Case 1:22-cv-10904-JSR Document 16 Filed 01/10/23 Page 1 of 34 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS Case Number: I :22-cv-10904 JSR 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 M') 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, I2A V.I.C. §§ 301 to 336, and in support thereof alleges as follows: PARTIES I. The Attorney General of the United States Virgin Islands (hereinafter "Virgin Islands") brings this parens pruriae action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 15 U.S.C. § 1595(d) and 3 V.I.C. § 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 EFTA02805715