Latest / Beyond The Horizon / Mega Edition: The Epstein Survivors Class Action Suit Filed Against JP Morgan (Part 5-9) (11/1/26)

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Mega Edition: The Epstein Survivors Class Action Suit Filed Against JP Morgan (Part 5-9) (11/1/26) · Beyond The Horizon

• 0:00
  Speaker 1: What's up everyone and welcome to another episode of the
• 0:03
  Speaker 1: Epstein Chronicles. In this episode, we're getting right back to
• 0:06
  Speaker 1: the survivor's lawsuit filed against JP Morgan. Between 2000 and 2005,
• 0:15
  Speaker 1: Epstein provided clients to JP Morgan and in exchange, JP
• 0:19
  Speaker 1: Morgan allowed Epstein to do as he pleased with his
• 0:22
  Speaker 1: JP Morgan accounts. JP Morgan allowed Epstein to engage in
• 0:26
  Speaker 1: structuring violations and other financial maneuvers and required to maintain
• 0:30
  Speaker 1: a criminal enterprise. The relationship continued without much of a
• 0:34
  Speaker 1: question from outsiders. JP Morgan financially benefited from allowing Epstein
• 0:39
  Speaker 1: to use his JP Morgan accounts to run his sex
• 0:42
  Speaker 1: trafficking venture. However, in 2006, Epstein's relationship with JP Morgan
• 0:47
  Speaker 1: hit a snag when Epstein was publicly exposed for sexually
• 0:50
  Speaker 1: abusing dozens of young girls and women, several as young
• 0:54
  Speaker 1: as 14 years old. There were hundreds of pages of
• 0:57
  Speaker 1: police reports and news articles revealing that Epstein was a
• 1:00
  Speaker 1: serial sexual abuser and trafficker, and that his operation depended
• 1:05
  Speaker 1: on his accessing nearly unlimited cash to use his payments
• 1:08
  Speaker 1: to his victims. With respect to those specific discoveries, the U.S.
• 1:13
  Speaker 1: Attorney's Office for the Southern District of Florida found that
• 1:16
  Speaker 1: some of the victims went to Mr. Epstein's house only once.
• 1:19
  Speaker 1: Some went there as much as 100 times or more.
• 1:23
  Speaker 1: It was publicly revealed in the investigation that Epstein was
• 1:26
  Speaker 1: sexually abusing three to four young females every single day
• 1:30
  Speaker 1: of his life and that he was paying each victim
• 1:32
  Speaker 1: hundreds of dollars in hush money, usually cash. The criminal
• 1:36
  Speaker 1: investigation also revealed that Epstein was paying countless recruiters to
• 1:40
  Speaker 1: constantly bring him more victims, making clear that quick access
• 1:44
  Speaker 1: to cash at a financial institution was the lifeblood for
• 1:47
  Speaker 1: his sex trafficking venture. The money trail into Epstein's accounts
• 1:51
  Speaker 1: was a dead giveaway that Epstein was engaging in crimes,
• 1:54
  Speaker 1: and the recipients of his money exposed the type of crimes.
• 1:58
  Speaker 1: To the extent that J.P. Morgan could feign plausible deniability
• 2:02
  Speaker 1: before Epstein's arrest in 2006, Thereafter, its ability to play
• 2:06
  Speaker 1: dumb was eviscerated when Epstein registered as a sex offender
• 2:10
  Speaker 1: and the details of his daily sexual abuse of young
• 2:12
  Speaker 1: females came to public light. Because Epstein was so publicly
• 2:16
  Speaker 1: exposed as a sex trafficker and abuser, one of his
• 2:19
  Speaker 1: primary financial engines, Les Wexner, abandoned him and separated himself
• 2:23
  Speaker 1: from Epstein. In 2008, around the same time that Epstein
• 2:27
  Speaker 1: was pleading guilty to felony sex offenses and registering as
• 2:30
  Speaker 1: a lifetime offender, it was discovered that another of JPMorgan's
• 2:34
  Speaker 1: high-value clients, Bernie Madoff, was running the largest Ponzi scheme
• 2:38
  Speaker 1: in modern history through his accounts at JPMorgan, causing JPMorgan
• 2:42
  Speaker 1: to review its clientele with a directive of severing ties
• 2:46
  Speaker 1: with any problematic customers. With this indisputable knowledge that Epstein
• 2:50
  Speaker 1: was a sexual offender who was using his wealth for
• 2:53
  Speaker 1: only one purpose, to run a sexual abuse and trafficking operation,
• 2:57
  Speaker 1: any responsible bank would have cut ties if only to
• 2:59
  Speaker 1: attempt to maintain the not-so-plausible deniability that it had not
• 3:04
  Speaker 1: known of Epstein's illegal sexual abuse operation earlier. However, rather
• 3:08
  Speaker 1: than cut its ties with Epstein, it's been reported that Staley,
• 3:12
  Speaker 1: acting on behalf of J.P. Morgan, personally visited Epstein when
• 3:15
  Speaker 1: he was serving his jail sentence in Florida. No matter
• 3:18
  Speaker 1: the cost, the bank made clear that Epstein could continue
• 3:22
  Speaker 1: to fund his sexual abuse operation through J.P. Morgan. When
• 3:26
  Speaker 1: executives on the board at J.P. Morgan recommended cutting ties
• 3:29
  Speaker 1: with Epstein, Staley made strong and successful arguments for J.P.
