Latest / The Vault: The Epstein Files / The USVI And Their Motion In Opposition To JP Morgan's Request For Dismissal (Part 3) (9/11/26)

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The USVI And Their Motion In Opposition To JP Morgan's Request For Dismissal (Part 3) (9/11/26) · The Vault: The Epstein Files

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  Speaker 1: What's up everyone and welcome back to the Epstein Chronicles.
• 0:03
  Speaker 1: In this episode, we're going to pick up where we
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  Speaker 1: left off with the USVI's motion to deny the request
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  Speaker 1: by J.P. Morgan to have the lawsuit dismissed. GGSalesforce.com Inc.
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  Speaker 1: 603 F.SUPP 3D 626 Northern District of Illinois 2022 also
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  Speaker 1: does not support J.P. Morgan's argument that the government does
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  Speaker 1: not sufficiently allege participation in In Salesforce.com, the court held
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  Speaker 1: that the plaintiff failed to allege participation by a software
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  Speaker 1: supplier whose software was used by an online marketplace to
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  Speaker 1: post advertisements for commercial sex. 603F. SUPP3D at 646 and 47.
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  Speaker 1: The court found no plausible allegations that Salesforce did anything
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  Speaker 1: but just sell Backpage off-the-shelf software. ID at 648. Finding
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  Speaker 1: no personalized services tailored to Backpage, customization, of its software
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  Speaker 1: to meet Backpage's needs. In other words, Salesforce merely supplied
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  Speaker 1: its regular product to Backpage. Unlike Salesforce.com, JPMorgan did much
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  Speaker 1: more than provide Epstein with its regular banking services. It
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  Speaker 1: handled payments Epstein was making to young women who were
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  Speaker 1: his victims and recruiters, totaling millions of dollars, which had
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  Speaker 1: no conceivable relationship to Epstein's stated business interests. It further
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  Speaker 1: handled payments from accounts of Epstein's charitable organization's two young women,
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  Speaker 1: which again had no conceivable relationship to the charity's stated purpose.
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  Speaker 1: It ignored obvious red flags relating to Epstein's accounts that
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  Speaker 1: in the normal course would have prompted action by J.P.
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  Speaker 1: Morgan and instead reported nothing unusual in Epstein's account transactions.
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  Speaker 1: It failed to demonstrate even basic due diligence on Epstein's accounts,
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  Speaker 1: particularly irregular given Epstein was a high-risk customer. It continued
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  Speaker 1: to maintain Epstein's assets for over a decade, despite the
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  Speaker 1: fact that he pled guilty to criminal felony charges constituting
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  Speaker 1: child trafficking and its internal security, risk management, and compliance
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  Speaker 1: teams repeatedly identified evidence of child and human sex trafficking. J.P.
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  Speaker 1: Morgan gave Epstein the most personalized and customized and illegal services. Moreover,
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  Speaker 1: unlike Salesforce.com, J.P. Morgan had redacted. Further, Salesforce.com differentiated cases
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  Speaker 1: where there was a showing of a continuous business relationship
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  Speaker 1: between the trafficker and the defendant, such that it would
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  Speaker 1: appear that the trafficker and the defendant have established a
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  Speaker 1: pattern of conduct or could be said to have a
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  Speaker 1: tacit agreement as to the venture. 603 F.S.U.P.P. 3D at 644.
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  Speaker 1: In M.A. v. Wyndham Hotels and Resorts, Inc., 425 S.U.P.P.
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  Speaker 1: 3D 959, 962, 970, and 71. For example, the court found,
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  Speaker 1: a sufficiently continuous relationship to constitute participation where the defendant
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  Speaker 1: hotel operator repeatedly rented rooms to a trafficker over 17 months. Here,
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  Speaker 1: while doing business with Epstein, in and beyond his accounts, J.P.
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  Speaker 1: Morgan handled and redacted Epstein's payments to victims and recruiters
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  Speaker 1: for over 10 years. J.P. Morgan separately contends that its
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  Speaker 1: redacted and redacted does not constitute participation because redacted, Putting
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  Speaker 1: aside that J.P. Morgan ignores the government's allegations that it
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  Speaker 1: facilitated the sex trafficking by handling payments to victims and recruiters,
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  Speaker 1: the government's claim is that J.P. Morgan did detect Epstein's
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  Speaker 1: sex trafficking, but redacted, in turn allowing Epstein's ongoing and
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  Speaker 1: future sex trafficking. 2. J.P. Morgan knew or acted with
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  Speaker 1: reckless disregard that minors would be caused to engage in
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  Speaker 1: commercial sex. J.P. Morgan acted with knowledge or reckless disregard
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  Speaker 1: that Epstein was sex trafficking minors based on law enforcement indictments,
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  Speaker 1: Epstein's own criminal guilty plea, and numerous additional law enforcement investigations.
