into its sex trafficking scheme. 163. Financial records more recently obtained show that the employee described above whom Kahn represented to be, alternatively, ee. was also a EFTA00162319

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Case 22a ER Momunesnttaeil Ale OTB Regge Ebalf1ZB8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 34 of 76 PY which did not actually or even pretend to perform either i 2010. 164. During several time periods, Southern Trust Company affirmed to EDC that it had no employees who were non-residents, even though it employed non-residents. 165. Southern Trust company does not appear to have had any clients and performed no visible informatics services. According to financial records, it held no investments for others. Instead, its employees performed tasks related to any number of other Epstein-owned companies or properties, such as Little St. James. 166. Despite having no visible clients and only one full-time employee working on information technology during the bulk of the period, Southern Trust Company reportedly generated net income of $50.3 million in 2013, $67.5 million in 2014, $52.8 million in 2015, and $4.8 million in 2016 and $17.1 million in 2017, with aggregate income of $117.8 million in 2014, $170.6 million in 2015, $175.3 million in 2016 and $192.4 million in 2017, or aggregate income for the period of $656 million. 167. | Money received by Southern Trust was then funneled, frequently by Defendant Indyke as authorized signatory, and often with copies given to Defendant Kahn, through other Epstein-owned entities and accounts, funding payments to foreign women and for credit cards, airplanes, and other instrumentalities of the Epstein Enterprise. 168. In fact, the main source of funds for the Epstein Enterprise came from Southern Trust. Between 2013 and 2017, Southern Trust reported approximately $184 million in revenues. 169. Defendants Kahn and Indyke directed and controlled the day-to-day activities of Southern Trust in form and in substance, serving as members of its Board of Directors, along EFTA00162320

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Case 22a ER Momumesntta4l Flee Pepe Bbalf1ZB GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 35 of 76 with Epstein. Indyke was a signatory on Southern Trust’s primary bank account to which funds were wired, primarily from a single source, as described below. Kahn, as Southern Trust’s treasurer, oversaw its accounting, invoicing, and tax reporting. Indyke also authorized a majority of the wire transfers from Southern Trust’s bank account in order to fund the various entities and personal bank accounts of Epstein, and had full inquiry capabilities over the account. 170. Bank records show that virtually all of Southern Trust Company’s income came from a single source (including related entities). 171. Inall, the single source paid $158 million to Defendant Southern Trust Company from 2013 to 2017, which constitutes 85% of the total revenues reported by Southern Trust Company. These funds appear to have not been used to pay for informatics or datamining services. 172. | These payments to Southern Trust were the main source of funds for Epstein’s Enterprise. Indeed, no other entity in Epstein’s Enterprise generated revenues. Funds received from the single source were funneled, at the direction of Kahn and Indyke, to Epstein’s personal accounts, and other Epstein entities to fund his criminal activities. 173. For the period between January 1, 2013 and December 31, 2017, Southern Trust Company received tax exemptions totaling $73.6 million. 174. As of December 31, 2017, Southern Trust Company, Inc. elected to file its income tax as an S-corporation, which elects to pass corporate income, losses, deductions and credits through to its sole shareholder—Jeffrey Epstein—for tax purposes. For this time period, Epstein's income tax exemption was $71.3 million. EFTA00162321

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Crase 122 Durrett PAO Page 27 aff 1Z3 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 36 of 76 175. Including gross receipt taxes, the Government currently estimates that, as a result of the EDC incentive, Epstein was able to avoid paying $80,576,236 in taxes. 176. Based upon these facts, it is clear that Southern Trust Company did not perform the "informatics" business represented to the EDC and could not have generated the business income attributable to that business. Instead, upon information and belief, Southern Trust Company existed to secure tax benefits for Epstein, to employ individuals associated with the Epstein Enterprise, and to provide a source of income to support his criminal activities and properties in the Virgin Islands. 2. Defendants Cypress, Inc.; Maple, Inc.; and Laurel, Inc. 177. Epstein formed Cypress, Inc.; Maple, Inc.; and Laurel, Inc. as Virgin Islands corporations in or about November 2011. 178. As of December 31, 2018, Epstein was listed as President Director and Defendants and Co-Executors Indyke and Kahn were listed, respectively, as Vice President/ Secretary/Director and Treasurer/Director of each of Cypress, Inc.; Maple, Inc.; and Laurel, Inc. 179. Defendant Cypress, Inc. acquired ownership of the property 49 Zorro Ranch Road in Stanley, New Mexico in or about December 2011, shortly after Cypress was formed. 180. | Defendant Maple, Inc. acquired ownership of the property 9 East 71st Street in New York, New York on or about December 23, 2011, shortly after Maple was formed. Maple acquired ownership of the property from Nine East 71st Street Corporation, which was owned by Epstein. 181. Defendant Laurel, Inc. acquired ownership of the property 358 Brillo Way in Palm Beach, Florida in or about December 2011, shortly after Cyrpess was formed. Laurel acquired ownership of the property from Epstein personally. EFTA00162322

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Case 22a R Douresnttasil PieiOWM22 Page GBalfIZ8 GVI v. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 37 of 76 182. Epstein appears to have maintained divided ownership of these properties, transferred ownership of them to the Virgin Islands, and then concealed this fact even from Virgin Islands authorities in an attempt to shield the properties from any judgment in the states where they are located. 183. The financial statements submitted by each of these three Defendant corporations to the Office of Lieutenant Governor of the Virgin Islands were false and misleading due to their failure to include the above properties owned by each company or the related expenses incurred by each company, such as property taxes. 184. For instance, Cypress’s Balance Sheet as of December 31, 2018 did not reflect any assets other than cash of $18,824. Further, Cypress reported only $301 in expenses for the year ended December 31, 2018, despite it paying BP a. 185. Similarly, in 2017, Cypress reported as its only asset cash in the amount of $29,736 and expenses of $150, despite it paying a. 186. Similarly, for the tax years 2011 through 2016, Cypress did not include the value of the New Mexico property in the total assets it reported and did not include any expenses related to the New Mexico property in the total expenses it reported to the Government. 187. | Likewise, Maple’s balance sheet as of December 31, 2018 did not reflect any assets other than cash of $21,265. Further, Maple reported only $300 in expenses for the year ended December 31, 2018, despite it paying Po EFTA00162323

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Case 22a R Doumesnttsil PietOWM22S Page BiaffIZe8 GVI v. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 38 of 76 188. Similarly, in 2017, Maple reported as its only asset cash in the amount of $18,281 and expenses of $150, despite it paying PO a 189. Similarly, for the tax years 2011 through 2016, Maple did not include the value of the New York property in the total assets it reported and did not include any expenses related to the New York property in the total expenses it reported to the Government. 190. Likewise, Laurel’s balance sheet as of December 31, 2018 did not reflect any assets other than cash in the amount of $20,155. Further, Laurel reported only $300 in expenses for the year ended December 31, 2018, despite it paying Po] as 191. Similarly, in 2017, Laurel reported as its only asset cash in the amount of $37,129 and expenses of $150, despite it paying PO a. 192. Similarly, for the tax years 2011 through 2016, Laurel did not include the value of the Palm Beach property in the total assets it reported and did not include any expenses related to the Palm Beach property in the total expenses it reported to the Government. 193. Neither Cypress’s, Maple’s, nor Laurel’s financial statements ever reflected the reality of the above assets held or the above expenses incurred by each entity. 194. The Annual Reports submitted on behalf of Cypress, Maple, and Laurel all were signed by Epstein and Defendant and Co-Executor Kahn with the representation that “ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT...” EFTA00162324