• 3:33
  Speaker 1: Morgan keeping Epstein as a customer. In support of J.P.
• 3:37
  Speaker 1: Morgan's CEO of private banking, Mary Erdos, argued that Epstein
• 3:41
  Speaker 1: was too valuable of a client to let go and
• 3:44
  Speaker 1: played a pivotal role in maintaining J.P. Morgan's relationship After
• 3:50
  Speaker 1: Staley went to visit Epstein in Florida while Epstein was
• 3:53
  Speaker 1: incarcerated on sex offenses, Epstein and Staley's relationship continued to grow. Ultimately,
• 3:58
  Speaker 1: after Epstein's release from jail, Staley and Epstein spent significant
• 4:03
  Speaker 1: time together at Epstein's townhouse in New York City. Staley
• 4:07
  Speaker 1: also visited Epstein on his private island in the United
• 4:10
  Speaker 1: States Virgin Islands, an island commonly dubbed Pedophile Island. After
• 4:15
  Speaker 1: his arrest in 2008, dozens of public lawsuits mounted against Epstein,
• 4:19
  Speaker 1: revealing greater details of Epstein's sexual abuse of young women,
• 4:23
  Speaker 1: each of which also detailed millions in payments that Epstein
• 4:26
  Speaker 1: was making to recruiters, co-conspirators, cover guys, such as his
• 4:31
  Speaker 1: longtime fixer lawyer and fixer accountant, and to his victims.
• 4:36
  Speaker 1: Through the civil lawsuits, evidence such as message pads taken
• 4:39
  Speaker 1: from Epstein's trash by police or through prior search warrants,
• 4:43
  Speaker 1: as well as flight logs, began to publicly surface, shedding
• 4:46
  Speaker 1: further public light on the expansiveness of Epstein's sex trafficking operation.
• 4:51
  Speaker 1: In addition to the inner workings of Epstein's sex trafficking
• 4:53
  Speaker 1: scheme becoming public when he was arrested and served his
• 4:57
  Speaker 1: jail time in Florida, other relevant information also became public
• 5:01
  Speaker 1: and was widely published. Epstein had no college degree, had
• 5:05
  Speaker 1: never obtained any specialized license, none of the companies with
• 5:09
  Speaker 1: whom he was associated had any legitimate business structure or purpose,
• 5:14
  Speaker 1: and he had no documented expertise that would provide the
• 5:17
  Speaker 1: requisite skill or knowledge to amass his vast wealth. Despite
• 5:23
  Speaker 1: the false rumors he had created to conceal his business,
• 5:26
  Speaker 1: Epstein was exposed as literally nothing more than a sex
• 5:29
  Speaker 1: trafficking abuser of young females, a fact easily discernible by
• 5:33
  Speaker 1: any responsible financial institution with whom he was banking. For J.P. Morgan,
• 5:39
  Speaker 1: a sophisticated financial institution legally responsible for complying with know-your-customer
• 5:44
  Speaker 1: laws and other banking obligations, the details of Epstein's sexual
• 5:49
  Speaker 1: abuse and trafficking were not a surprise. Even so, J.P.
• 5:53
  Speaker 1: Morgan never cooperated in any of the civil or criminal
• 5:57
  Speaker 1: complaints against Epstein because to do so would reveal J.P.
• 6:01
  Speaker 1: Morgan's complicity in Epstein's operation. Fearful that Epstein could turn
• 6:06
  Speaker 1: on the bank for its willful blindness, JPMorgan and Staley
• 6:09
  Speaker 1: remain incentivized to maintain and grow the relationship and to
• 6:13
  Speaker 1: assist in concealing Epstein's illegal and questionable banking practices. When
• 6:18
  Speaker 1: a subpoena was served on JPMorgan in 2009 by one
• 6:21
  Speaker 1: of Jeffrey Epstein's sexual abuse victims, JPMorgan refused to comply
• 6:25
  Speaker 1: with the subpoena, making it abundantly clear whose side JPMorgan
• 6:29
  Speaker 1: was on. After Epstein was released from his Florida incarceration,
• 6:34
  Speaker 1: he picked up right where he left off. abusing young
• 6:36
  Speaker 1: women on a daily basis, paying recruiters, and paying hush
• 6:39
  Speaker 1: money to victims. J.P. Morgan also picked up right where
• 6:44
  Speaker 1: it left off, protecting Epstein's operation and allowing it to
• 6:47
  Speaker 1: flourish once again. With the encouragement of state lead J.P. Morgan,
• 6:51
  Speaker 1: knowingly and intentionally participated in the Epstein sex trafficking venture by,
• 6:56
  Speaker 1: among other things, providing the financial underpinnings for Epstein to
• 7:00
  Speaker 1: have ready and reliable access to resources, including cash to recruit, lure, coerce,
• 7:06
  Speaker 1: and entice young women and girls to cause them to
• 7:09
  Speaker 1: engage in commercial sex acts and other degradations. J.P. Morgan
• 7:14
  Speaker 1: assisted and participated in Epstein's sex trafficking venture by knowingly
• 7:19
