Latest / Beyond The Horizon / The USVI Pushes Back On The Epstein Estates Attempt To Remove The Liens (11/10/26)
Transcript
- 0:00Speaker 1: What's up everyone and welcome back to the program. In
- 0:03Speaker 1: this episode, we're going to dive back into some Epstein
- 0:06Speaker 1: court documents and we're going to look at the USVI
- 0:09Speaker 1: and their opposition to the request to extinguish criminal activity liens.
- 0:16Speaker 1: Case number 19-PB-000080 in the matter of the Epstein estate.
- 0:26Speaker 1: Government of the United States, Virgin Islands, opposition to request
- 0:30Speaker 1: to extinguish criminal activity liens. The Government of the United States,
- 0:34Speaker 1: Virgin Islands, hereby responds to the supplemental brief regarding co-executors'
- 0:39Speaker 1: obligations to satisfy expenses of administration notwithstanding liens issued to
- 0:44Speaker 1: the estate, filed before the probate division of the Superior Court,
- 0:49Speaker 1: and opposes the request therein for this court to enter
- 0:52Speaker 1: a judgment extinguishing the criminal activity liens entered against the
- 0:56Speaker 1: estate of Jeffrey E. Epstein. Introduction. The court should deny
- 1:01Speaker 1: the co-executor's request for a judgment extinguishing the government's criminal
- 1:05Speaker 1: activity liens because the court has no authority to grant
- 1:09Speaker 1: this relief and the arguments the co-executors make are legally
- 1:13Speaker 1: incorrect and misleading. The probate court lacks authority to extinguish
- 1:18Speaker 1: the criminal activity liens while the government's Criminally Influenced and
- 1:22Speaker 1: Corrupt Organizations Act action is pending against the Epstein estate.
- 1:27Speaker 1: Under SECO, when the Attorney General files a criminal activity
- 1:30Speaker 1: lien notice upon commencement of an action, the lien attaches
- 1:34Speaker 1: as of the filing and shall continue thereafter until expiration, termination,
- 1:39Speaker 1: or release as provided herein. 14 Virgin Island Code Section 610F.
- 1:45Speaker 1: The Act further provides that during the lien notice's six-year term,
- 1:49Speaker 1: Virgin Island Code 14 Section 610Q, only the Attorney General
- 1:53Speaker 1: or the United States Attorney Filing the criminal activity lien
- 1:57Speaker 1: notice may release the criminal activity lien notice upon such
- 2:00Speaker 1: terms as he may determine. Virgin Island Code 610 R.
- 2:05Speaker 1: The sole exception where a court may release or extinguish
- 2:08Speaker 1: a criminal activity lien arises if no criminal or civil
- 2:11Speaker 1: proceeding or action under this chapter is then pending against
- 2:15Speaker 1: the person named in a criminal activity lien notice. Virgin
- 2:19Speaker 1: Island Code 14 Section 610 T. The exception clearly does
- 2:23Speaker 1: not apply here because the government's SECO action is pending
- 2:27Speaker 1: against the Epstein estate. Thus, the court has no authority
- 2:30Speaker 1: or discretion to enter a judgment, as the co-executors request,
- 2:35Speaker 1: extinguishing the government's criminal activity liens. Even if the court
- 2:39Speaker 1: had the authority, which it does not, the co-executors fail
- 2:42Speaker 1: to raise any legal basis for this relief. The co-executors
- 2:46Speaker 1: argue that criminal activity lien notices apply to trustees, and
- 2:50Speaker 1: that since they are not trustees, the liens do not
- 2:53Speaker 1: apply to them. Under SECO, however, the criminal activity lien
- 2:56Speaker 1: notices may apply not only to a trustee, but to
- 3:00Speaker 1: any person or other entity named in the notice. Virgin
- 3:03Speaker 1: Island Code 14, Section 610C. The Epstein estate is such
- 3:08Speaker 1: an entity properly sued as a defendant. CEG Outley v.
- 3:13Speaker 1: Estate of Bell, 61, Virgin Islands, 480, 500, 2014. Outley
- 3:15Speaker 1: correctly named Bell's estate as the defendant. The co-executors also
- 3:23Speaker 1: argue that the government's SECO action is defective for not
- 3:26Speaker 1: complying with Virgin Island Code 15 Section 606 timing and
- 3:31Speaker 1: notice procedures. Section 606, however, applies only to a creditor's
- 3:36Speaker 1: claim against an executor or administrator. U.S. Code 15 Section 606B.
