EPSTEIN
page 5 / 187 . OCR, unverified
Virgin Islands, where he then had them transported to his private island, Little St. James.1 He also
trafficked women to New York and to other properties he owned. Epstein and his associates often
deceived these girls and young women into traveling with promises of modeling contracts,
employment, or educational opportunities. Other times, Epstein’s abuse began as a demand for a
massage, which rapidly evolved into abuse. Once trafficked to the U.S. Virgin Islands, Epstein
and others in his network exploited and abused these women, and then ensured their silence with
both threats and payoffs. Epstein was infamous for paying his victims in cash, although he on
occasion also wired money directly to both victims and allies.2
49.
The full scale of Epstein’s abuses is hard to comprehend. Epstein is accused of
trafficking and abusing girls as young as 11 years old, reflecting his repulsive preference of the
“younger the better.”3 Air traffic controllers and other airport personnel in the U.S. Virgin Islands
reported seeing Epstein disembark from his plane with girls that appeared to be between 11 and
years old. In one harrowing instance, a 15 year old victim that Epstein abused on Little St.
Government of the United States Virgin Islands v. Indyke, et al. ST-20-CV-14, Second Am.
Compl. (Nov. 30, 2022) at ¶49 (hereinafter “USVI State Complaint”).
Government of the United States Virgin Islands v. JP Morgan Chase Bank, N.A., 22-cv-10904
(CSR), Second Am. Compl. (Apr. 12, 2023) at ¶42 (hereinafter “USVI Complaint”).
Jane Doe 1 v. JP Morgan Chase Bank, N.A., 22-cv-10019 (JSR), First Am. Compl. (Jan. 13,
2023) at ¶126 (hereinafter “Doe Complaint”).
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 11 of 53
James attempted to escape by swimming off the island. Epstein organized a search party, found
the victim, confiscated her passport, and threatened her with physical harm if she did not submit.4
50.
Epstein trafficked many of his victims from Eastern Europe and sometimes kept
the same girls and women in servitude for several years. For example, Epstein is accused of having
flown one victim to his island dozens of times between 2004 and 2017; and another more than 50
times between 2000 and 2002. This meant that Epstein eventually had to grapple with immigration
concerns. To address this problem, Epstein forced some of his victims to marry his American
citizen associates (or even other victims), and then helped finalize arrangements with immigration
authorities.5 Epstein is accused of having forced at least three victims into marriages, and then
threatening them with harm if they attempted to leave.
51.
Epstein’s appetite for abuse was seemingly insatiable. Epstein is reported to have
regularly abused up to 3-4 victims each day—a demand that even Epstein’s extensive network
struggled to supply. Epstein therefore demanded that his victims themselves help deceive and
recruit other victims. To this end, Epstein often instructed his victims to go to night clubs or on
shopping trips to help identify other unsuspecting women and girls that they might be able to
entrap. Epstein paid an additional fee for each new victim that an existing victim lured in.
52.
The frequency and duration of his crimes make clear that Epstein could not have
orchestrated his abuse without both an extensive network of allies and enablers, and steady,
unquestioned access to large amounts of cash. In JP Morgan, Epstein had both.
USVI State Complaint, ¶60.
USVI State Complaint, ¶63.
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 12 of 53
II.
JP MORGAN ENABLED EPSTEIN’S CRIMES FOR YEARS
53.
Epstein was a JP Morgan client from at least 1998 through 2013. Over this time,
JP Morgan serviced roughly 55 accounts that belonged or were related to Epstein, collectively
worth hundreds of millions of dollars. In addition to accounts in his own name, Epstein also
operated many JP Morgan accounts in the names of other companies and non-profit entities that
often had no legitimate business purpose. These entities included 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, each of which had accounts with JP
Morgan. Epstein used many of these entities to make and conceal payments to his victims and his
associates or, as the U.S. Virgin Islands alleges, to help shield his assets from judgment.
54.
Over the many years that Epstein served as a star JP Morgan client, he used his 55+
accounts with the Bank extensively to facilitate his abuse. According to the U.S. Virgin Islands
government, Epstein paid at least 20 of his victims through JP Morgan accounts, and these victims