  Speaker 1: enabling him to make payments to victims, including directly or
• 7:23
  Speaker 1: indirectly Jane Doe 1 and others similarly situated, and obtain
• 7:28
  Speaker 1: large sums of cash from his various accounts in violation
• 7:31
  Speaker 1: of structuring laws. in order to finance his well-known cash-driven
• 7:35
  Speaker 1: sexual abuse and sex trafficking venture. J.P. Morgan participated in
• 7:40
  Speaker 1: Epstein's violations of the Trafficking Victims Protection Act by knowingly
• 7:45
  Speaker 1: and intentionally facilitating, assisting, and enabling Epstein's illegal sexual abuse
• 7:50
  Speaker 1: and sex trafficking venture, including, in particular, his coercive sex
• 7:54
  Speaker 1: trafficking in violation of U.S. Code 18, Section 1591A1. JP
• 8:01
  Speaker 1: Morgan's conduct knowingly and intentionally violated the TVPA, which forbids
• 8:05
  Speaker 1: benefiting financially by participating in a sex trafficking venture knowing
• 8:10
  Speaker 1: or in reckless disregard of the fact that means of force,
• 8:13
  Speaker 1: threats of force, fraud, coercion, abuse of process, and combination
• 8:17
  Speaker 1: of those means have been used to cause young women
• 8:20
  Speaker 1: and girls to engage in commercial sex acts. Ultimately, JP
• 8:25
  Speaker 1: Morgan financially benefited by earning millions of dollars, for its
• 8:29
  Speaker 1: participation in the Epstein sex trafficking venture. Throughout its relationship
• 8:33
  Speaker 1: with Epstein, JPMorgan violated numerous regulations in order to continue
• 8:38
  Speaker 1: its lucrative venture facilitating the Epstein sexual abuse and sex
• 8:42
  Speaker 1: trafficking scheme. It was later revealed that Staley and Epstein
• 8:46
  Speaker 1: exchanged more than 1,200 emails between 2008 and the end
• 8:51
  Speaker 1: of Staley's tenure at JPMorgan, which speaks volumes to the
• 8:54
  Speaker 1: close personal and business relationship that the two shared. Due
• 8:59
  Speaker 1: to the extensive publicity about Epstein's illegal sexual activity and
• 9:03
  Speaker 1: the departure of Staley from JP Morgan, the bank finally
• 9:06
  Speaker 1: severed ties with Epstein in 2013. After losing Staley, Epstein
• 9:11
  Speaker 1: no longer had his primary protector at JP Morgan. In
• 9:15
  Speaker 1: order to continue to operate, Epstein would need to find
• 9:18
  Speaker 1: a new bank. Fortunately for Epstein, former JP Morgan banker
• 9:22
  Speaker 1: Paul Morris joined Deutsche Bank in 2012. Soon after joining
• 9:27
  Speaker 1: Deutsche Bank, Morris suggested to senior management that Epstein was
• 9:31
  Speaker 1: a potential client who could generate millions of dollars of
• 9:34
  Speaker 1: revenue as well as leads for other lucrative clients for
• 9:38
  Speaker 1: the bank. Morris and Epstein began discussions in the spring
• 9:42
  Speaker 1: of 2013 about a potential relationship between the bank and Epstein.
• 9:47
  Speaker 1: Shortly thereafter, Morris onboarded Epstein's accounts to the bank and
• 9:52
  Speaker 1: instantly Epstein had a new bank willing to circumvent banking
• 9:55
  Speaker 1: laws to make profits from Epstein's widely known sex trafficking venture.
• 10:00
  Speaker 1: JP Morgan enabled Epstein to have ready and reliable access
• 10:03
  Speaker 1: to resources, including cash, to recruit, solicit, entice, harbor, obtain, provide,
• 10:09
  Speaker 1: and transport young women and girls, including the plaintiff bringing
• 10:12
  Speaker 1: this action, to cause them to engage in commercial sex
• 10:16
  Speaker 1: acts and to sexually abuse them. Deutsche Bank then took
• 10:19
  Speaker 1: over exactly where J.P. Morgan left off with a complete,
• 10:23
  Speaker 1: acquired knowledge of Epstein's history of sexual abuse and his
• 10:27
  Speaker 1: sex trafficking operation. Banking regulations exist to help prevent funding
• 10:32
  Speaker 1: of criminal ventures. The Federal Bank Secrecy Act requires financial
• 10:36
  Speaker 1: institutions to have adequate anti-money laundering policies and systems in place.
• 10:41
  Speaker 1: New York state law requires financial institutions to devise and
• 10:45
  Speaker 1: implement systems that reasonably designed to identify and report suspicious
• 10:49
  Speaker 1: activity and block transactions prohibited by law. All regulated institutions
• 10:54
  Speaker 1: are expected to configure systems based on their unique risk factors,
• 10:59
  Speaker 1: incorporating parameters such as institution size, presence, and high-risk jurisdictions,
• 11:04
  Speaker 1: and the specific lines of business involved, and the institutions
• 11:08
  Speaker 1: have an affirmative duty to ensure that their systems run effectively.