- 3:42Speaker 1: See also Oat v. Sewer Enterprises LTD 46 Virgin Islands
- 3:46Speaker 1: 286-290 DVI 2004. Section 606B forbids the plaintiff from commencing
- 3:54Speaker 1: an action against the sewer's estate until she has first
- 3:58Speaker 1: presented a claim to sewer. The government's SECO action and
- 4:01Speaker 1: criminal activity liens seeking forfeiture and divestiture from the Epstein
- 4:05Speaker 1: estate's property within the Virgin Islands used to facilitate Mr.
- 4:09Speaker 1: Epstein's criminal sex trafficking enterprise is not such a claim.
- 4:13Speaker 1: See Outley 61 VI at Ford 98. we agree that
- 4:17Speaker 1: an action for partition is not a claim that is
- 4:20Speaker 1: required to be presented to an estate's executor or administrator
- 4:24Speaker 1: under Section 606. Finally, the co-executor's argument that the Epstein
- 4:29Speaker 1: estate's expenses relating to other persons' claims take priority under
- 4:33Speaker 1: Virgin Island Code 15 Section 421 fails because the government's
- 4:37Speaker 1: criminal activity liens take priority over all claims except those
- 4:41Speaker 1: where a beneficial interest was acquired before the filing of
- 4:44Speaker 1: the lien notice. See Virgin Island Code 14, Section 610F.
- 4:49Speaker 1: The co-executors do not, in their briefing identity, any claimant
- 4:53Speaker 1: who has obtained a judgment as of January 16, 2020,
- 4:57Speaker 1: when the government filed its lien notice. Thus, no identified
- 5:01Speaker 1: claimant has priority over the government's criminal activity lien. Therefore,
- 5:05Speaker 1: the co-executor's request for a judgment extinguishing the government's criminal
- 5:09Speaker 1: activity liens is procedurally defective because the court lacks the
- 5:13Speaker 1: authority to grant this relief is substantively baseless and should
- 5:17Speaker 1: be denied. The argument, A. The court lacks authority to
- 5:21Speaker 1: extinguish the government's criminal activity liens while its SECO action
- 5:24Speaker 1: against the Epstein estate is pending. In their supplemental brief,
- 5:28Speaker 1: the co-executors ask the court to allow them to disregard
- 5:31Speaker 1: the government's criminal activity liens against the Epstein estate. Supplemental
- 5:36Speaker 1: brief at 1. To enter a judgment extinguishing the liens,
- 5:39Speaker 1: ID at 3, and to reject the liens, ID at 7.
- 5:43Speaker 1: see also Emergency Motion at 14-17. The court should vacate
- 5:47Speaker 1: the liens. The court should reject these requests out of
- 5:51Speaker 1: hand because it lacks authority to grant this relief. Under SECO,
- 5:55Speaker 1: where the government has filed an action against a party
- 5:58Speaker 1: and concurrently filed a criminal activity lien notice, only the
- 6:01Speaker 1: Attorney General may release the liens thereunder while the action
- 6:05Speaker 1: is pending. The relevant SECO sections provide that, upon the
- 6:08Speaker 1: institution of any criminal or civil proceeding or action under
- 6:12Speaker 1: this chapter, the Attorney General may file a criminal activity
- 6:15Speaker 1: lien notice and that the Clerk of the Trial Court shall,
- 6:18Speaker 1: upon the presentation of a criminal activity lien notice, immediately
- 6:22Speaker 1: record in the official records. Virgin Island Code 14, Section 610.
- 6:28Speaker 1: The government has done this here. See Exhibit A, here too,
- 6:31Speaker 1: criminal activity lien notices. The government's filing of a criminal
- 6:35Speaker 1: activity lien notice creates, from the time of its filing,
- 6:39Speaker 1: a lien in favor of the government of the territory
- 6:41Speaker 1: of the Virgin Islands, on the name, person, or entities, personal,
- 6:45Speaker 1: or real property situated in the territory of the Virgin Islands,
- 6:49Speaker 1: and on any beneficial interest in it located in the
- 6:52Speaker 1: territory of the Virgin Islands. Virgin Island Code 14, Section
- 6:58Speaker 1: 610E1 and 2. See also Virgin Island Code 14, Section 6101.