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Crase 122 ESR Durst PAO Rage Dalf1Ze8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 39 of 76 195. In fact, Indyke and Kahn knew or should have known that their attestations were false. Upon information and belief, particularly given the absence of any other justification for these transactions and the fraudulent nature of their reporting, these transactions were made for the sole purpose of sheltering these assets from collection. STATUTES OF LIMITATIONS ARE TOLLED AND DEFENDANTS ARE ESTOPPED FROM ASSERTING STATUTES OF LIMITATIONS AS DEFENSES 1. Equitable Estoppel and Fraudulent Concealment 196. Defendants are equitably estopped from relying upon a statute of limitations defense for conduct that occurred prior to the limitation period because they undertook active efforts to deceive the Government and to purposefully conceal their unlawful conduct and fraudulently assure public authorities that their conduct was in compliance with the laws, all with the goal of avoiding punishment. 197. Defendants were deliberate in taking steps to conceal their criminal sex trafficking and abuse conduct and their fraudulent conduct in obtaining unearned tax benefits from the Government. Defendants’ acts of concealment include, but are not limited to, the following. 198. Defendants used Epstein’s secluded island of Little St. James and his later purchase of the nearby island of Great St. James to shield their trafficking and sexual abuse of young women and female children from detection by law enforcement authorities and to prevent their victims from escaping. 199. Defendants used Epstein’s private aircraft to transport young women and female children to the Virgin Islands and to Little St. James while limiting public observation of this trafficking activity. EFTA00162325

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Case tt 22a ER Doutta Piet OWM 2S Page Zl aff1Z8 GVI v. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 40 of 76 200. Defendants used Epstein’s businesses and ostensibly charitable foundations in the Virgin Islands to make payments to the victims who were trafficked and sexually abused while concealing these payments from detection by law enforcement authorities. 201. Defendants also prevented Epstein Enterprise entity employees from cooperating with law enforcement by requiring them to sign confidentiality and non-disclosure agreements. 202. Defendants also actively obstructed law enforcement by denying investigators access to Little St. James beyond its boat dock. 203 ee 206. Defendants also concealed their fraud on the Government in obtaining unearned tax benefits by providing false testimony and submitting false and inaccurate reporting to the Economic Development Commission to prevent detection of Defendant Southern Trust Company’s non-compliance with requirements concerning the nature of its business and the residency of the persons it employed. 207. The discovery of the nature, scope, and magnitude of Defendants’ unlawful conduct and could not have been acquired earlier through the exercise of reasonable diligence. EFTA00162326

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Case 22a JER Momumeenttail Ale B Peg M2 aff 128 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 41 of 76 2. Continuing Violations 208. The continuous criminal conduct by the Defendants has caused repeated and continuous injury. 209. Defendants criminal trafficking and sexual abuse of young women and female children in the Virgin Islands occurred continuously from Epstein’s purchase of Little St. James in 1998 through his arrest and death in prison in 2019. 210. — Flight logs and other sources establish that between 2001 and 2019, Defendants transported young women and female children to the Virgin Islands, where they were then transported by private helicopter or boat to Little St. James. 211. — Air traffic controllers and airport personnel have reported seeing, as recently as 2018, Epstein leaving his private jet with young girls who appeared to be between the ages of 11 and 18 years. 212. One victim was brought by Defendants more than 50 times between 2000 and 2002, when she was around 18 to 20 years old, to Little St. James, where she was required to have sexual relations with Epstein or his guests multiple times per day and where she saw large numbers of other young women and female children subject to the same treatment. 213. Another victim was brought by Defendants dozens of times between 2004 and 2017 to Little St. James, where she too observed a succession of young women and female children who likewise were transported to the island and were required to have sexual relations with Epstein and his guests. 214. Defendants’ fraud on the Government in obtaining unearned tax benefits through Defendant Southern Trust Company likewise was continuous inasmuch as Southern Trust’s failure to perform the informatics services that it represented to the Economic Development EFTA00162327

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Case 22a ER MomumresnttSe. Ale OTB PRegge AB aAfIZB GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 42 of 76 Commission and its false reporting of the residency and job descriptions of its employees were continuous from the start of the tax benefits in 2013 through Epstein’s arrest and death in prison in 2019. 215. The continued criminal conduct by Defendants has caused repeated and continuous injury. The criminal conduct of the Epstein Enterprise was not completed nor were all damages incurred until the wrongdoing ceased. COUNT ONE Human Trafficking — Trafficking an Individual Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"), 14 V.LC. § 600 et seq. and 14 V.L.C § 133 216. The Government restates and realleges paragraphs | to 215 of this Complaint as if fully set forth herein. 217. — Atall times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 218. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly recruiting, transporting, transferring, harboring, receiving, providing, obtaining, isolating, maintaining, or enticing female children and young women in the furtherance and performance of forced labor, sexual servitude and commercial sexual activity in violation of Virgin Islands laws codified in 14 V.LC. §§ 133-138. 219. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 220. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. EFTA00162328

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Case 22a JER OMomumesttaeil PAO RB PRegge PB aff 1728 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 43 of 76 221. —Atall times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.14 V.L.C. §600 et seq. COUNT TWO Human Trafficking — Trafficking an Individual Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.LC. § 600 et seg. and 14 V.LC § 133 222. The Government restates and realleges paragraphs | to 221 of this Complaint as if fully set forth herein. 223. — At all times material herein, each Defendant joined in a conspiracy to violate laws prohibiting human trafficking. 224. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by recruiting, transporting, transferring, harboring, receiving, providing, obtaining, isolating, maintaining or enticing female children and young women in the furtherance and performance of forced labor, sexual servitude and commercial sexual activity in violation of Virgin Islands laws codified in 14 V.LC. § 133 -138. 225. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. 226. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.LC. §604(j). EFTA00162329

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Case 22a ER Momumesttail Ale Regge stbalfIZe GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 44 of 76 227. — Atall times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. §600 et seg. COUNT THREE Human Trafficking — Forced Labor Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.LC. § 600 et seg. and 14 V.IL.C § 134 228. The Government restates and realleges paragraphs | to 227 of this Complaint as if fully set forth herein. 229. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 230. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly using coercion to compel underage girls and young women to provide labor or services by forced labor in violation of 14 V.LC. § 134. 231. The Epstein Enterprise knowingly provided or obtained the labor services of individuals by means of force, threats of force, physical restraint, and/or threats of physical restraint; by means of serious harm or threats of serious harm; by means of abuse or threatened abuse of law or legal processes; and by means of the Epstein Enterprise with the intent to cause individuals to believe that, if individuals did not perform such labor or services, individuals would suffer serious harm or physical restraint. 232. Defendants through a pattern of criminal activity directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. EFTA00162330

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Case 22a JER Momumesttail Flee Regge sibalf1Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 45 of 76 233. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 234. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 235. Atall times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. §600 et seq. COUNT FOUR Human Trafficking — Forced Labor Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.L.C. § 600 et seg. and 14 V.L.C § 134 236. The Government restates and realleges paragraphs 1 to 235 of this Complaint as if fully set forth herein. 237. —_Atall times material herein, each Defendant joined in a conspiracy to violate laws prohibiting human trafficking. 238. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by knowingly using coercion to compel underage girls and young women to provide labor or services by forced labor in violation of 14 V.LC. § 134. 239. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. EFTA00162331