• 11:13
  Speaker 1: In addition to having effective AML controls in place, it's
• 11:16
  Speaker 1: also necessary for financial institutions to monitor their customers for
• 11:20
  Speaker 1: the purpose of preventing their customers from facilitating criminal activity
• 11:25
  Speaker 1: using the institution's facilities. As part of preventing criminal activity,
• 11:30
  Speaker 1: know your customer and customer due diligence are critically important,
• 11:34
  Speaker 1: and financial institutions must collect customer information at the time
• 11:38
  Speaker 1: of establishing new relationships with clients and including as necessary
• 11:42
  Speaker 1: to assess the risks associated to that client. To properly
• 11:46
  Speaker 1: consider these risks, financial institutions must consider relevant factors such
• 11:51
  Speaker 1: as the nature of the client's business, the purpose of
• 11:54
  Speaker 1: the client's accounts, and the nature and duration of the relationship.
• 11:59
  Speaker 1: Financial institutions must also conduct KYC reviews for each client
• 12:03
  Speaker 1: relationship at intervals of to the AML risk posed by
• 12:07
  Speaker 1: the client, including reviewing account activity, to determine whether such
• 12:11
  Speaker 1: activity fits with what would have been expected given the
• 12:14
  Speaker 1: nature of the account. Each client's AML risk should also
• 12:18
  Speaker 1: be reassessed if material new information or unexpected account activity
• 12:23
  Speaker 1: is discovered. Financial institutions must also establish criteria for determining
• 12:28
  Speaker 1: when a client relationship poses too high of a risk
• 12:31
  Speaker 1: and therefore must be terminated. A financial institution may be
• 12:35
  Speaker 1: liable under applicable laws if it maintains such a relationship
• 12:39
  Speaker 1: despite repeated indications of facilitation of improper transactions. All right, folks,
• 12:46
  Speaker 1: we're going to wrap up right here. And in the
• 12:47
  Speaker 1: next episode dealing with the topic, we're going to pick
• 12:49
  Speaker 1: up where we left off. All of the information that
• 12:52
  Speaker 1: goes with this episode can be found in the description box.
• 12:56
  Speaker 1: What's up, everyone? And welcome to another episode of the
• 12:59
  Speaker 1: Epstein Chronicles. In this episode, we're going to dive right
• 13:02
  Speaker 1: back in to the survivor's lawsuit filed against J.P. Morgan. J.P.
• 13:08
  Speaker 1: Morgan's Knowledge About the Epstein Venture J.P. Morgan failed in
• 13:12
  Speaker 1: various respects to meet its know-your-customer and other obligations fully
• 13:16
  Speaker 1: with respect to his relationship with Jeffrey Epstein and entities
• 13:20
  Speaker 1: related to Jeffrey Epstein. J.P. Morgan was aware that Epstein
• 13:24
  Speaker 1: was a wealthy man with hundreds of millions of dollars
• 13:26
  Speaker 1: in assets and an extensive network of friends and connections
• 13:30
  Speaker 1: that that included prominent financial institutions, politicians, royalty, and billionaires. J.P.
• 13:36
  Speaker 1: Morgan was aware that Epstein also had a well-publicized reputation
• 13:40
  Speaker 1: for sexually trafficking and abusing young women. Allegations against him
• 13:44
  Speaker 1: began appearing in the press as early as March of 2005,
• 13:48
  Speaker 1: with the accusation that he paid a 14-year-old girl for
• 13:51
  Speaker 1: a massage. That year, the Palm Beach, Florida Police Department
• 13:55
  Speaker 1: began an investigation into allegations against Epstein related to his
• 13:59
  Speaker 1: sexual abuse in Palm Beach. The investigation quickly uncovered dozens
• 14:04
  Speaker 1: of other Epstein sex abuse victims. The investigation also identified
• 14:08
  Speaker 1: the Epstein sex trafficking venture, which included a number of
• 14:12
  Speaker 1: individuals who were responsible for recruiting young women to come
• 14:15
  Speaker 1: to Epstein's Palm Beach mansion to give massages or otherwise
• 14:19
  Speaker 1: furthering his abuse. In 2006, the state attorney handling the case,
• 14:23
  Speaker 1: after meeting privately with an attorney representing Epstein, referred the
• 14:27
  Speaker 1: case to a state grand jury instead of charging Epstein
• 14:30
  Speaker 1: and his co-conspirators for crimes for which local police believe
• 14:34
  Speaker 1: there was an abundance of evidence. As a result, the
• 14:37
  Speaker 1: Palm Beach police chief publicly denounced the state attorney and
• 14:40
  Speaker 1: referred the case to the federal bureau, which subsequently opened
• 14:45
  Speaker 1: its own investigation and interviewed potential witnesses and victims. In
• 14:50
  Speaker 1: September 2007, Epstein agreed to plead guilty to two prostitution
• 14:54
  Speaker 1: charges in state court, including the solicitation of a minor
• 14:58
  Speaker 1: to engage in prostitution in exchange for a federal non-prosecution agreement,
• 15:03
  Speaker 1: providing him and co-conspirators, including Leslie Groff, Sarah Kellan, Adriana Ross,
• 15:08
  Speaker 1: and Nadia Marcinkova, with immunity from federal prosecution for extensive
• 15:13
  Speaker 1: federal sex trafficking charges in Florida. The deal included an
• 15:17
  Speaker 1: 18-month sentence and Epstein was also required to register as
• 15:21
  Speaker 1: a sex offender upon his release. Epstein ultimately served only
• 15:25
  Speaker 1: 13 months of his 18-month sentence in the Palm Beach