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  Speaker 1: In 2006, J.P. Morgan knew that Epstein had been indicted
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  Speaker 1: for and later pled guilty to federal criminal charges of
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  Speaker 1: solicitation and procurement of a minor for prostitution. Solicitation and
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  Speaker 1: procurement of a minor for prostitution are acts covered by
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  Speaker 1: Section 1591A and 2. Recruits, entices, harbors, transports, provides, obtains, maintains,
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  Speaker 1: or solicits by any means a person and the person
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  Speaker 1: has not attained the age of 18 years and will
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  Speaker 1: be caused to engage in a commercial sex act. The
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  Speaker 1: government further alleges that in 2009, the non-prosecution agreement between
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  Speaker 1: Epstein and the United States became public and revealed information,
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  Speaker 1: federal law enforcement allegations, that Epstein may have used interstate
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  Speaker 1: commerce to induce minors to engage in prostitution. engaged illicit
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  Speaker 1: sexual conduct with minors, and trafficked minors. The complaint details
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  Speaker 1: other law enforcement investigations of child sex trafficking by Epstein,
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  Speaker 1: of which J.P. Morgan was aware, based on investigations and
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  Speaker 1: reports by its own security, risk management, and compliance teams.
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  Speaker 1: In a 2010 internal email, J.P. Morgan's Risk Management Division
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  Speaker 1: wrote of new allegations of an investigation related to child
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  Speaker 1: sex trafficking, Are you still comfortable with this client who
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  Speaker 1: is now a registered sex offender? In March 2011, JPMorgan's
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  Speaker 1: Global Corporate Security Division reported that it was aware of
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  Speaker 1: numerous articles detailing various law enforcement agencies investigating Jeffrey Epstein
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  Speaker 1: for allegedly participating, directly or indirectly, in child sex trafficking
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  Speaker 1: and molesting underage girls. Jeffrey Epstein has settled a dozen
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  Speaker 1: civil lawsuits out of court from his victims regarding solicitation
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  Speaker 1: for an undisclosed amount. The same internal JP Morgan reports
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  Speaker 1: pointed to derogatory information that Jean-Luc Brunel, owner of the
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  Speaker 1: MC2 Model Management, and Jeffrey Epstein engaged in racketeering that
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  Speaker 1: involved luring in minor children for sexual play for money.
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  Speaker 1: The government also alleges that Epstein, through J.P. Morgan, paid
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  Speaker 1: more than $ 600, 000 to Jane Doe One, a woman with
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  Speaker 1: an Eastern European surname, who J.P. Morgan's own due diligence
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  Speaker 1: reports stated Epstein purchased at the age of 14. 3. J.P.
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  Speaker 1: Morgan's knowledge or a reckless disregard of the use of force, threats, fraud,
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  Speaker 1: or coercion. With respect to victims 18 and over, Section
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  Speaker 1: 1591A2 requires that a beneficiary of sex trafficking like J.P.
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  Speaker 1: Morgan has acted with knowledge or a reckless disregard of
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  Speaker 1: the fact that means of force, fraud, and or coercion
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  Speaker 1: will be used to cause the victim to engage in
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  Speaker 1: commercial sex acts. The government alleges that J.P. Morgan knew
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  Speaker 1: it was processing Epstein's payments to specific young women around
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  Speaker 1: the world. that these young women were trafficked by or
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  Speaker 1: recruiters of victims for Epstein, and that JP Morgan knew
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  Speaker 1: these payments had no conceivable relationship to Epstein's stated business interests,
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  Speaker 1: and that JP Morgan knew that Epstein was being connected
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  Speaker 1: repeatedly to human trafficking activity. After Epstein's arrest and death
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  Speaker 1: in 2019, JP Morgan acknowledged that recipients of the payments
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  Speaker 1: may be victims of human trafficking. In addition to consistent
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  Speaker 1: references to human trafficking, J.P. Morgan, the government, alleges that J.P.
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  Speaker 1: Morgan's internal reports showed accounts of MC2, modeling agency, and
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  Speaker 1: Epstein luring victims. It is inferable that the young women
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  Speaker 1: would have been lured by a modeling agency with the
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  Speaker 1: fraudulent promise of modeling opportunities and careers. Moreover, J.P. Morgan
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  Speaker 1: handled payments for numerous women with Eastern European surnames who
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  Speaker 1: were publicly and internally identified as Epstein recruiters, and or victims,
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  Speaker 1: including Jane Doe One, who J.P. Morgan's own internal report
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  Speaker 1: stated Epstein purchased when she was a child. It is
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  Speaker 1: inferable these young women from Eastern Europe were subject to fraud, force,
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  Speaker 1: or coercion. J.P. Morgan argues that the government fails to
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  Speaker 1: allege knowledge of trafficking for a specific victim. Motion at 10.