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Case 22a JER Domumesnttaeil Ale B Pegg Sl aff 128 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 46 of 76 240. — At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.LC. §604(j). 241. — Atall times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. §600 et seq. COUNT FIVE Human Trafficking — Sexual Servitude Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.LC. § 600 et seg. and 14 V.LC § 135 242. The Government restates and realleges paragraphs | to 241 of this Complaint as if fully set forth herein. 243. — Atall times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 244. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly maintaining or making available minors for the purpose of engaging the minors in commercial sexual activities or using coercion or deception to force young women to engage in commercial sexual activity in violation of 14 V.LC. § 135. 245. On the pretext of providing modeling opportunities, careers and contracts, Defendants facilitated the transporting or recruiting of young women and girls or lured and recruited young women and underage girls to travel to the Virgin Islands where they engaged in sexual acts with Epstein and others. In some instances, young women and underage girls were EFTA00162332

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Case 22a ER Momumesnttaeil Ale Regge siBalf1Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 47 of 76 given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and others. 246. Defendants through a pattern of criminal activity directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 247. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 248. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 249. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. §600 et seq. COUNT SIX Human Trafficking — Sexual Servitude Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.LC. § 600 et seg. and 14 V.LC § 135 250. The Government restates and realleges paragraphs | to 249 of this Complaint as if fully set forth herein. 251. Atall times material herein, each Defendant joined in a conspiracy to violate laws prohibiting human trafficking. 252. Each Defendant engaged in acts that revealed its intent to join the criminal conspiracy by knowingly maintaining or making available minors for the purpose of engaging the minors in commercial sexual activities or using coercion or deception to force young women to engage in commercial sexual activity in violation of 14 V.LC. § 135. EFTA00162333

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Case 22a JER Momumeenttaedl Flee Regge siPalf1ZB GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 48 of 76 253. On the pretext of providing modeling opportunities, careers and contracts, Defendants facilitated the transporting or recruiting of young women and girls or lured and recruited young women and underage girls to travel to the Virgin Islands where they engaged in sexual acts with Epstein and others. In some instances, young women and underage girls were given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and others. 254. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. 255. — Atall times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.LC. §604(j). 256. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. §600 et seq. COUNT SEVEN Human Trafficking — Patronizing Minors and Victims of Sexual Servitude Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.LC. § 600 et seq. and 14 V.LC §§ 136-37 257. The Government restates and realleges paragraphs | to 256 of this Complaint as if fully set forth herein. 258. = Atall times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. EFTA00162334

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Case 22a ER Momumeettail Ale OUN eS Reagedalfize8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 49 of 76 259. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly giving, agreeing to give, or offering to give items of value to young women and minors so that the young women and minors would engage in commercial sexual activity with Epstein, other Defendants, and other individuals in violation of 14 V.LC. §§ 136-137. 260. In some instances, young women and underage girls were given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and others. 261. Defendants through a pattern of criminal activity directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 262. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 263. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 264. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 14 V.LC. §600 et seq. COUNT EIGHT Human Trafficking — Patronizing Minors and Victims of Sexual Servitude Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.LC. § 600 et seg. and 14 V.LC §§ 136-37 265. The Government restates and realleges paragraphs | to 264 of this Complaint as if fully set forth herein EFTA00162335

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Case 22a JER OMomumesnttail Ale eB Regge sal aff128 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 50 of 76 266. At all times material herein, each Defendant joined in a conspiracy to violate laws prohibiting human trafficking. 267. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by knowingly giving, agreeing to give, or offering to give items of value to young women and minors so that the young women and minors would engage in commercial sexual activity with Epstein, other Defendants, and other individuals in violation of 14 V.LC. §§ 136-137. 268. In some instances, young women and underage girls were given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and others. 269. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. 270. — Atall times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 271. — Atall times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 14 V.LC. $600 et seq. EFTA00162336

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Case 22a ER OMomumeenttaeil Ale B Regge s2ahf1Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 51 of 76 COUNT NINE Child Abuse and Neglect—All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual Capacities Violation of the Criminally Influenced and Corrupt Organization Act, 14 V.LC. § 600 et seg. and 14 V.L.C §§ 505, 506 and 507 272. The Government restates and realleges paragraphs | to 271 of this Complaint as if as if fully set forth herein. 273. — Atall times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 274. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, knowingly or recklessly causing a child to suffer physical, mental or emotional injury, or knowingly or recklessly causing a child to be placed in a situation where it is reasonably foreseeable that such child may suffer physical, mental or emotional injury, in violation Virgin Islands criminal laws prohibiting Child Abuse and Neglect in Title 14 V.LC. § 500 et. seg. 275. As a result of the Epstein Enterprise's actions numerous young girls suffered serious physical, mental and emotional injury. 276. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 277. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 278. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. §600 et seq. EFTA00162337

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Case 1 22eu ER DomumresnttSipl. Pee OT Pepe Bal f 128 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 52 of 76 COUNT TEN Child Abuse and Neglect Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act —All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual Capacities, 14 V.L.C. § 600 et seg. and 14 V.I.C §§ 505, 506 and 507 279. The Government restates and realleges paragraphs | to 278 of this Complaint as if as if fully set forth herein. 280. — Atall times material herein, each Defendant joined in a conspiracy to violate laws prohibiting child abuse and neglect. 281. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy as they knowingly or recklessly caused a child to suffer physical, mental or emotional injury, or knowingly or recklessly caused a child to be placed in a situation where it is reasonably foreseeable that such child may suffer physical, mental or emotional injury, in violation Virgin Islands criminal laws prohibiting Child Abuse and Neglect in Title 14 V.LC. § 500 et seq. 282. Asaresult of Defendants’ actions, numerous young girls suffered serious physical, mental and emotional injury. 283. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. 284. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.LC. §604(j). EFTA00162338

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Case 22a JER Momumeenttaeil Ale Regge si alf1Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 53 of 76 285. — Atall times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. §600 et seq. COUNT ELEVEN Aggravated Rape—All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual Capacities Violation of the Criminally Influenced and Corrupt Organization Act, 14 V.LC. § 600 et seg. and 14 V.LC § 1700a 286. The Government restates and realleges paragraphs | to 285 of this Complaint as if fully set forth herein. 287. — Atall times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 288. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, conduct that constituted or facilitated the rape of minors by force, intimidation, or the perpetrator's position of authority over the victim. 289. Epstein and others, using force or intimidation, engaged in sexual intercourse with underage girls without their consent in violation of 14 V.LC. § 1700a. 290. As a result of the Epstein Enterprise's actions, numerous underage girls suffered serious physical, mental and emotional injury. 291. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 292. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. EFTA00162339

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Coase 122 ER DmumresnttSieb il Pee Pepe Hbaff 128 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 54 of 76 293. — Atall times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. §600 et seq. COUNT TWELVE Aggravated Rape Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, —All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual Capacities, 14 V.LC. § 600 et seg. and 14 V.LC § 1700a 294. The Government restates and realleges paragraphs | to 293 of this Complaint as if fully set forth herein. 295. — At all times material herein, each Defendant joined in a conspiracy to violate laws prohibiting aggravated rape. 296. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by engaging in conduct that constituted or facilitated the rape of minors by force, intimidation, or the perpetrator's position of authority over the victim. 297. — Epstein and others, using force or intimidation, engaged in sexual intercourse with underage girls without their consent in violation of 14 V.LC. § 1700a. 298. As aresult of Defendants’ actions, numerous underage girls suffered serious physical, mental and emotional injury 299. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. EFTA00162340

