Jane Doe 1 v. JPMorgan Chase Bank, N.A.

Jane Doe 1 v. JPMorgan Chase Bank, N.A. was a putative class action filed in the Southern District of New York on November 24, 2022 by an Epstein survivor proceeding under pseudonym, on behalf of a class of women alleged to have been trafficked by Jeffrey Epstein during the period in which JPMorgan served as his primary banking institution. The First Amended Class Action Complaint (EFTA00162121) was filed on January 13, 2023 and brought claims under the federal Trafficking Victims Protection Act, 18 U.S.C. § 1591, et seq., together with claims for aiding and abetting, intentional infliction of emotional distress, and negligence under the New York Adult Survivors Act, N.Y. C.P.L.R. § 214-j. The action was assigned to Judge Jed S. Rakoff.

The core allegation was that JPMorgan provided "the financial lifeblood for Epstein's international sex-trafficking organization from 1998 through August 2013" and that the bank "knowingly and intentionally benefited" from a relationship it continued to maintain through Epstein's 2008 Florida non-prosecution agreement and his 2008 state-court guilty plea (EFTA00162121 at 1–2). The complaint pleaded class-wide liability under TVPA § 1591(a)(2) (knowingly benefiting from participation in a sex-trafficking venture) and § 1591(d) (obstructing enforcement of the statute), together with state-law theories of aiding and abetting and negligence as a banking institution providing non-routine private-banking services.

In early 2023 the Court consolidated 22-cv-10019 for discovery with two parallel actions before the same judge: Jane Doe 1 v. Deutsche Bank Aktiengesellschaft et al., 22-cv-10018 (S.D.N.Y.), filed days earlier against Epstein's successor bank, and the parens patriae enforcement action Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., 22-cv-10904 (S.D.N.Y.), filed by the V.I. Attorney General one month after Doe 1 (EFTA02807219). On March 20, 2023, Judge Rakoff issued a consolidated motion-to-dismiss order ruling on JPMorgan's and Deutsche Bank's Rule 12(b)(6) motions (EFTA02806578) — sustaining the core TVPA § 1591(a)(2) beneficiary, § 1591(d) obstruction, and negligence claims while dismissing several adjacent state-law counts.

In March 2023 JPMorgan filed a third-party complaint against its former private-bank executive James E. "Jes" Staley, contending that any liability the bank incurred to Doe and to USVI was the product of Staley's personal misconduct and seeking contribution and indemnification (EFTA02817124). The Staley third-party action was litigated under the same docket caption as both Doe and USVI through summary judgment and Daubert motion practice (EFTA02817124, EFTA02817454, EFTA02818619, EFTA02818698). A class settlement of $290 million between Doe and JPMorgan was reached in June 2023; in October 2023, sixteen state Attorneys General (led by New Mexico) filed an amici letter objecting to a release provision in the proposed settlement that, in the states' reading, purported to extinguish their parens patriae claims under TVPA § 1595(d) without their consent (EFTA00037104). The Court ultimately approved a settlement, and the case is closed at the trial-court level.

The corpus contains 145 EFTA-stamped pages and 27 emails linked to docket 22-cv-10019. Because the Court consolidated 22-cv-10019 with the parallel USVI action (22-cv-10904) and the Deutsche Bank action (22-cv-10018) for discovery, the substantive record produced into the EFTA corpus is dominated by joint-caption filings stamped with both case numbers — with the Doe-specific filings concentrated at the pleading and settlement-objection stages, and the bulk of the consolidated summary-judgment, Daubert, and Staley third-party record filed primarily under the 22-cv-10904 caption.

The Doe-specific filings in the sample include the First Amended Class Action Complaint (EFTA00162121, 130 pp.), which sets out the TVPA § 1591(a)(2) and § 1591(d) theories and the New York Adult Survivors Act state-law claims, and pleads the bank-relationship period "from 1998 through August 2013"; Judge Rakoff's March 20, 2023 consolidated motion-to-dismiss order resolving the bank defendants' Rule 12(b)(6) motions in 10018, 10019, and 10904 (EFTA02806578); and the October 19, 2023 multistate Attorneys General letter to the Court (EFTA00037104), in which the AGs of New Mexico, Arizona, California, Connecticut, Delaware, the District of Columbia, Hawaii, Illinois, Maryland, Minnesota, Mississippi, New York, Oregon, Pennsylvania, Tennessee, Utah, and Vermont objected that proposed Section 1.25 of the Doe class settlement agreement "purports to release state Attorney General parens patriae claims under Section 1595(d) of the [TVPA]" without notice or consent under the Class Action Fairness Act.

The consolidated record bearing on Doe includes the dual-caption Staley third-party summary-judgment papers (EFTA02817124, EFTA02817454), in which Staley's counsel argues, among other things, that JPMorgan "cannot recover its settlement in the Doe case or associated costs via contribution or any proportional fault theory" and recites that Staley used his JPMorgan corporate email to communicate with Epstein from 1998 through 2019; JPMorgan's WilmerHale-filed Ellsworth declaration attaching deposition excerpts from Staley (June 10, 2023), JPMorgan banker Francis Pearn (May 30, 2023), and Doe-class counsel Justin Nelson (April 21, 2023) in opposition to Staley's MSJ (EFTA02818619); and Staley's Daubert brief seeking to exclude JPMorgan's expert on "the reasonableness of the Jane Doe Settlement" — the only sample document that directly references the dollar amount of the Doe class settlement (EFTA02818698). The corpus does not contain the executed final settlement agreement, the Court's final approval order, the Doe class notice and claims-administration record, or the sealed deposition transcripts that the Ellsworth declaration attaches as exhibits.