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  Speaker 1: This argument is incorrect for two reasons. First, J.P. Morgan
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  Speaker 1: omits Section 1591A' s coverage of a defendant having reckless disregard. Second, J.P.
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  Speaker 1: Morgan ignores that the government identifies 20 specific young women
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  Speaker 1: who were trafficked by Epstein in the Virgin Islands and elsewhere,
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  Speaker 1: for whom J.P. Morgan handled Epstein's payments knowing there was
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  Speaker 1: no conceivable relationship to Epstein's stated business interests, knowing that
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  Speaker 1: Epstein was repeatedly being connected to trafficking, and recognizing that
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  Speaker 1: these women may be victims of human trafficking. J.P. Morgan's
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  Speaker 1: own internal reports stated that Epstein purchased Jane Doe 1
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  Speaker 1: at $ 14, 000 yet it processed $ 600, 000 in payments by Epstein
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  Speaker 1: to her. The government also alleges that J.P. Morgan had
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  Speaker 1: up-close view of Epstein's conduct. These allegations support a plausible
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  Speaker 1: inference that J.P. Morgan knew, or at a minimum, acted
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  Speaker 1: with reckless disregard for the probability that these women were
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  Speaker 1: being subjected to forced threats of fraud and or coercion. C.E.G.
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  Speaker 1: Studeau v. Fleischman, 164F. 3D. 820. 827, 2nd Circuit, 1999 reckless disregard shown
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  Speaker 1: by recognition of substantial probability of harm and action with
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  Speaker 1: disregard for its occurrence. J.P. Morgan separately argues that the
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  Speaker 1: government cannot establish knowledge based solely on J.P. Morgan's awareness
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  Speaker 1: of allegations of Epstein's trafficking. Again, J.P. Morgan omits reckless
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  Speaker 1: disregard Epstein's guilty plea to conduct that constitutes child sex
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  Speaker 1: trafficking under Section 1591, which is knowledge, not an allegation,
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  Speaker 1: and its own observation of red flags and adoption of
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  Speaker 1: the trafficking allegations. Moreover, the allegations, or lack thereof, in
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  Speaker 1: Grubea are a far cry from this case. Grubea found
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  Speaker 1: that there was no evidence of knowledge of wrongdoing, not
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  Speaker 1: even allegations, 318 F.S.U.P.P. 3D at 701. Argument that the
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  Speaker 1: government knew of the fraudulent conduct at issue is pure speculation.
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  Speaker 1: In Escobar, the allegations that were held insufficient to give
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  Speaker 1: rise to knowledge were some complaints by private individuals to
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  Speaker 1: state regulators about a healthcare provider. The allegations were numerous,
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  Speaker 1: widely reported, in many cases involved law enforcement investigations, and
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  Speaker 1: extended over a number of years. Given Epstein was a
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  Speaker 1: registered sex offender, felon, and high-risk client, J.P. Morgan's failure
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  Speaker 1: to follow up on these allegations, other than to assign Staley,
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  Speaker 1: whose J.P. Morgan emails strongly suggest he was involved in
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  Speaker 1: Epstein sex trafficking, and whose relationship with Epstein catapulted his career,
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  Speaker 1: to talk to Epstein, at a minimum shows reckless disregard. J.P.
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  Speaker 1: Morgan cites, SJ vs. Choice Hotels International 473 SUPP 3D
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  Speaker 1: 147 154 EDNY 2020. See motion at 12 and 13
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  Speaker 1: for the proposition that knowledge or willful blindness of a
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  Speaker 1: general sex trafficking problem does not satisfy the mens rea
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  Speaker 1: requirements of the TVPA. This is in opposite because the
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  Speaker 1: government alleges that J.P. Morgan had general knowledge of trafficking,
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  Speaker 1: but that it had knowledge of the specific sex trafficking venture.
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  Speaker 1: Epstein was operating through the foregoing evidence that was uniquely
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  Speaker 1: in its sights. Alright, we're going to wrap this episode
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  Speaker 1: up right here, and in the next episode dealing with
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  Speaker 1: the topic, we're going to pick up where we left off,
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  Speaker 1: and that's with Part 4. J.P. Morgan knowingly benefited. All
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  Speaker 1: of the information that goes with this episode can be
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  Speaker 1: found in the description box.