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Case 22a ER Momumesttaeil Flee Regge ib alf1Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 55 of 76 300. — Atall times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.LC. §604(j). 301. — Atall times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. §600 et seq. COUNT THIRTEEN Rape in the Second Degree—All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual Capacities Violation of the Criminally Influenced and Corrupt Organization Act, 14 V.LC. § 600 et seq. and 14 V.LC § 1702 14 V.LC. § 600 et seg. and 14 V.LC § 1700a 302. The Government restates and realleges paragraphs | to 301 of this Complaint as if fully set forth herein. 303. Atall times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 304. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, conduct that constituted or facilitated the rape of girls under 18 years of age. 305. Epstein and others who engaged in rape were over 18 years old at the time of the incidents. 306. As a result of the Epstein Enterprise's actions, numerous minors suffered serious physical, mental and emotional injury. 307. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. EFTA00162341

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Coase 122 ER DomuesnttSisl. Pie OAT Pepe G7 aff 1728 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 56 of 76 308. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 309. — Atall times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. §600 ef seq. COUNT FOURTEEN Rape in the Second Degree Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, —All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual Capacities, 14 V.LC. § 600 et seg. and 14 V.I.C § 1702 310. |The Government restates and realleges paragraphs | to 309 of this Complaint as if fully set forth herein. 311. Atall times material herein, each Defendant joined in a conspiracy to violate laws prohibiting rape in the second degree. 312. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by engaging in conduct that constituted or facilitated the rape of girls under 18 years of age. 313. Epstein and others who engaged in rape were over 18 years old at the time of the incidents. 314. — Asa result of Defendants’ actions, numerous minors suffered serious physical, mental and emotional injury. 315. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, EFTA00162342

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Case 22a ER Momumesnttaeil Ale Regge SBalf1Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 57 of 76 forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. 316. — Atall times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.LC. §604(j). 317. Atall times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. §600 et seq. COUNT FIFTEEN Unlawful Sexual Contact in the First or Second Degree—All Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual Capacities Violation of the Criminally Influenced and Corrupt Organization Act, 14 V.LC. § 600 et seq. and 14 V.I.C §§ 1708 and 1709 318. The Government restates and realleges paragraphs | to 317 of this Complaint as if as if fully set forth herein. 319. Atall times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 320. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, using or facilitating the use of force or coercion to accomplish sexual contact or engaging in sexual contact with a minor between 13 and 16 years of age. 321. Epstein and others who engaged in the sexual contact were over 18 years old at the time of the incidents. 322. As aresult of the Epstein Enterprise's actions numerous young women and minors suffered serious physical, mental and emotional injury. EFTA00162343

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Case 22a ER MDomumesnttaeil PAO eB Regge SPalf1Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 58 of 76 323. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 324. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 325. Atall times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 14 V.LC. §600 et seq. COUNT SIXTEEN Unlawful Sexual Contact in the First or Second Degree Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act —AII Defendants Except Darren K. Indyke and Richard D. Kahn in Their Individual Capacities, 14 V.LC. § 600 et seg. and 14 V.I.C §§ 1708 and 1709 326. The Government restates and realleges paragraphs | to 325 of this Complaint as if as if fully set forth herein. 327. — Atall times material herein, each Defendant joined in a conspiracy to violate laws prohibiting unlawful sexual contact. 328. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by using or facilitating the use of force or coercion to accomplish sexual contact or engaging in sexual contact with a minor between 13 and 16 years of age. 329. Epstein and others who engaged in the sexual contact were over 18 years old at the time of the incidents. 330. As aresult of Defendants’ actions, numerous young women and minors suffered serious physical, mental and emotional injury. EFTA00162344

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Case 22a ER Momumeenttail Ale OUN eS Reape alfIze8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 59 of 76 331. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. 332. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.LC. §604(j). 333. — Atall times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 14 V.LC. §600 et seg. COUNT SEVENTEEN Prostitution and Keeping House of Prostitution Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.LC. § 600 et seq. and 14 V.I.C. §§ 1622, 1624 334. The Government restates and realleges paragraphs | to 333 of this Complaint as if fully set forth herein. 335. Atall times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 336. The Epstein Enterprise engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including the engaging in or facilitating the knowing and/or reckless abuse of minors through the acts alleged herein. 337. | The Epstein Enterprise knowingly persuaded, induced, enticed, and/or coerced women and children to travel to the Virgin Islands to engage in prostitution and/or sexual activity, and/or attempted to do the same. EFTA00162345

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Case 22a JER Momumesnttaeil PAO eB Pee SEL aff 17278 GVI v. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 60 of 76 338. The Epstein Enterprise kept, maintained, and/or permitted his property at Little St. James to be used for the purpose of prostitution, lewdness or assignation with knowledge or reasonable cause to know the same. 339. The Epstein Enterprise received or offered or agreed to receive women and children at his property at Little St. James for the purposes of prostitution, lewdness or assignation, and/or permitted women and children to remain there for such purposes. 340. The Epstein Enterprise directed, took, transported, and or offered or agreed to take or transport women and children to Little St. James with the knowledge or reasonable cause to know that the purpose of such directing, taking or transporting was prostitution, lewdness or assignation. 341. | The Epstein Enterprise knew or should reasonably have known that individuals that were the subjects of the actions described in this Count were minors. 342. As a result of Defendants’ actions, numerous young women and minors suffered serious physical, mental and emotional injury. 343. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 344. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 345. — Atall times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. §600 et seq. EFTA00162346

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Case 22a JER Domumeenttaeil PAO eB Pepe G2ahf12Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 61 of 76 COUNT EIGHTEEN Prostitution and Keeping House of Prostitution Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.LC. § 600 et seg. and 14 V.LC. §§ 1622, 1624. 346. |The Government restated and realleges paragraph | to 345 of this Complaint as if fully set forth herein. 347. — Atall times material herein, each Defendant joined a conspiracy to laws against prostitution. 348. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by engaging in or facilitating the persuasion, inducement, enticement or coercion of women and children to travel to the Virgin Islands to engage in prostitution and/or sexual activity, and/or attempted to do the same; keeping, maintaining, and/or permitting Epstein's property at Little St. James, to be used for the purpose of prostitution, lewdness or assignation with knowledge or reasonable cause to know the same: receiving, offering, or agreeing to receive individuals at his property at Little St. James for the purposes of prostitution, lewdness or assignation, and/or permitted women and children to remain there for such purposes; and directing, taking, transporting, and/or offering or agreeing to take or transport women and children to Little St. James with the knowledge or reasonable cause to know that the purpose of such directing, taking or transporting was prostitution, lewdness or assignation, in violation of 14 V.LC. §§ 1622 and 1624. 349. Defendants knew or should reasonably have known that individuals that were the subjects of the actions described in this Count were minors. 350. As arresult of Defendants’ actions numerous young women and minors suffered serious physical, mental and emotional injury. EFTA00162347

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Case 22a ER Momumesnttae Ale OTB Pepe EB aAf1Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 62 of 76 351. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands 352. — Atall times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.LC. §604(j). 353. — Atall times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 14 V.LC. §600 et seg. COUNT NINETEEN Sex Offender Registry—Estate of Jeffrey E. Epstein Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.LC. § 600 et seq. and 14 V.L.C. § 1721 et seq. 354. | The Government restates and realleges paragraphs | to 353 of this Complaint as if fully set forth herein. 355. Epstein was required to, and did, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.ILC. § 1721 et seq. 356. | SORCPA requires that offenders required to register provide information relating to intended travel in foreign commerce. 357. On at least two occasions, Epstein traveled to Vienna and Monaco without disclosing that travel to the Virgin Islands sex offender registry. EFTA00162348

