She then ordered him to perform oral sex on her, ignoring his pleas of ‘don’t make me do this.’
‘Afraid that Ms. Hajdini would act on her threats to retaliate against him, [Doe], embarrassed and humiliated, complied with her demands,’ the lawsuit states.
Doe claims he was assaulted again later the same month.
During the second encounter, Hajdini allegedly ordered him to suck her toes, pushed him to the ground and sat on his face, berating him when he was unable to sustain arousal.
‘I’m very uncomfortable, please, Lorna, please, I’m begging you,’ Doe claims he told her. But she allegedly laughed before making a racist remark that at least his genitals didn’t ‘taste like curry,’ according to the complaint.
Over the following months, Doe claims Hajdini continued to subject him to overt sexual advances at work and in public, and continued to sexually assault him.
The complaint says she repeatedly reminded him that she ‘owned’ him and that she controlled his promotion and bonus, which he understood as a threat that she would block both if he refused.
During an encounter in late September 2024, Hajdini allegedly yelled at Doe that he wasn’t bringing in enough business to help her secure a promotion to Managing Director, before again threatening him if he refused to have sex with her, the complaint says.
‘I f**king own you! I will make you pay… Do you think you’re going to be in good standing if you do not have me in your corner,’ she allegedly said. ‘You really think [management]… want some Brown boy Indian leading Originations?… If you don’t f**k my brains out tonight, I’m going to sabotage your promotion.’
Fearful of retaliation, Doe claims he relented and submitted to another encounter.
His initial protests were overheard by a second witness who was staying in the adjoining room, according to the lawsuit.
The complaint was filed Monday in New York County Supreme Court by a plaintiff proceeding anonymously as John Doe
Doe claims Hajdini later admitted to drugging him with Rohypnol or ‘roofies’ and ‘an erection-enabling pharmaceutical substance’, to ensure he could perform before coerced encounters.
Fearful of reporting her behavior, and allegedly concerned JPMC would not properly investigate his claims, Doe began seeking job opportunities elsewhere in late 2024.
However, he claims in the complaint that Hajdini and other senior managers conspired to derail his prospects with ‘aggressively negative’ references after learning of his plans to leave.
In May 2025, Doe delivered a written complaint to JPMC detailing what he described as race and gender-based discrimination and harassment, and a pattern of ‘severe sexual abuse.’
A week later, he claims the firm began retaliating against him.
That included receiving anonymous threatening phone calls from individuals he believes were acting on behalf of Hajdini and others, attempting to scare him into silence, according to the complaint.
‘Just wait ‘till you’re back in New York, Brown boy…’ one caller allegedly told him. ‘You better stay away – snitch.’
On June 9, 2025, Doe says he received a voicemail from someone claiming to be a manager at JPMC, telling him he wasn’t welcome because of his skin color, adding that ‘people don’t want you or your kind here.’
Another caller allegedly threatened to contact US Immigration and Customs Enforcement (ICE) about him and his family.
The lawsuit also accuses JPMorgan Chase of enabling the alleged abuse and retaliating against the banker after he reported it
Doe claims the company took overt steps to retaliate against him as well, the complaint states.
Within days of filing his report, he says he was reprimanded and then locked out of all company systems and placed on involuntary leave – a decision he claims HR linked to his complaints.
Meanwhile, he alleges that Hajdini and other executives he accuses have faced no comparable action.
JPMC denied Doe’s claims, insisting an investigation found no evidence to support his allegations. Hajdini is still employed at the company.
In an interview with the Daily Mail, Doe’s attorney, Daniel J Kaiser, called his client’s allegations horrendous and disturbing.
Kaiser said Doe has been left devastated personally and professionally by the treatment he was allegedly subjected to.
He claims his client has been diagnosed with Post-Traumatic Stress Disorder (PTSD) and continues to struggle financially because his reputation has been damaged and he has been unable to find another job.
Doe is seeking damages for lost earnings, emotional distress and reputational harm, as well as punitive damages and changes to the bank’s practices, according to the complaint.