- 7:03Speaker 1: The lien shall commence and attach as the time of
- 7:06Speaker 1: the filing of the criminal activity lien notice. The government's
- 7:09Speaker 1: activity liens thus already are attached to all of Epstein's
- 7:12Speaker 1: estate's property and interests located within the territory of the
- 7:16Speaker 1: Virgin Islands. Once the government's criminal activity liens were filed
- 7:20Speaker 1: and attached, they shall continue thereafter until expiration, termination, or
- 7:24Speaker 1: release provided herein. Virgin Island Code 14 Section 610F. With
- 7:30Speaker 1: respect to expiration, the Act provides that the term of
- 7:33Speaker 1: the criminal activity lien notice shall be for a period
- 7:36Speaker 1: of six years from the date of filing. and the
- 7:39Speaker 1: subject to renewal for one additional six-year period upon notice
- 7:43Speaker 1: filed by the Attorney General. Virgin Island Code 14 Section 610Q,
- 7:49Speaker 1: the government's liens on the Epstein estate thus shall continue
- 7:52Speaker 1: in effect until either January 16, 2026 or January 16, 2032,
- 7:57Speaker 1: absent a termination or a release, whereas here the government's
- 8:03Speaker 1: underlying SECO action still is pending and only the Attorney
- 8:07Speaker 1: General may release any property or interest from the criminal
- 8:10Speaker 1: activity liens. This is the express command of the statute
- 8:14Speaker 1: which provides in relevant part that the Attorney General filing
- 8:18Speaker 1: the criminal activity lien notice may release in whole or
- 8:21Speaker 1: in part any criminal activity lien notice or may release
- 8:25Speaker 1: any personal or real property or beneficial interest in it
- 8:28Speaker 1: from the criminal activity lien notice upon such terms and
- 8:31Speaker 1: conditions as he may determine. Virgin Island Code 14, Section 610R.
- 8:37Speaker 1: The act thus is unambiguous that where, as here, a
- 8:41Speaker 1: criminal activity lien notice has commenced and attached upon the
- 8:44Speaker 1: Attorney General's filing of an action and notice, the Attorney
- 8:48Speaker 1: General has sole authority to release the liens upon such
- 8:51Speaker 1: terms and conditions as she may determine to be appropriate.
- 8:55Speaker 1: This exclusive authority is with the Attorney General leaves no
- 8:57Speaker 1: room for the court or any other to disregard, extinguish,
- 9:01Speaker 1: or reject the government's criminal activity liens, as to the
- 9:05Speaker 1: co-executor's request. The one instance in which SECO permits a
- 9:09Speaker 1: court to release or extinguish a criminal activity lien notice
- 9:12Speaker 1: does not apply here. The Act provides that there were
- 9:16Speaker 1: no criminal or civil proceeding or action under this chapter
- 9:20Speaker 1: is then pending against the person named in a criminal
- 9:22Speaker 1: activity lien notice... Any person named in a criminal activity
- 9:26Speaker 1: lien notice may institute an action seeking a release or
- 9:29Speaker 1: extinguishment of the notice, which a court may grant upon
- 9:33Speaker 1: appropriate factual findings. Virgin Island Code 14, Section 610T, 1-3.