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Case 22a ER Momumesnttaeil Flee Pepe Sl aff17Z8 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 63 of 76 358. — Epstein's failure to disclose this travel before, during, or even after his travel was knowing. 359. Epstein's violation SORPCA was part of a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise. 14 V.I.C. §604()). COUNT TWENTY Fraudulent Conveyance Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.L.C. § 600 et seg. and 14 V.L.C. §§ 832-833 360. | The Government restates and realleges paragraphs | to 359 of this Complaint as if fully set forth herein. 361. Atall times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 362. Each Defendant engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to transferring assets to and between various entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder or delay claims against them. 363. | Upon information and belief, in an effort to defeat the claims of creditors and avoid the oversight of the court probating his estate, Epstein, days before his death, transferred significant assets, including assets held by other Defendants, into The 1953 Trust. 364. At the time of these transfers, Epstein had numerous actions pending against him related to his trafficking and sexual assaults seeking financial judgments. 365. Through these transfers, Epstein and the Epstein Enterprise fraudulently removed property and effects beyond the jurisdiction of the probate court. EFTA00162349

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Cased 222:c40020438R DdounreehBGEt1 Frdd@MOAv2M23 PAgge.66 of 123 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 64 of 76 366. — Epstein and the Epstein Enterprise were parties to the fraudulent conveyance of the property, real or personal, and/or the interests or rights arising out of property, contracts, or conveyances of Epstein and the Epstein Enterprise. 367. Epstein and the Epstein Enterprise acted with the intent to defeat, hinder, or delay creditors and claimants, including the Government of the Virgin Islands, in collecting on their judgements, debts and demands 368. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 369. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 370. — Atall times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. §600 et seq. COUNT TWENTY-ONE Fraudulent Conveyance Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.LC. § 600 et seq. and 14 V.LC. §§ 832-833 371. |The Government restates and realleges paragraphs | to 370 of this Complaint as if fully set forth herein. 372. — Atall times material herein, each Defendant joined in a conspiracy to commit fraudulent conveyances. 373. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy, including, but not limited to, transferring assets to and between various EFTA00162350

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CGaed 222:7vL0090438R DdounreshBSEl1 Frdd@ OM 2W23 PAggd.66 of 723 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 65 of 76 entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder or delay claims against them. 374. | Upon information and belief, in an effort to defeat the claims of creditors and avoid the oversight of the court probating his estate, Epstein, days before his death, transferred significant assets, including assets held by other Defendants, into The 1953 Trust. 375. At the time of this transfer, Epstein had numerous actions pending against him related to his trafficking and sexual assaults seeking financial judgments. 376. Through this transfer, Epstein and the Epstein Enterprise fraudulently removed property and effects beyond the jurisdiction of the probate court. 377. Epstein and the Epstein Enterprise were parties to the fraudulent conveyance of the property, real or personal, and/or the interests or rights arising out of property, contracts, or conveyances of Epstein and the Epstein Enterprise. 378. Epstein and the Epstein Enterprise acted with the intent to defeat, hinder, or delay the Government of the Virgin Islands and other creditors and claimants to collect on their judgements, debts and demands. 379. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the Virgin Islands. 380. — Atall times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.LC. §604(j). EFTA00162351

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OGased 22250-009043S8R DdounreanBSél1 FrddMOM2H23 PAagga 62 of 123 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 66 of 76 381. Atal times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. §600 et seq. COUNT TWENTY-TWO Civil Conspiracy 382. The Government restates and realleges paragraphs | to 381 of this Complaint as if fully set forth herein. 383. Defendants acted in concert and joined with others to perform the wrongful acts identified in Counts | to 13, among others, concealing the sexual abuse of minor females by unlawful means. 384. Each co-conspirator knew, or in the exercise of reasonable care should have known, about the conduct of the others and about the common unlawful scheme. 385. These unlawful acts could not have been carried to the length and extent accomplished without the common understanding shared by Epstein and the Epstein Enterprise Defendants. 386. — Each of the Defendants had a duty to report, stop or terminate the wrongful conduct, but instead each Defendant concealed, assisted and furthered the wrongful acts by use of civil conspiracy. 387. As a direct and proximate result of Defendants’ conspiracy, the Virgin Island has been injured. 388. Each co-conspirator is jointly and severally liable for the acts alleged herein. EFTA00162352

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CGaed 222:c40090438R DdouureehBGE:1 Frdd@OAv2H23 PAggd.68 of 123 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 67 of 76 COUNT TWENTY-THREE Fraudulent Claims Upon the Government—Southern Trust Company, Inc. Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.LC. § 600 et seq. and 14 V.LC. § 843 389. The Government restates and realleges paragraphs | to 388 of this Complaint as if fully set forth herein. 390. — Atall times relevant and material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 391. Each Defendant engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including, but not limited to, making fraudulent claims upon the Government. 392. The Epstein Enterprise misrepresented the purpose, activities, employment, and income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epstein Enterprise, with the active participation of Defendants Indyke and Kahn, used Southern Trust Company to employ, pay, and conceal the activities of participants in the criminal activities of the Enterprise. 393. | The Epstein Enterprise made and presented an application for tax incentives, testimony, and quarterly reports to the EDC, a commission of the Government, regarding the Southern Trust Company, knowing such claims to be false, fictitious, or fraudulent; knowingly and willfully falsified, concealed or covered up material facts regarding the Southern Trust Company: made false or fraudulent statements or representations about the purpose, activities, income, and employment of Southern Trust Company; and made and submitted false affidavits knowing the same to contain any fraudulent or fictitious statement or entry. EFTA00162353

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CGaed 222:c40090438R DdounreehBGEt1 FrddMOsv2W23 PAggd.6a of 123 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 68 of 76 394. These false statements and documents included affidavits, testimony, an application, and other documents that misrepresented that Southern Trust Company was engaged in, and failed to disclose it did not and could not carry out, in its stated purpose of providing consulting services in financial and biomedical informatics. 395. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude, and commercial sexual activity of underage girls and young women in knowing and reckless disregard of the laws of the Virgin Islands. 396. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 397. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 398. At all times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. § 600 et seq. COUNT TWENTY-FOUR Fraudulent Claims Upon the Government—Southern Trust Company, Inc. Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 VLC. § 600 et seq. and 14 V.LC. § 843 399. The Government restates and realleges paragraphs | to 398 of this Complaint as if fully set forth herein. 400. — Atall times material herein, each Defendant joined in a conspiracy to commit fraudulent conveyances. EFTA00162354

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Cased 2227v009043S8R DdounreanBSel1 Fidd@MOM2M@23 PaggaV6 of 723 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 69 of 76 401. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy, including, but not limited to, transferring assets to and between various entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder or delay claims against them. 402. The Epstein Enterprise misrepresented the purpose, activities, employment, and income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epstein Enterprise, with the active participation of Defendants Indyke and Kahn, used Southern Trust Company to employ, pay, and conceal the activities of participants in the criminal activities of the Enterprise. 403. The Epstein Enterprise made and presented an application for tax incentives, testimony, and quarterly reports to the EDC, a commission of the Government, regarding the Southern Trust Company, knowing such claims to be false, fictitious, or fraudulent; knowingly and willfully falsified, concealed or covered up material facts regarding the Southern Trust Company; made false or fraudulent statements or representations about the purpose, activities, income, and employment of Southern Trust Company; and made and submitted false affidavits knowing the same to contain any fraudulent or fictitious statement or entry. 404. These false statements and documents included affidavits, testimony, an application, and other documents that misrepresented that Southern Trust Company was engaged in, and failed to disclose it did not and could not carry out, in its stated purpose of providing consulting services in financial and biomedical informatics. 405. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, EFTA00162355