• 15:28
  Speaker 1: County Jail and was allowed work release privileges that enabled
• 15:32
  Speaker 1: him to leave jail six days a week for 12
• 15:34
  Speaker 1: hours a day. In the summer of 2008, Epstein's non-prosecution
• 15:39
  Speaker 1: agreement with the U.S. Department of Justice was made public
• 15:42
  Speaker 1: when it was unsealed in connection with a challenge to
• 15:45
  Speaker 1: the MPA by two of his victims. Among other things,
• 15:48
  Speaker 1: the agreement outlined the possible federal sex offense charges that
• 15:52
  Speaker 1: could have resulted from the investigation, including charges that Epstein
• 15:56
  Speaker 1: conspired to use a means of interstate commerce to induce
• 16:00
  Speaker 1: minors to engage in prostitution, to engage in illicit sexual
• 16:03
  Speaker 1: conduct with minors, conspiring with others to do the same,
• 16:07
  Speaker 1: and trafficking minors. That agreement also noted that the United
• 16:11
  Speaker 1: States had compiled a list of the individuals whom it
• 16:14
  Speaker 1: identified as victims, and that Epstein would pay for legal
• 16:18
  Speaker 1: representation for these alleged victims. Court proceedings involving the challenge
• 16:23
  Speaker 1: to Epstein's NPA continued between 2008 and 2013 and beyond,
• 16:28
  Speaker 1: and attracted significant media attention. Indeed, between 2005 and 2013,
• 16:34
  Speaker 1: press reports outlined the allegations underlining the NPA, and to
• 16:38
  Speaker 1: varying degrees detailed the involvement of Epstein's alleged co-conspirators, including
• 16:43
  Speaker 1: Leslie Groff, Sarah Kellan, and Nadia Marcinkova. Some articles reported
• 16:48
  Speaker 1: that Leslie Groff and Sarah Kellan had invoked their Fifth
• 16:51
  Speaker 1: Amendment right against self-incrimination, and others reported that Nadia Marcinkova
• 16:56
  Speaker 1: had allegedly recruited underage girls to give Epstein massages. Additionally,
• 17:01
  Speaker 1: press reports during the time noted allegations that Epstein was
• 17:04
  Speaker 1: involved with Eastern European women in particular, and that a
• 17:07
  Speaker 1: modeling agency he helped fund brought young girls, often from
• 17:11
  Speaker 1: Eastern Europe, to the U.S. on Epstein's private jets. At
• 17:15
  Speaker 1: all times material here too, J.P. Morgan was aware of
• 17:19
  Speaker 1: the foregoing information and more about Epstein's sex trafficking activities.
• 17:24
  Speaker 1: It is well known that J.P. Morgan did know that
• 17:27
  Speaker 1: a large number of cash transactions by a customer can
• 17:29
  Speaker 1: be an indicator of criminal activity generally, and sex trafficking
• 17:33
  Speaker 1: in particular. Payments to victims of sex trafficking are often
• 17:37
  Speaker 1: made in cash to avoid leaving a paper trail for
• 17:40
  Speaker 1: law enforcement or other investigators to follow. Forced sexual exploitation
• 17:45
  Speaker 1: of victims has been estimated to generate approximately $ 100 billion
• 17:50
  Speaker 1: in yearly illicit profits, according to a recent study. by
• 17:53
  Speaker 1: the Financial Action Task Force entitled Financial Flows from Human Trafficking.
• 17:59
  Speaker 1: Given the illegal nature of sex trafficking, individuals perpetrating the crime,
• 18:03
  Speaker 1: as well as laundering the proceeds of that crime, may
• 18:06
  Speaker 1: be identifiable by observing financial transactions and information obtained by
• 18:11
  Speaker 1: financial institutions in the course of conducting their customer due
• 18:15
  Speaker 1: diligence and the behavior of offenders. Sex trafficking organizations are
• 18:20
  Speaker 1: have the need for large amounts of cash because many
• 18:23
  Speaker 1: illegal transactions are often necessary to keep the organization functioning.
• 18:28
  Speaker 1: The technique that financial institutions use to detect other criminal
• 18:32
  Speaker 1: enterprises using their services can also be employed to detect
• 18:35
  Speaker 1: sex trafficking. For example, sex trafficking organizations often use assets
• 18:40
  Speaker 1: for money laundering, such as cash, real estate, cars, etc.,
• 18:44
  Speaker 1: that other sex trafficking organizations use. Sex trafficking organizations may
• 18:49
  Speaker 1: also make cash deposits and withdrawals below customer identification thresholds
• 18:54
  Speaker 1: to avoid triggering additional scrutiny or bank reporting requirements. Sex
• 18:59
  Speaker 1: trafficking organizations may also use multiple accounts to disguise the
• 19:03
  Speaker 1: nature of their illegal transactions, thereby laundering the funds involved.
• 19:08
  Speaker 1: One indicator of sex trafficking can be media coverage of
• 19:11
  Speaker 1: an account holder activities relating to sex trafficking. Another indicator
• 19:16
  Speaker 1: of sex trafficking can be recurring payments for transportation of
• 19:20
  Speaker 1: logistics service in the late night or early morning. A
• 19:24
  Speaker 1: similar indicator can be significant payments for transportation or logistics,
• 19:29
  Speaker 1: car rental, taxi, and ride-sharing service transactions. J.P. Morgan participated
• 19:34
  Speaker 1: in Epstein's violation of the TVPA by knowingly and intentionally assisting, supporting, facilitating,
• 19:40
  Speaker 1: and enabling Epstein's illegal conduct and sex trafficking venture, including,
• 19:45
  Speaker 1: in particular, his coercive sex trafficking in violation of U.S.