- 9:39Speaker 1: This provision does not apply here for the simple reason
- 9:42Speaker 1: that the government's SECO action against the Epstein estate is
- 9:45Speaker 1: pending before the Superior Court. which has sole authority to
- 9:49Speaker 1: hear any challenge to that action, such as the co-executor's
- 9:52Speaker 1: purported constitutional challenge to the government's criminal activity liens. Emergency
- 9:57Speaker 1: motion at 8 and 10. This court, however... has no
- 10:00Speaker 1: authority to disregard, extinguish, or reject the government's criminal activity
- 10:05Speaker 1: liens against the Epstein estate. The estate may, however, attempt
- 10:09Speaker 1: to invoke the statutory exception by moving the Superior Court,
- 10:13Speaker 1: not this court, to dismiss the SECO action. Virgin Island
- 10:17Speaker 1: Code 14, Section 610U. In the event of a civil
- 10:20Speaker 1: proceeding is pending against a person named in a criminal
- 10:23Speaker 1: activity lien notice, the Superior Court or United States District Court,
- 10:27Speaker 1: upon motion by the person, may grant the relief set
- 10:31Speaker 1: forth in this section. A dismissal on the merits of
- 10:33Speaker 1: the Superior Criminal Activity Lien at such a time, see
- 10:37Speaker 1: Virgin Island Code 14, Section 610, S & T. The
- 10:41Speaker 1: estate has not done so, however. In sum, the co-executors'
- 10:44Speaker 1: request that the court disregard, extinguish, or reject the government's
- 10:49Speaker 1: criminal activity liens has no merit or basis in law
- 10:52Speaker 1: and therefore must be denied. In light of the legislature's
- 10:56Speaker 1: purpose in enacting SECO to curtail criminal activity and lessen
- 10:59Speaker 1: its economic power in the territory of the Virgin Islands
- 11:03Speaker 1: by providing to law enforcement new civil sanctions and remedies,
- 11:07Speaker 1: Virgin Island Code 14, Section 601, the probate court has
- 11:11Speaker 1: no authority to grant this relief while the government's SECO
- 11:14Speaker 1: action against the Epstein estate is pending in Superior Court. b.
- 11:19Speaker 1: The co-executor's legal arguments for extinguishing the government's criminal activity
- 11:22Speaker 1: liens are incorrect. Even if the probate court had authority
- 11:26Speaker 1: to extinguish the criminal activity liens during the pendency of
- 11:29Speaker 1: the government's SECO actions against the Epstein estate, which it
- 11:32Speaker 1: does not, the court also should not grant this relief
- 11:35Speaker 1: because the co-executor's legal arguments proffered in support of it
- 11:39Speaker 1: are incorrect. First, the co-executors argue that criminal activity lien
- 11:44Speaker 1: notices apply to trustees pursuant to Virgin Island Code 14,
- 11:47Speaker 1: Section 610, but that a trustee under SECO does not
- 11:51Speaker 1: include an executor appointed by or under the control of
- 11:55Speaker 1: or accountable to a court. Supplemental briefing at 2. See
- 11:58Speaker 1: also emergency motion at 10. This is true as far
- 12:01Speaker 1: as it goes, but that is not far enough. Although
- 12:04Speaker 1: SECO does apply to trustees CEG, Virgin Island Code 14,
- 12:08Speaker 1: Section 610, K & M, it does not apply only
- 12:11Speaker 1: to trustees. Rather, SECO's criminal activity lien notice provisions apply
- 12:16Speaker 1: to any person or other entity named in the notice,
- 12:19Speaker 1: Virgin Island Code 14, Section 610E. Thus, whether or not
- 12:24Speaker 1: the co-executors are considered trustees under SECO, they do not
- 12:28Speaker 1: have to be because the act applies far more broadly
- 12:31Speaker 1: to any other person or entity of which the Epstein
- 12:34Speaker 1: estate is one. Second, arguing the next, That the lien
- 12:38Speaker 1: is not valid against the estate because the underlying SECO
- 12:41Speaker 1: action is not, the co-executors assert that it's axiomatic that
- 12:46Speaker 1: an estate is not a legal entity and cannot be sued.
- 12:50Speaker 1: And the same holds true with respect to the government
- 12:52Speaker 1: naming the 1953 trust, which also cannot be sued, as
- 12:56Speaker 1: a defendant in its forfeiture action. Supplemental brief at 2
- 13:00Speaker 1: and 3 see also emergency motion at 13 and 14.
- 13:03Speaker 1: An estate is not a legal entity. It cannot be sued.
- 13:07Speaker 1: This argument makes no reference to Virgin Islands law and
- 13:09Speaker 1: is clearly incorrect and baseless. Indeed, just two sentences earlier
- 13:14Speaker 1: in their brief, the co-executors cited to the case of
- 13:17Speaker 1: Otley and estate of Bell Supra, see supplemental brief at 2,
- 13:21Speaker 1: the Otley case is, as its caption suggests, a lawsuit
- 13:26Speaker 1: naming an estate as defendant. See 61 Virgin Islands at 486,
- 13:29Speaker 1: Otley named Bell's estate Ebony and Gerard collectively, appellees, as
- 13:35Speaker 1: defendants in the action. Moreover, in its decision in Otley
- 13:39Speaker 1: and Virgin Island Supreme Court, Squarely held that Otley correctly
- 13:43Speaker 1: named Bell Estate as the defendant, and although not necessary,
- 13:46Speaker 1: additionally listed the two heirs entitled to inherit his interests
- 13:50Speaker 1: in the disputed property, ID at 500, CF Francis v.