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Cased 222:c40020438R DdounreahBGEt1 Frdd@MOmVv32M23 PAgga. 06 of 123 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 70 of 76 forced labor, sexual servitude, and commercial sexual activity of underage girls and young women in knowing and reckless disregard of the laws of the Virgin Islands. 406. — Atall times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.LC. §604(j). 407. — Atall times material herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.LC. §600 et seq. COUNT TWENTY-FIVE Fraudulent Claims Upon the Government—Cypress, Inc.; Maple, Inc.; Laurel, Inc. Violation of the Criminally Influenced and Corrupt Organizations Act, 14 V.LC. §§ 600 et seg. and 14 V.L.C. § 843 408. The Government restates and realleges paragraphs | to 407 of this Complaint as if fully set forth herein. 409. Atall times relevant and material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. 410. Each Defendant engaged in two or more occasions of conduct that constitute criminal predicate acts as defined by CICO, including but not limited to making fraudulent claims upon the Government. 411. Defendants Cypress, Maple, and Laurel misrepresented the values of their assets held and expenses incurred in their annual reporting to the Government of the United States Virgin Islands for each of the tax years from 2011 to 2018. 412. Defendant Cypress misrepresented the value of its assets held during each of these years by omitting the value of the 49 Zorro Ranch Road, Stanley, New Mexico property that it EFTA00162356

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CGaed 2227 0090438R DdounreshBSé1 Fdd@MOM2W23 PAggd.O2Z of 123 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 71 of 76 acquired in or about December 2011, and misrepresented the value of its expenses incurred during each of these years by omitting the annual amounts of property taxes it paid for the New Mexico property. 413. Defendant Maple misrepresented the value of its assets held during each of these years by omitting the value of the 9 East 71st Street, New York, New York property that it acquired in or about December 2011, and misrepresented the value of its expenses incurred during each of these years by omitting the annual amounts of property taxes it paid for the New York property. 414. Defendant Laurel misrepresented the value of its assets held during each of these years by omitting the value of the 358 Brillo Way, Palm Beach, Florida property that it acquired in or about December 2011, and misrepresented the value of its expenses incurred during each of these years by omitting the annual amounts of property taxes it paid for the Palm Beach property. 415. Epstein and Defendant/Co-Executor Kahn signed each of Cypress, Maple, and Laurel’s annual reports for these years in which they represented that “ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT... .” 416. Epstein appears to have maintained divided ownership of these properties, transferred ownership of them to the Virgin Islands, and then concealed this fact even from Virgin Islands authorities in an attempt to shield the properties from any judgment in the states where they are located. 417. Defendants’ knowingly and willfully made false representations to the Government regarding the assets and expenses of Cypress, Maple, and Laurel, and their conduct EFTA00162357

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CGaed 222:c40090438R DdouureehBGEt1 Frdd@MOmv32H23 PAgga 8 of 123 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 72 of 76 in failing to inform the Government of each company’s true assets and expenses, constitute fraud upon the Government. 14 V.LC. § 843. 418. Defendants, through a pattern of criminal activity, acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or of real property. 419. Defendants benefitted directly and indirectly from the pattern of criminal activity conducted by the Epstein Enterprise. Defendants knowingly benefitted financially and/or obtained non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced sexual servitude, and commercial sexual activity of underage girls and young women, in knowing and reckless disregard of the laws of the Virgin Islands. 420. At all material times herein, Defendants engaged in a pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO, 14 V.LC. §8§ 600 et seq. COUNT TWENTY-SIX Fraudulent Claims Upon the Government—Cypress, Inc.; Maple, Inc.; Laurel, Inc. Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.L.C. §§ 600 et seg. and 14 V.LC. § 843 421. The Government restates and realleges paragraphs | to 420 of this Complaint as if fully set forth herein. 422. Atall material times herein, each Defendant engaged in a conspiracy to commit fraudulent conveyances. 423. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy, including, but not limited to, transferring assets to and between various entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder, or delay claims against them. EFTA00162358

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CGasd 2227 009043S8R DdounreanBSel1 Fidd@MOi2M@23 Pagga Va of 723 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 73 of 76 424. These false statements and documents included annual financial statements for the years 2011 to 2018 submitted by each Cypress, Maple, and Laurel to the Office of Lieutenant Governor of the Virgin Islands that misrepresented the value of the assets held and the amount of the expenses incurred by each company during each of these years. 425. Epstein appears to have maintained divided ownership of these properties, transferred ownership of them to the Virgin Islands, and then concealed this fact even from Virgin Islands authorities in an attempt to shield the properties from any judgment in the states where they are located. 426. Defendants knowingly benefitted financially and/or obtained other non-financial value from their participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude, and commercial sexual activity of underage girls and young women, in knowing and reckless disregard of the laws of the Virgin Islands. Notice of Allegation of PUNITIVE DAMAGES 427. The purpose of punitive damages in the common law is to punish the defendant for outrageous conduct that is reckless or intentional and to deter others from engaging in such conduct in the future. 428. This Complaint describes intentional conduct so egregious, persistent, and injurious that it shocks the conscience and offends a civilized society. 429. Punitive damages are especially important in the case of persons or companies that have so money, assets, and power that mere fines, penalties, and economic damages are simply not sufficient. EFTA00162359

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Cased 222-7 009043S8R DdouureanBSel1 Fidd@MOi2M@23 Pagga 16 of 723 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 74 of 76 430. At all times material herein, Epstein and the Epstein Enterprise engaged repeatedly in wrongful acts which were intentional and outrageous. The Government gives notice that it intends to pursue the possibility of punitive damages in any jury verdict. PRAYER FOR RELIEF WHEREFORE, the Government respectfully requests that the Court: A. Enter a judgment in favor of the Government and against Defendants on all counts; B. Declare that Defendants, through the Epstein Enterprise, have engaged in a pattern of criminal activity in the Virgin Islands including but not limited to human trafficking, forced labor and sexual servitude of female children and young women, unlawful sexual contact, child sexual abuse, child abuse and neglect, rape, prostitution civil conspiracy and other offenses related offenses, and civil conspiracy; Cc. Pursuant to 14 V.L.C. § 610, enforce and maintain the criminal activity liens the Government is filing contemporaneously with this lawsuit, or shall file in connection with this action; D. Pursuant to 14 V.LC. § 607(a)(1) and 14 V.LC. § 141, issue an order forfeiting and divesting in favor of the Government of the Virgin Islands all of Defendants’ interests in any real and personal property used to facilitate the criminal enterprise carried out by the Epstein Enterprise, including but not limited to Little St. James Island and Greater St. James Island; E. Issue an order forfeiting to the Government of the Virgin Islands any proceeds or funds obtained by Defendants, whether directly or indirectly, during the course of the criminal activity of the Epstein Enterprise; EFTA00162360