• 19:48
  Speaker 1: Code 18, Section 106. 1591, A and 1. J.P. Morgan's
• 19:53
  Speaker 1: conduct violated the TVPA, which forbids benefiting financially from participating
• 19:58
  Speaker 1: in a venture that, in or affecting interstate or foreign commerce,
• 20:02
  Speaker 1: has recruited, solicited, enticed, transported, harbored, provided, or obtained a
• 20:07
  Speaker 1: person knowing that or in reckless disregard of the fact
• 20:10
  Speaker 1: that the person has been caused to engage in a
• 20:13
  Speaker 1: commercial sex act by the means of force, threats of force, fraud, coercion, abuse,
• 20:18
  Speaker 1: of process, or a combination of such means. J.P. Morgan's
• 20:22
  Speaker 1: actions knowingly and intentionally furthered the Epstein sex trafficking venture,
• 20:26
  Speaker 1: including specifically Epstein sex trafficking. For example, J.P. Morgan provided
• 20:31
  Speaker 1: cash to Epstein knowing that he would use the cash
• 20:34
  Speaker 1: to pay for commercial sex acts, including sexualized massages, during
• 20:38
  Speaker 1: which Epstein penetrated Jane Doe One, forcing her to engage
• 20:42
  Speaker 1: in sexual activity. J.P. Morgan also aided and abetted Epstein's
• 20:46
  Speaker 1: sex trafficking venture by, among other things, providing the financial
• 20:50
  Speaker 1: underpinnings for the venture. J.P. Morgan enabled Epstein to have
• 20:54
  Speaker 1: ready and reliable access to resources, including cash and a
• 20:57
  Speaker 1: variety of bank accounts and other financial tools, to recruit, entice, solicit, harbor, provide, obtain,
• 21:05
  Speaker 1: and transport young women and girls to cause them to
• 21:07
  Speaker 1: engage in commercial sex acts. J.P. Morgan knowingly and intentionally
• 21:13
  Speaker 1: benefited financially and in other ways from its participation in
• 21:17
  Speaker 1: Epstein's sex trafficking venture, with knowledge or with reckless disregard
• 21:21
  Speaker 1: to the fact that Epstein used means of force, threats
• 21:24
  Speaker 1: of force, fraud, and coercion, and combinations thereof, to force
• 21:28
  Speaker 1: young women and girls to into engaging into commercial sex acts.
• 21:32
  Speaker 1: As recounted throughout this complaint, JPMorgan financially benefited by earning
• 21:36
  Speaker 1: millions of dollars from its participation in the Epstein sex
• 21:40
  Speaker 1: trafficking venture. The benefits that JPMorgan received came directly from
• 21:45
  Speaker 1: its participation in the sex trafficking venture and because of
• 21:48
  Speaker 1: its participation in that venture. In other words, there was
• 21:52
  Speaker 1: a casual relationship between JPMorgan's conduct furthering Epstein's sex trafficking
• 21:56
  Speaker 1: venture and its receipt of the financial benefits with actual
• 22:00
  Speaker 1: and constructive knowledge of that casual relationship. JP Morgan knowingly
• 22:06
  Speaker 1: and intentionally financed Epstein's illegal sex trafficking venture. JP Morgan
• 22:11
  Speaker 1: knew that if it did not finance Epstein's illegal sex
• 22:13
  Speaker 1: trafficking venture, then it would lose valuable Epstein-related accounts. Faced
• 22:18
  Speaker 1: with the choice between profiting from Epstein's sex trafficking venture
• 22:22
  Speaker 1: or following the law, JP Morgan chose to profit. In
• 22:25
  Speaker 1: violation of various banking laws and regulations, including various Know
• 22:29
  Speaker 1: Your Customer laws, J.P. Morgan regularly authorized cash withdrawals and
• 22:33
  Speaker 1: deposits for the Epstein sex trafficking venture, which allowed Epstein,
• 22:37
  Speaker 1: his co-conspirators, and those they directed to conduct the business
• 22:41
  Speaker 1: of the sex trafficking venture. J.P. Morgan's knowing and intentional
• 22:46
  Speaker 1: banking law violations allowed Epstein and his various corporations to
• 22:49
  Speaker 1: stay under the radar and continue the sex trafficking operation
• 22:53
  Speaker 1: without close scrutiny or or interference. JPMorgan knowingly and intentionally
• 22:58
  Speaker 1: benefited financially from Epstein's sex trafficking venture by facilitating and
• 23:03
  Speaker 1: financing Epstein's commercial sex acts in interstate and foreign commerce.
• 23:08
  Speaker 1: JPMorgan earned interest, commissions, service fees, and other financial benefits
• 23:12
  Speaker 1: directly from its connection with Epstein. Epstein-related entities and others
• 23:17
  Speaker 1: acting in concert with Epstein And Epstein provided those financial
• 23:22
  Speaker 1: benefits to JP Morgan precisely because it was facilitating his
• 23:26
  Speaker 1: sex trafficking venture. And JP Morgan knew that was the
• 23:29
  Speaker 1: reason that Epstein was providing them with those financial benefits.