- 13:54Speaker 1: Ruan Living Trust, No. ST 15 CV 177, 2016, Virgin
- 13:57Speaker 1: Island Lexus 160 at 13. Virgin Islands Superior Court, Division
- 14:05Speaker 1: of St. Thomas and St. John, October 5th, 2016. Plaintiff
- 14:09Speaker 1: has pled sufficient facts to support her claim of negligence
- 14:12Speaker 1: against defendant Ruan Trust. Thus, the co-executors' argument that the
- 14:17Speaker 1: government's SECO action is improper because the Epstein estate cannot
- 14:20Speaker 1: be sued is incorrect and should be rejected. Third, the
- 14:23Speaker 1: co-executors argue that the government's entire SECO action is defective
- 14:27Speaker 1: as well because the government has failed to follow the
- 14:30Speaker 1: statutory procedures required In Virgin Island Code 15, Section 606B.
- 14:35Speaker 1: That must be met before such an action can be commenced.
- 14:38Speaker 1: Supplemental brief at 2. See also emergency motion at 11
- 14:42Speaker 1: through 13. Repeating Section 606 argument. This too is wrong.
- 14:47Speaker 1: Section 606 timing and notice requirements apply only to a
- 14:51Speaker 1: claim against an executor or administrator. 15 U.S. Code 606B.
- 14:56Speaker 1: The Otley Supra of the Virgin Island Supreme Court. addressed
- 14:59Speaker 1: an action for partition of real property brought by a
- 15:02Speaker 1: half-owner against the estate of the other half-owner and her heirs,
- 15:06Speaker 1: who argued that the action was invalid for failure to
- 15:09Speaker 1: comply with Section 606B. See 61 Virgin Island at 485.
- 15:14Speaker 1: The Supreme Court reversed dismissal of the action, holding that
- 15:19Speaker 1: an action for partition is not a claim that is
- 15:22Speaker 1: required to be presented to an estate's executor or administrator
- 15:25Speaker 1: under Section 606, ID at 498. The court explained that
- 15:30Speaker 1: at Section 606 coverage of claims contemplates the debts that
- 15:34Speaker 1: the deceased incurred during their lifetime and which accreditor is
- 15:37Speaker 1: attempting to recover from the estate, whereas an action for
- 15:41Speaker 1: partition is not an attempt to recover debt or property
- 15:44Speaker 1: from an estate. The same is true here with respect
- 15:47Speaker 1: to the government's SECO action against the Epstein estate for
- 15:50Speaker 1: forfeiture and divestiture of Epstein's interests in real and personal
- 15:53Speaker 1: property within the U.S. Virgin Islands used to facilitate Mr.
- 15:57Speaker 1: Epstein's sex trafficking enterprise, civil penalties, damages, and other equitable remedies.
- 16:03Speaker 1: See complaint, prayer for relief. Since the government is not
- 16:06Speaker 1: seeking payments of an alleged debt owed by the Epstein estate,
- 16:10Speaker 1: Virgin Island 15, Section 606 does not apply. The court, therefore,
- 16:14Speaker 1: should likewise reject the collateral attack on the SECO action
- 16:18Speaker 1: and criminal activity liens. Fourth, the co-executors argue that the
- 16:22Speaker 1: Virgin Island Code creates an unambiguous preference in favor of
- 16:26Speaker 1: payment of the estate's administration and that the government's criminal
- 16:30Speaker 1: activity liens thus are subordinate to the estate's administrative expenses,
- 16:34Speaker 1: including primarily those for defending 22 pending lawsuits filed in
- 16:39Speaker 1: multiple jurisdictions, supplemental brief 3 and 4, citing Virgin Island
- 16:43Speaker 1: Code 15 Section 421C. This argument, too, must fail. The
- 16:49Speaker 1: 22 other pending lawsuits would constitute other claims against the
- 16:53Speaker 1: estate under Section 421A7. The co-executors do not contend, however,
- 16:58Speaker 1: that any of these lawsuits have been litigated to judgment
- 17:01Speaker 1: against Mr. Epstein or the Epstein estate. Absent an enforceable
- 17:05Speaker 1: judgment as of the time of the government filed its
- 17:08Speaker 1: criminal activity lien notice, those claims are subordinate to the
- 17:11Speaker 1: government's liens. See Virgin Island Code 14, Section 610F. The
- 17:16Speaker 1: government's criminal activity lien shall be superior to and prior
- 17:20Speaker 1: to the interest of any other person in the personal
- 17:22Speaker 1: or real property or beneficial interest in it if the
- 17:26Speaker 1: interest is acquired subsequent to the filing of the notice. Here,
- 17:30Speaker 1: the government's criminal activity lien notice was filed prior to
- 17:33Speaker 1: and thus is superior to any acquired interest in the
- 17:37Speaker 1: claims in the identified cases. The co-executor's arguments, therefore, should
- 17:41Speaker 1: be rejected if as an attempt at an end run
- 17:44Speaker 1: around the SECO lien enforcement provisions. And finally, the court
- 17:47Speaker 1: also should reject the co-executor's argument that the equity strongly
- 17:51Speaker 1: disfavored the imposition of the liens. Supplemental Brief at 6.