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CGasd 2227 009043S8R DdounreanBSel1 Fidd@MOM2M@23 Pagga TG of 723 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 75 of 76 F. Pursuant to 14 V.LC. § 607(a)(1), require Defendants to divest themselves of any real property or other interests in favor of the Government of the Virgin Islands used to further the goals of the Epstein Enterprise; G. Pursuant to 14 V.LC. § 607(a)(3) and (5), order the dissolution of the Epstein Enterprise, including but not limited to, order the dissolution of the corporate Defendants; H. Pursuant to 14 V.LLC. § 607(a)(2) enter an injunction to prevent the further criminal conduct, and concealment of the criminal conduct, by the Epstein Enterprise: L Pursuant to 14 V.LC. § 607(a)(4), order the revocation of any and all licenses, permits and approvals that had been granted by any agency of the Territory, and require the repayment of any tax benefits that had been bestowed on any Defendant: J. Pursuant to 14 V.LC. §§ 607(a)(6) and 607(k), order all assets and funds of the Estate of Jeffrey E. Epstein be placed into receivership; K. Pursuant to 14 V.L.C. § 607(e), award the Government the maximum civil penalty for each and every violation of law committed by the Epstein Enterprise: L. Pursuant to 14 V.LC. § 607, award treble damages and all other available remedies, including attorneys’ fees and costs; M. Award compensatory and punitive damages for Defendants’ civil conspiracy; N. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; oO. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 V.LC. § 608(c)(4), to protect the rights of victims and innocent persons in the interest of justice and consistent with the purposes of CICO; P. Assess and award a judgment in favor of the Government and against the Defendants for attorneys’ fees and costs and pre- and post-judgment interest; and EFTA00162361

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Caasd 222-04 00904}S8R DdounreahBSet1 Fdd@OOmW2H23 PaggaI2 of 123 GVIv. Estate of Jeffrey Epstein GVI’s Second Amended Complaint Page 76 of 76 Q. Award any and all other relief this Court deems appropriate. The Government demands a jury trial on all issues so triable. Dated: February 10, 2021 RESPECTFULLY SUBMITTED, DENISE N. GEORGE, ESQ. ATTORNEY GENERAL /s/ Carol Thomas-Jacobs CAROL THOMAS-JACOBS, ESQ. Assistant Attorney General Virgin Islands Department of Justice Office of the Attorney General 34-38 Kronprindsens Gade St. Thomas, U.S. Virgin Islands 00802 Email: ariel.smith @doj.vi.gov (340) 774-5666 ext. 10101 EFTA00162362

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UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Case Number: ad- cun (0404 GOVERNMENT OF THE UNITED ) STATES VIRGIN ISLANDS ) ) ACTION FOR DAMAGES PLAINTIFF, ) ) JURY TRIAL DEMANDED V. ) ) JP MORGAN CHASE BANK, N.A. ) ) ' DEFENDANT. ) PROTE RDER The parties having agreed to the following terms of confidentiality, and the Court having found that good cause exists for issuance of an appropriately tailored confidentiality order governing the pre-trial phase of this action, it is therefore hereby ORDERED that any person subject to this Order -- including without limitation the parties to this action, their representatives, agents, experts and consultants, all third parties providing discovery in this action, and all other interested persons with actual or constructive notice of this Order -- shall adhere to the following terms, upon pain of contempt: 1. Any person subject to this Order who receives from any other person any “Discovery Material” (i.e., information of any kind provided in the course of discovery in this action) that is designated as “Confidential” pursuant to the terms of this Order shall not disclose such Confidential Discovery Material to anyone else except as expressly permitted hereunder. 2. The person producing any given Discovery Material may designate as Confidential only such portion of such material as consists of: a. previously nondisclosed financial information (including without EFTA00162363

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limitation profitability reports or estimates, percentage fees, design fees, royalty rates, minimum guarantee payments, sales reports and sale margins); b. previously nondisclosed confidential reporting to law enforcement agencies; c. previously nondisclosed material relating to ownership or control of any non-public company; d. previously nondisclosed business plans, product development information, or marketing plans; e. any information of a personal or intimate nature regarding any individual; f. any information maintained by JPMorgan Chase Bank, N.A. or its affiliates that is required to be kept confidential pursuant to the Bank Secrecy Act, 31 U.S.C. §§ 5311 to 5336, or its implementing regulations (“BSA”) but for which the appropriate regulatory authority has authorized disclosure, including but not limited to the fact that no BSA information exists, (“BSA- Protected Information”)! and any information that, pursuant to 31 U.S.C. 5318(g)(2)(A)(1), 31 C.F.R. § 1020.320, 12 C.F.R § 21.11, Section 314(a) or (b) of the PATRIOT ACT, 12 U.S.C, §§ 3414(a)(3) and (c) or any other applicable regulations ' BSA-Protected Information maintained by other financial institutions are not within the scope of this Order and remain subject to the standard confidentiality requirements of the BSA and its implementing regulations. EFTA00162364

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concerning potential suspicious activity (“SAR-Related Information”), is not permitted to be produced unless authorized by the appropriate regulatory authority (“SAR-Protected Information”); any information that is confidential supervisory information (“CSI”) of the Board of Governors of the Federal Reserve System as set forth in 12 C.F.R. § 261.2(c), non-public information of the Office of the Comptroller of the Currency or the former Office of Thrift Supervision as set forth in 12 C.F.R. § 4.32(b), exempt information of the Federal Deposit Insurance Corporation as set forth in 12 C.F.R. §§ 309.2, 309.5, and 309.6, and confidential information of the Consumer Financial Protection Board as set forth in 12 C.F.R. § 1070.2, and any other records concerning supervision, regulation, and examination of banks, savings associations, their holding companies and affiliates, and records compiled in connection with the enforcement responsibilities of federal and state financial regulatory agencies that is not permitted to be disclosed to a third party absent consent of the applicable regulator or government agency unless authorized by the appropriate regulatory authority (“CSI-Protected Information”); or any other category of information hereinafter given confidential status by the Court. EFTA00162365

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3. With respect to the Confidential portion of any Discovery Material other than deposition transcripts and exhibits, the producing person or that person’s counsel may designate such portion as “Confidential” by stamping or otherwise clearly marking as “Confidential” the protected portion in a manner that will not interfere with legibility or audibility, and by also producing for future public use another copy of said Discovery Material with the confidential information redacted. For the avoidance of doubt, nothing herein is intended to prevent a party from designating the entirety of a given document as “Confidential” if the party reasonably believes the entire document falls within one or more of the categories in paragraph 2, above. With respect to deposition transcripts and exhibits, a producing person or that person’s counsel may indicate on the record that a question calls for Confidential information, in which case the transcript of the designated testimony shall be bound in a separate volume and marked “Confidential Information Governed by Protective Order” by the reporter. 4. If at any time prior to the trial of this action, a producing person realizes that some portion[s] of Discovery Material that that person previously produced without limitation should be designated as Confidential, he may so designate by so apprising all parties in writing, and such designated portion[s] of the Discovery Material will thereafter be treated as Confidential under the terms of this Order. If a party has disclosed such designated portion[s] of Discovery Material to anyone other than the individuals set forth in paragraph 5 below, that party shall make reasonable efforts to promptly retrieve such Discovery Material, and inform any recipient of the terms of the Order. 5. With the exception of the qualifications pertaining to BSA-Protected EFTA00162366

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Information, SAR-Protected Information and/or CSI-Protected Information in paragraph 6, no person subject to this Order other than the producing person shall disclose any of the Discovery Material, designated by the producing person as Confidential excluding any material containing BSA-Protected Information, SAR- Protected Information and/or CSI-Protected Information to any other person whomsoever, except to: a. b. the parties to this action; counsel retained specifically for this action, including any paralegal, clerical and other assistant employed by such counsel and assigned to this matter; as to any document, its author, its addressee, and any other person indicated on the face of the document as having received a copy; any witness who counsel for a party in good faith believes may be called to testify at trial or deposition in this action, provided such person has first executed a Non-Disclosure Agreement in the form annexed as an Exhibit hereto; any person retained by a party to serve as an expert witness or otherwise provide specialized advice or services to counsel in connection with this action (including but not limited to professional jury or trial consultants, mock jurors, and persons or entities providing litigation support services — such as photocopying, videotaping, translating, preparing exhibits or demonstrations, and processing, hosting, organizing, storing, or EFTA00162367