• 23:34
  Speaker 1: JP Morgan benefited by receiving things of value from its
• 23:37
  Speaker 1: participation in the Epstein sex trafficking venture. Among the various
• 23:41
  Speaker 1: things of value it received were 1. Connections with Jeffrey Epstein,
• 23:45
  Speaker 1: his co-conspirators, and his wealthy friends and associates. 2. Additional
• 23:50
  Speaker 1: deposits from Epstein, his co-conspirators, and his wealthy friends and associates. 3.
• 23:55
  Speaker 1: The opportunity to earn financial benefits from the funds that
• 23:59
  Speaker 1: he had been deposited with J.P. Morgan. J.P. Morgan knowingly
• 24:03
  Speaker 1: and intentionally received these things of value as a direct
• 24:06
  Speaker 1: result of its participation in the Epstein sex trafficking venture,
• 24:10
  Speaker 1: and because it was furthering Epstein's sex trafficking venture. Among
• 24:14
  Speaker 1: the women and girls whose sex trafficking and sex abuses
• 24:17
  Speaker 1: JPMorgan furthered was Jane Doe One. Alright folks, we're going
• 24:21
  Speaker 1: to wrap up right here, and in the next episode
• 24:23
  Speaker 1: dealing with the topic, we're going to pick up where
• 24:25
  Speaker 1: we left off. All of the information that goes with
• 24:28
  Speaker 1: this episode can be found in the description box. What's
• 24:32
  Speaker 1: up everyone, and welcome to another episode of the Epstein Chronicles.
• 24:36
  Speaker 1: In this episode, we're going to pick up where we
• 24:37
  Speaker 1: left off with the survivor's lawsuit filed against J.P. Morgan.
• 24:43
  Speaker 1: Epstein uses J.P. Morgan accounts for the sex trafficking venture.
• 24:47
  Speaker 1: Over the course of the relationship, Epstein and his representatives
• 24:51
  Speaker 1: used J.P. Morgan accounts to send dozens of wires directly
• 24:54
  Speaker 1: and indirectly to co-conspirators in the sex trafficking venture. J.P.
• 24:59
  Speaker 1: Morgan was aware that the recipients of some of these
• 25:02
  Speaker 1: wire transfers described in the previous paragraph were to Epstein's
• 25:06
  Speaker 1: co-conspirators and that the wire transfers were in furtherance of
• 25:10
  Speaker 1: the Epstein sex trafficking venture. Epstein used J.P. Morgan accounts
• 25:14
  Speaker 1: to pay for Coors commercial sex by Jane Doe 1.
• 25:18
  Speaker 1: Given J.P. Morgan's knowledge about Epstein's past sex trafficking, its
• 25:21
  Speaker 1: continuation of its financial relationship with Epstein was, at a minimum,
• 25:26
  Speaker 1: in reckless disregard of the fact that Epstein was using
• 25:29
  Speaker 1: means of force, threats of force, fraud, coercion, and a
• 25:33
  Speaker 1: combination of such means to cause Epstein's victims to engage
• 25:36
  Speaker 1: in commercial sex acts. In addition to actual knowledge that
• 25:40
  Speaker 1: it was facilitating the Epstein sex trafficking venture, JPMorgan benefited
• 25:44
  Speaker 1: financially by participating in the venture that it should have
• 25:48
  Speaker 1: known had engaged in coercive sex trafficking in violation of U.S.
• 25:52
  Speaker 1: Code 18 Section 1591A. If a financial institution decides to
• 25:58
  Speaker 1: do business with a high-risk client, that institution is required
• 26:01
  Speaker 1: to conduct due diligence, commensurate with the risk, and to
• 26:05
  Speaker 1: tailor its transaction monitoring to detect suspicious or unlawful activity
• 26:09
  Speaker 1: based on what the risk is. J.P. Morgan, knowingly, intentionally, deliberately,
• 26:14
  Speaker 1: and maliciously, failed to do so with regard to its
• 26:17
  Speaker 1: relationship with Epstein. The bank was well aware not only
• 26:22
  Speaker 1: that Epstein had pled guilty and served prison time for
• 26:25
  Speaker 1: engaging in sex with a minor, but also that there
• 26:27
  Speaker 1: were public allegations that his conduct was facilitated by several
• 26:32
  Speaker 1: named co-conspirators. Despite this knowledge, the bank did little or
• 26:36
  Speaker 1: nothing to inquire into or block numerous payments to name
• 26:40
  Speaker 1: co-conspirators and to or on behalf of numerous young women
• 26:44
  Speaker 1: or to inquire how Epstein was using hundreds of thousands
• 26:47
  Speaker 1: of dollars in cash per year. Hush money, financial compensation
• 26:51
  Speaker 1: of recruiters, and compensation of victims was integral to Epstein's scheme.
• 26:56
  Speaker 1: without which his sex trafficking operation could not exist. The
• 27:00
  Speaker 1: ability to obtain exorbitant amounts of money and wires to
• 27:03
  Speaker 1: young females and obtain unlimited cash was critical to Epstein's operation.
