(Bloomberg) -- JPMorgan & Chase Co. pushed back on allegations that its former executive Jes Staley “personally observed” Jeffrey Epstein’s abuse, calling them “unsupported” and “conclusory.”

The bank on Tuesday night asked a federal judge to dismiss an amended lawsuit filed last month by Epstein victims who claim JPMorgan facilitated his sex-trafficking ring. The revised suit added claims that Staley had direct knowledge of Epstein’s activities, contending that meant the bank knew as well.

JPMorgan said the unsupported allegation that Staley observed the lead plaintiff’s sexual battery by Epstein couldn’t be used to impute knowledge to the bank. 

“Actual knowledge of Plaintiff’s battery cannot be established by the unsupported assertion that, at an unspecified time, Staley ‘observed [Plaintiff] in circumstances indicating sexual abuse and trafficking,’” the bank said in its filing.

Staley, who is not named as a defendant in the suit, has consistently denied knowledge of Epstein’s abuse. He left JPMorgan in 2013 and was later appointed chief executive officer at Barclays Plc. He stepped down in 2021 following a UK Financial Conduct Authority probe into his ties to Epstein.

The amended complaint alleges that Staley, who was JPMorgan’s head of private banking at the time, frequently visited Epstein’s properties, including his New York townhouse massage room, a “stash house” apartment on Manhattan’s Upper East Side and a US Virgin Islands estate. He met many of Epstein’s trafficking victims and witnessed the financier “sexually grabbing” some of them, the suit claims.

But JPMorgan said that, while “odious,” such grabbing didn’t establish the plaintiff was a sex-trafficking victim, much less that Staley knew that she was. The bank noted that the crime of sex-trafficking only applies to children or adults subject to force or coercion. 

“Without that crucial detail, Plaintiff alleges nothing more than that a JPMC employee developed a bond with a wrongdoer customer,” the bank’s lawyers wrote. 


Even with the new allegations about Staley, the suit’s “sparse allegations and meritless legal theories” mean it should be dismissed, JPMorgan said.

Proposed class actions against both JPMorgan and Deutsche Bank, which became Epstein’s main bank after 2013, were first filed separately in November by a plaintiff identified as Jane Doe 1. The suits claim the banks knowingly benefited and received things of value for assisting and supporting Epstein’s sex-trafficking scheme. 

Like JPMorgan, Deutsche Bank has also sought dismissal of the claims, denying knowledge of Epstein’s conduct. 

In a filing late Tuesday, Deutsche Bank argued that Doe added “few new factual allegations” in the 60-plus pages she added to her original complaint and instead offered “conclusory” and “unsupported” claims that are legally inadequate for the case to proceed.

The Frankfurt-based bank also said it recently learned from Doe’s lawyer that she entered into a settlement with Epstein’s estate which included a “broad release” of claims against any entity that was ever engaged by or worked for the financier. This means that Doe has waived her claims against Deutsche Bank, the company’s lawyers said in the filing.

The plaintiffs, represented by David Boies, are suing under New York’s Adult Survivors Act, which temporarily lifts the time limit for sexual assault claims, but both banks say the law does not apply to them.

Epstein was found dead in his US jail cell in 2019, after being charged with sex-trafficking. His connections to US and British elites led to career downfalls for a number of prominent Wall Street names.

The case is Jane Doe 1 v. JPMorgan Chase Bank, 22-cv-10019, US District Court, Southern District of New York (Manhattan).

--With assistance from Robert Burnson.

(Updates with Deutsche Bank’s arguments for dismissal of suit)

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