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i. retrieving data in any form or medium — and their employees and subcontractors), provided such person has first executed a Non- Disclosure Agreement in the form annexed as an Exhibit hereto; any mediator or other dispute-resolution personnel, or any employee thereof, provided such person has first executed a Non- Disclosure Agreement in the form annexed as Exhibit hereto; insurers, reinsurers, insurance adjusters, and/or third party administrators of insurance policies that do or may provide insurance coverage applicable to this action; stenographers engaged to transcribe depositions conducted in this action and videographers engaged to record depositions conducted in this action; and the Court and its support personnel. 6. No person subject to this Order shall disclose any BSA-Protected Information, SAR-Protected Information, and/or CSI-Protected Information to any other person whomsoever, except to the following persons, consistent with any authorization received from the appropriate regulatory authority: a. the Government of the U.S. Virgin Islands and its counsel and JPMorgan Chase and its counsel, including any paralegal, clerical and other assistant employed by such counsel and assigned to this matter; any witness employed or formerly employed by JPMorgan Chase who counsel for the Government of the U.S. Virgin Islands or EFTA00162368

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e. JPMorgan Chase in good faith believes may be called to testify at trial or deposition in this action, provided such person has first executed a Non-Disclosure Agreement in the form annexed as an Exhibit hereto; any person retained by the Government of the U.S. Virgin Islands or JPMorgan Chase to serve as an expert witness or otherwise provide specialized advice to counsel in connection with this action, provided such person has first executed a Non-Disclosure Agreement in the form annexed as an Exhibit hereto; stenographers engaged to transcribe depositions conducted in this action and videographers engaged to record depositions conducted in this action provided such person has first executed a Non-Disclosure Agreement in the form annexed as Exhibit hereto; and the Court and its support personnel. 7. Prior to any disclosure of any Confidential Discovery Material to any person referred to in subparagraphs 5(d), 5(e), or 5(f) above, such person shall be provided by counsel with a copy of this Protective Order and shall signa Non-Disclosure Agreement in the form annexed as an Exhibit hereto stating that that person has read this Order and agrees to be bound by its terms. Said counsel shall retain each signed Non-Disclosure Agreement, hold it in escrow, and produce it to opposing counsel either prior to such person being permitted to testify (at deposition or trial) or at the conclusion of the case, whichever comes first. EFTA00162369

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8. All Confidential Discovery Material filed with the Court, and all portions of pleadings, motions or other papers filed with the Court that disclose such Confidential Discovery Material, shall be filed under seal with the Clerk of the Court and kept under seal until further order of the Court. The parties will use their best efforts to minimize such sealing. In any event, any party filing a motion or any other papers with the Court under seal shall also publicly file a redacted copy of the same, via the Court’s Electronic Case Filing system, that redacts only the Confidential Discovery Material itself, and not text that in no material way reveals the Confidential Discovery Material. 9. Any party who either objects to any designation of confidentiality, or who, by contrast, requests still further limits on disclosure (such as “attorneys” eyes only” in extraordinary circumstances), may at any time prior to the trial of this action serve upon counsel for the designating person a written notice stating with particularity the grounds of the objection or request. If agreement cannot be reached promptly, counsel for all affected persons will convene a joint telephone call with the Court to obtain a ruling. 10, All persons are hereby placed on notice that the Court is unlikely to seal or otherwise afford confidential treatment to any Discovery Material introduced in evidence at trial, even if such material has previously been sealed or designated as Confidential. The Court also retains unfettered discretion whether or not to afford confidential treatment to any Confidential Document or information contained in any Confidential Document submitted to the Court in connection with any motion, application, or proceeding that may result in an order and/or decision by the Court. 11. Each person who has access to Discovery Material that has been EFTA00162370

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designated as Confidential shall take all due precautions to prevent the unauthorized or inadvertent disclosure of such material. 12. If, in connection with this litigation, a party inadvertently discloses information subject to a claim of attorney-client privilege or attorney work product protection, including any privilege or immunity from production associated with BSA, SAR-Related Information, and/or CSI (“Inadvertently Disclosed Information”), such disclosure shall not constitute or be deemed a waiver or forfeiture of any claim of privilege or work product or such other applicable protection with respect to the Inadvertently Disclosed Information and its subject matter. For avoidance of doubt, outside of authorization from an appropriate regulatory authority, the disclosure of BSA, SAR-Related Information and/or CSI shall not constitute or be deemed a waiver or forfeiture of any claim of privilege or work product or such other applicable protection with respect to such information. 13. If a disclosing party makes a claim of inadvertent disclosure, the receiving party shall not thereafter review the Inadvertently Disclosed Information for any purpose, except by order of the Court. The receiving party shall, within five business days, return or destroy all copies of the Inadvertently Disclosed Information, and provide a certification of counsel that all such information has been returned or destroyed. 14. | Within five business days of the notification that such Inadvertently Disclosed Information has been returned or destroyed, the disclosing party shall produce a privilege log with respect to the Inadvertently Disclosed Information. 15. As with any information redacted or withheld, the receiving party may EFTA00162371

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move the Court for an Order compelling production of the Inadvertently Disclosed Information. The motion shall be filed under seal, and shall not assert as a ground for entering such an Order the fact or circumstances of the inadvertent production. 16. The disclosing party retains the burden of establishing the privileged or protected nature of any Inadvertently Disclosed Information. Nothing in this Order shall limit the right of any party to request an in camera review of the Inadvertently Disclosed Information. 17. This Protective Order shall survive the termination of the litigation. Within 30 days of the final disposition of this action, all Discovery Material designated as “Confidential,” and all copies thereof, shall be promptly returned to the producing person, or, upon permission of the producing person, destroyed. For the avoidance of doubt, counsel of record in this action shall be permitted to keep copies of filings and work product that incorporates any Confidential Discovery Material, so long as counsel continues to treat such Confidential Discovery Material in accordance with this Order. 18. This Court shall retain jurisdiction over all persons subject to this Order to the extent necessary to enforce any obligations arising hereunder or to impose sanctions for any contempt thereof. SO STIPULATED AND AGREED. 10 EFTA00162372

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/s/ Linda Singer LINDA SINGER Admitted Pro Hac Vice Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 232-5504 Isinger@motleyrice.com Dated: January 9, 2023 SO ORDERED. Dated: New York, New York I-/0-)3 /s/ Boyd Johnson WILMER CUTLER PICKERING HALE AND DORR LLP Boyd M. Johnson III Robert L. Boone Hillary Chutter-Ames 7 World Trade Center 250 Greenwich Street New York, NY 10007 (t) (212) 230-8800 (f) (212) 230-8888 boyd.johnson@wilmerhale.com robert.boone@wilmerhale.com hillary.chutter-ames@wilmerhale.com Felicia H. Ellsworth 60 State Street Boston, MA 02109 (t) (617) 526-6687 (f) (617) 526-5000 felicia.ellsworth@wilmerhale.com Dated: January 9, 2023 JED 2 RAKOFF, Ab EFTA00162373