EFTA00162121.txt

"Plaintiff Jane Doe 1 files this first amended individual and civil class action complaint for damages and other relief under the United States federal"

"JP Morgan knew that it was providing the financial lifeblood for Epstein's international sex-trafficking organization from 1998 through August 2013."

"crucial financial support allowed Epstein to successfully rape, sexually assault, and coercively sex traffic Jane Doe 1"

"Jeffrey Epstein's New York mansion, located within this District at 9 East 71st Street in New York City."

"Plaintiff Jane Doe 1 files this first amended individual and civil class action complaint"

"The Epstein sex-trafficking venture knowingly used means of force, threats of force, fraud, coercion... to cause Jane Doe 1, and many dozens of others"

"Epstein recruited, solicited, coerced, harbored, transported, and enticed some of his victims, including Jane Doe 1"

"While Epstein's abuse began in the early 1990s with the use of his paramour turned madame, Ghislaine Maxwell"

"primarily his townhouse located at 9 East 71 Street, New York, NY, where he would sexually abuse each one."

"Epstein used JP Morgan accounts to pay, through wire transfers and in cash, for coerced commercial sex acts by Jane Doe 1 and other Class Members."

"Between about 1998 and 2013, in this District in New York, Jeffrey Epstein intentionally committed batteries and other intentional tortious conduct..."

"Epstein intentionally and non-consensually touched Jane Doe 1 and the Class Members in a harmful and offensive manner"

"During a trip to the U.S. Virgin Islands in January 2007, Jane Doe 1 was repeatedly raped and coerced into commercial sex"

"Epstein transferred approximately $31 million to Maxwell, an amount believed to be payment for her role in Epstein's sex trafficking venture"

"Staley flew on Epstein's plane along with Sarah Kellen and Nadia Marcinkova"

"Mary C. Erdoes... intervened to keep Epstein as a client after he pled guilty to sex crimes"

"Epstein was close friends with Glenn Dubin"

"Wexner, Epstein's client who had turned over a power of attorney to Epstein"

"Jane Doe 1 brings this action pursuant to Federal Rule of Civil Procedure 23(b)(3) and 23(c)(4) on behalf of herself"

"The money used to make settlement payments was paid from Epstein-related entity accounts at JP Morgan."

"Epstein maintained numerous apartment units at 301 East 66th Street in New York City"

"The charges alleged that she had assisted, facilitated, and contributed to Epstein's abuse of sex-trafficking victims, helping Epstein to recruit, gro"

"the United States Attorney's Office for the Southern District of New York filed a sealed, two-count Indictment against Epstein"

"Maxwell was found guilty on five federal sex-trafficking counts and is now serving nearly 20 years"

"Epstein paid more than $600,0000 to Jane Doe 1"

"Hyperion Air, Inc.—the Epstein-controlled company that owned Epstein's private jet"

"numerous JP Morgan executives... were influenced by Staley to continue to support Epstein"

"In 2013... JP Morgan realized that its claims to not knowing what Epstein was doing were no longer facially plausible. Accordingly, and reluctantly, J"

"Jane Doe I listed Epstein's apartments on 66th Street in New York City as her address"

"Epstein to commit intentional tortious conduct and Chapter 130 Crimes against Jane Doe 1 and the Class Members."

"JP Morgan, through Staley, knew that Epstein was abusing females sexually on a daily basis and through that knowledge, developed a special relationshi"

"personally visited Epstein when he was serving his jail sentence in Florida and arranged for an even tighter connection between JP Morgan and Epstein."

"knew that Epstein's co-conspirators like Ghislaine Maxwell were involved in the sex trafficking operation"

"After Epstein was released from his Florida incarceration, he picked up right where he left off—abusing young women on a daily basis"

"Epstein hired Roy Black, Ken Starr, Jay Lefkowitz, Guy Lewis... All of these lawyers were now on Epstein's payroll"

"To be clear, during his years as a top executive at JP Morgan, Staley was not only one of Epstein's closest pals"

"Epstein trafficked Jane Doe 1 to the U.S. Virgin Islands where she was repeatedly raped."

"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 Mor"

"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."

"One of JP Morgan's officers, Jes Staley, also knew the names of the many of Epstein's sex trafficking victims."

"Epstein's and his conspirators sex-trafficking venture and sex trafficking of Jane Doe 1"

"JP Morgan provided large amounts of cash to further the Epstein sex-trafficking venture and with the purpose of helping Epstein evade criminal liabili"

"Jane Doe 1 respectfully requests that the Court enter judgment in her favor, and against JP Morgan"

"Plaintiff Government of the United States Virgin Islands files this Complaint against JPMorgan Chase Bank, N.A. for violations of Trafficking Victims "

"Jane Doe 1 respectfully requests that the Court... appoint her lawyers as Class Counsel; ... Respectfully Submitted, EDWARDS POTTINGER, LLC By: /s/ Br"

"David Boies Boies Schiller Flexner LLP 55 Hudson Yards New York, New York"

"Government of the U.S. Virgin Islands v. Indyke et at, Case No. ST-20-CV-14 (Super. Ct. V.I. Jan. 15, 2020)."

"Epstein's commission of sexual abuse and commercial sex acts with Jane Doe 1"

"the same Office indicted Epstein's co-conspirator, Ghislaine Maxwell, for conspiracy to entice minor victims to travel to be abused by Epstein."

"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 Dis"