- 17:55Speaker 1: The government's criminal activity liens are not proposed preliminary injunction
- 17:59Speaker 1: subject to judicial review based upon a balancing of asserted equities.
- 18:04Speaker 1: CEG SBRM COA LLC vs. Morehouse Real Estate Investment LLC
- 18:10Speaker 1: 62 Virgin Island LLC 168-186 VI Superior Court, St. Thomas
- 18:16Speaker 1: and St. John. A preliminary injunction is an extraordinary remedy
- 18:20Speaker 1: offering equitable relief. However, flexibility is a hallmark of equity jurisdiction.
- 18:26Speaker 1: The best approach would appear to require the Virgin Island
- 18:28Speaker 1: courts to balance these two conflicting concepts in fashionable, equitable relief. Here,
- 18:34Speaker 1: the government's criminal activity liens under SECO do not invite
- 18:38Speaker 1: or permit the court to balance perceived inequities based upon
- 18:42Speaker 1: the Epstein estate co-executors purported assertions of the interest of Mr.
- 18:47Speaker 1: Epstein's many victims. To the extent the co-executors resist or
- 18:51Speaker 1: deary the sweeping remedies the government invokes under SECO, they
- 18:55Speaker 1: are trying to avoid or rewrite the history in which Mr.
- 18:58Speaker 1: Epstein chose to carry out his sex trafficking enterprise in
- 19:01Speaker 1: the Virgin Islands on his vast property buildings here. Whatever Mr.
- 19:06Speaker 1: Epstein's reasons were for making his choice, The Epstein estate
- 19:09Speaker 1: and its co-executors cannot avoid the consequences of his choice
- 19:13Speaker 1: based on a purported assertion of his victim's interest in
- 19:16Speaker 1: an attempt to override controlling Virgin Islands law. The government
- 19:20Speaker 1: is very sympathetic to the interests of victims, those who
- 19:23Speaker 1: may participate voluntarily in an informal claims process, those who
- 19:27Speaker 1: may choose to pursue existing lawsuits to judgment, or those
- 19:30Speaker 1: who may come forward in the future and is willing
- 19:32Speaker 1: to work with the estate and victims themselves. as with
- 19:35Speaker 1: Epstein's estate and expenses to release funds to resolve their claims.
- 19:40Speaker 1: But that decision is at the government's discretion upon acceptable
- 19:43Speaker 1: terms and accounting. Regardless of the co-executor's arguments, the law
- 19:48Speaker 1: is clear that the government criminal activity liens are enforceable
- 19:52Speaker 1: against the Epstein estate and superior as to any other interests. Conclusion.
- 19:57Speaker 1: For all those reasons set forth, the court lacks authority
- 20:00Speaker 1: to grant the co-executor's request to disregard, extinguish, or reject
- 20:04Speaker 1: the government's criminal activity liens, and therefore should deny these requests.
- 20:08Speaker 1: Respectfully submitted, Denise George. And this was submitted February 10th, 2020.
- 20:14Speaker 1: All right, folks, that's going to do it for this one.
- 20:16Speaker 1: All of the information that goes with this episode can
- 20:19Speaker 1: be found in the description box.