EPSTEIN
page 4 / 187 . OCR, unverified
33.
Defendant James E. Staley (“Staley”) was the CEO of JP Morgan’s Investment
Bank from September 2009 through January 2013. Previously, Staley was the CEO of JP
Morgan’s Asset Management division from 2001-2009, and was the head of JP Morgan’s Private
Banking division from 1999-2001. Staley is an individual and is believed to be a resident of
Manhattan, New York.
34.
Defendant William C. Weldon (“Weldon”) was a director of JP Morgan from 2005-
2019. Weldon is an individual and is believed to be a resident of North Palm Beach, Florida.
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 8 of 53
35.
Defendant Barry L. Zubrow (“Zubrow”) was JP Morgan’s Chief Risk Officer from
2007-2012. Zubrow is an individual and is believed to be a resident of West Palm Beach, Florida.
36.
Defendants Bammann, Bell, Biggs, Bowles, Burke, Combs, Cote, Crown, Dimon,
Flynn, Futter, Hobson, Jackson, Kessler, Lipp, Neal, Novak, Manoogian, Raymond, and Weldon
are referred to collectively herein as the “Director Defendants.”
37.
Defendants Bacon, Dimon, Erdoes, Hogan, Staley, and Zubrow are referred to
collectively herein as the “Officer Defendants.”
38.
The Director Defendants and Officer Defendants are collectively referred to herein
as “Defendants.”
RELEVANT NON-PARTIES
39.
Alicia Boler Davis (“Davis”) has been a director of JP Morgan since March 2023.
40.
Alex Gorsky (“Gorsky”) has been a director of JP Morgan since July 2022.
41.
Phebe N. Novakovic (“Novakovic”) has been a director of JP Morgan since 2020.
42.
Virginia M. Rometty (“Rometty”) has been a director of JP Morgan since 2020.
JURISDICTION AND VENUE
43.
The Court has jurisdiction over this action pursuant to 28 U.S.C. § 1332. The Court
has supplemental jurisdiction over the state law claims asserted herein pursuant 28 U.S.C.
§ 1367(a). This action is not a collusive one to confer jurisdiction on a court of the United States
which it would not otherwise have.
44.
Venue is proper in this Court because JP Morgan has its principal place of business
in this district, Plaintiff’s claims arose in this district, and JP Morgan has suffered and will continue
to suffer harm in this district. Venue is further proper in this Court because various actions related
to the allegations asserted herein, including Doe v. JP Morgan and USVI v. JP Morgan (defined
below), are currently pending before this Court.
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 9 of 53
PROCEDURAL BACKGROUND
45.
JP Morgan is currently defending allegations from two distinct lawsuits stemming
from its facilitation and concealment of Epstein’s abuse. First, a plaintiff identified as “Jane Doe
1”, on behalf of herself and other victims of Epstein’s abuse, asserted several claims against the
Company’s primary banking subsidiary, JP Morgan Chase Bank, N.A., in the litigation styled Jane
Doe 1 v. JP Morgan Chase Bank, N.A., 22-cv-10019 (JSR) (“Doe v. JP Morgan”). Second, the
government of the U.S. Virgin Islands also asserted several claims against JP Morgan Chase Bank,
N.A. in the litigation styled Government of the United States Virgin Islands v. JP Morgan Chase
Bank, N.A., 22-cv-10904 (CSR) (“USVI v. JP Morgan”).
46.
In both actions, the plaintiffs broadly allege that for several years, JP Morgan knew
about Epstein’s abusive conduct and knew about Epstein’s suspicious use of his many accounts at
the Bank, yet failed to comply with federal regulations to report his suspicious activity. This failure
and concealment, in turn, helped Epstein’s systematic abuse to continue unchecked. Plaintiffs in
both actions seek monetary damages, including punitive and treble damages in the USVI v. JP
Morgan action. JP Morgan therefore faces a material risk of substantial monetary liability, above
and beyond the significant reputational harm that JP Morgan has already suffered and will continue
to suffer as a result of its longstanding facilitation and concealment of Epstein’s crimes. JP Morgan
also faces the risk of fines or monetary damages as the result of potential governmental
investigations into its conduct.
SUBSTANTIVE ALLEGATIONS
I.
EPSTEIN’S DECADES OF ABUSIVE CONDUCT
47.
The shocking extent and gravity of Epstein’s abuses are now well known. For more
than two decades, Epstein operated a vast network of shell companies, intermediaries, and enablers
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 10 of 53
for the sole purpose of trafficking and abusing young women at his properties, including in the
U.S. Virgin Islands.
48.
Epstein is reported to have begun his systematic exploitation of young women as
early as the 1990s. But since at least 2001, Epstein trafficked young girls and women to the U.S.
Virgin Islands, where he then had them transported to his private island, Little St. James.1 He also