EPSTEIN
page 6 / 187 . OCR, unverified
collectively received in excess of $1 million. Epstein also used his JP Morgan accounts to pay his
associates and enablers: the U.S. Virgin Islands government alleges that Epstein paid nearly $1.5
million to known recruiters.
55.
The details of these enormous payments are deeply troubling. Epstein paid the
plaintiff identified as Jane Doe 1, for example, more than $600,000 through his JP Morgan
accounts between 2003 and 2013. Epstein’s abuse of Doe 1 began when she was only 14 years
old.6 In an obvious sign that something was amiss, Doe 1 listed Epstein’s New York City
townhouse as her address for purposes of the many payments she received from Epstein.
USVI Complaint, ¶66.
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 13 of 53
56.
More troublingly, Epstein also regularly withdrew millions of dollars from his JP
Morgan accounts—in cash. As early as 2006, a JP Morgan Rapid Response Team noted that
Epstein routinely withdrew $40,000 to $80,000 in cash from his accounts several times each
month, and more than $750,000 per year. In each of 2004 and 2005, Epstein withdrew more than
$800,000 in cash. Epstein also used his JP Morgan accounts to make at least 95 foreign remittances
to unknown payees—another blatantly suspicious pattern of conduct.
57.
Some of Epstein’s use of cash is so obviously illegitimate that it almost defies
belief. For example, the company that owned and operated Epstein’s private plane (Hyperion Air,
Inc.) issued more than $547,000 in checks—payable to cash—for “fuel expenses when traveling
to foreign countries.”7 Apart from the absurdity of paying for hundreds of thousands of dollars’
worth of jet fuel in cash, some of these checks were issued when Epstein was under house arrest,8
and plainly unable to travel anywhere.
58.
Similarly, between January 2012 and June 2013, Hyperion converted more than
$120,000 into foreign currency, with the constituent cash withdrawals either exceeding the typical
$10,000 reporting threshold, or being structured in a way to avoid meeting this threshold. Epstein
also used other entities under his control to funnel payments to his victims and associates. For
example, Epstein used a charitable organization he controlled (and which had an account with JP
Morgan) to pay $29,464 to three young women, and used another organization to pay $124,232 to
Leslie Wexner, who is now known to have been a vital part of Epstein’s network.
USVI Complaint, ¶67.
As discussed further below, Epstein was arrested in Florida in 2006 on charges of soliciting a
minor for prostitution, and entered into a plea agreement in 2008.
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 14 of 53
III.
JP MORGAN WILLFULLY IGNORED AND FAILED TO REPORT EPSTEIN’S
HIGHLY SUSPICIOUS PRACTICES
59.
JP Morgan knew of Epstein’s true nature at least as early as 2006. The previous
year, press reports emerged that claimed that Epstein paid a 14-year old girl in Palm Beach, Florida
for a massage and then proceeded to abuse her. These press reports prompted other Epstein victims
to come forward with similar allegations. In 2006, Epstein was arrested and indicted in Florida
for solicitation of a minor, amidst additional extensive press reports about his crimes.
60.
JP Morgan was immediately aware of Epstein’s arrest. In 2006, the same year
Epstein was arrested, JP Morgan’s Global Corporate Security Division found “[s]everal newspaper
articles … that detail the indictment of Jeffrey Epstein in Florida on felony charges of soliciting
underage prostitutes”9 (i.e. raping children). Despite these reports and Epstein’s indictment, JP
Morgan decided to retain Epstein as a client—while concluding that his account “should be
classified as high risk” and require special approval.10
61.
JP Morgan’s knowledge of Epstein’s crimes at this time was not limited to lower-
level employees, but extended all the way to the top. At her deposition in the USVI v. JP Morgan
action, Mary Erdoes (who was CEO of JP Morgan Private Bank from 2005 until she became CEO
of the Asset & Wealth Management Division in 2009) admitted that JP Morgan was aware in 2006
not only that Epstein was abusing women and underage girls, but that Epstein paid these victims
in cash. Crucially, this was the same year that a team at JP Morgan made an internal report that
Epstein was withdrawing up to $80,000 in cash at a time, multiple times a month.
USVI Complaint, ¶44.
USVI Complaint, ¶44.
Case 1:23-cv-03903-JSR Document 1 Filed 05/09/23 Page 15 of 53
62.
In 2008, Epstein pled guilty to several of the charges that he faced in Florida,
including solicitation of a minor for prostitution. As part of his plea arrangement, Epstein was
sentenced to serve 18 months in jail and was required to register as a sex offender.11 To the extent