• 27:08
  Speaker 1: Suspicious wire transfers and withdrawals of millions of dollars in
• 27:12
  Speaker 1: cash are basic hallmarks of any major criminal enterprise. A
• 27:16
  Speaker 1: bank that would allow Epstein to operate in this blatant
• 27:19
  Speaker 1: criminal fashion was necessary to for the growth of his
• 27:22
  Speaker 1: trafficking operation and for the continued abuse of hundreds of
• 27:26
  Speaker 1: young women. Before J.P. Morgan facilitated Epstein's operation without question,
• 27:32
  Speaker 1: Epstein was able to abuse young women sporadically and in
• 27:36
  Speaker 1: fear of being caught. J.P. Morgan eliminated that fear, making
• 27:40
  Speaker 1: sure that the suspicious money trail that would unveil Epstein's
• 27:44
  Speaker 1: operation as the criminal sexual abuse machine that it was
• 27:47
  Speaker 1: would be covered up and would lead to his downfall.
• 27:50
  Speaker 1: The negligence of J.P. Morgan is clear. The complicity, though,
• 27:53
  Speaker 1: far extended negligence as J.P. Morgan acted with a high
• 27:57
  Speaker 1: degree of moral turpitude and demonstrated such wanton dishonesty as
• 28:01
  Speaker 1: to imply a criminal indifference to civil obligations. And J.P.
• 28:05
  Speaker 1: Morgan also acted outrageously and intentionally. J.P. Morgan knew Epstein
• 28:11
  Speaker 1: had no college degree, no ongoing legitimate business, and was
• 28:15
  Speaker 1: engaging in sexual abuse of females on a daily basis.
• 28:19
  Speaker 1: JP Morgan recognized its importance to Epstein as the exclusive
• 28:23
  Speaker 1: financial institution that was willing to allow Epstein to engage
• 28:27
  Speaker 1: in obvious criminal financial activities to fund his sex trafficking venture.
• 28:32
  Speaker 1: JP Morgan, acting through Staley, was a criminal co-conspirator of
• 28:36
  Speaker 1: the operation. There came a time when JP Morgan absolutely
• 28:40
  Speaker 1: knew Epstein was running a sex trafficking venture, and JP
• 28:44
  Speaker 1: Morgan chose to remain Epstein's banking partner to receive financial
• 28:47
  Speaker 1: benefits in exchange for for ensuring the venture's continued operation.
• 28:52
  Speaker 1: In order to make hundreds of millions of dollars off
• 28:55
  Speaker 1: of Epstein and his contacts, J.P. Morgan facilitated Epstein's sex
• 28:59
  Speaker 1: trafficking network, which caused billions of dollars in damages from
• 29:03
  Speaker 1: the pain and suffering of hundreds of Epstein's sexual abuse
• 29:06
  Speaker 1: and sex trafficking victims. J.P. Morgan's desire to maintain its
• 29:11
  Speaker 1: profitable relationship with Epstein let it avoid taking steps that
• 29:15
  Speaker 1: would have documented its involvement in Epstein's sex trafficking venture.
• 29:20
  Speaker 1: The statute of limitations under the TVPA is 10 years
• 29:26
  Speaker 1: after the cause of action arose or 10 years after
• 29:29
  Speaker 1: the victim reaches 18 years of age, if the victim
• 29:32
  Speaker 1: was a minor at the time of the alleged offense.
• 29:35
  Speaker 1: The TVPA, causes of action for Jane Doe 1 and
• 29:38
  Speaker 1: other class members all arose within 10 years of the
• 29:42
  Speaker 1: filing of this complaint. The New York Adult Survivors Act
• 29:45
  Speaker 1: has opened up a one-year revival window for the statute
• 29:48
  Speaker 1: of limitations. Class Action Allegations Plaintiff Jane Doe 1 brings
• 29:54
  Speaker 1: this action pursuant to federal rule of Civil Procedure 23B3, 23C4,
• 30:00
  Speaker 1: on behalf of themselves and the following class, all women
• 30:03
  Speaker 1: who were sexually trafficked by Jeffrey Epstein, during the time
• 30:07
  Speaker 1: when J.P. Morgan maintained bank accounts for Epstein and or
• 30:10
  Speaker 1: Epstein-related entities, which was in or about 2000 through in
• 30:14
  Speaker 1: or about August of 2013, both dates inclusive the class period.
• 30:20
  Speaker 1: Plaintiff reserves the right to seek leave to modify the definition,
• 30:24
  Speaker 1: including the addition of one or more subclasses after having
• 30:27
  Speaker 1: the opportunity to conduct discovery. Numerosity. The class consists of
• 30:33
  Speaker 1: dozens of women, making joinder impracticable. In satisfaction of FedR
• 30:37
  Speaker 1: Civ P23A1, the exact size of the class and the
• 30:41
  Speaker 1: identities of the individual class members are ascertainable through records
• 30:46
  Speaker 1: maintained by the Epstein estate and the defendant, including but
• 30:49
  Speaker 1: not limited to J.P. Morgan's records for Epstein's related accounts,
• 30:53
  Speaker 1: account ledgers reflecting payments from Epstein to class members. Typicality.
• 30:59
  Speaker 1: Plaintiff's claims are typical of the claims of the other
• 31:01
  Speaker 1: class members she seeks to represent. The claims of plaintiff
• 31:05
  Speaker 1: and the other class members are based on the same
• 31:07
  Speaker 1: legal theories and arise from the same unlawful pattern and
• 31:10
  Speaker 1: practice of defendants' participation in and funding of the Epstein
• 31:15
  Speaker 1: sexual abuse and Epstein sex trafficking venture. Commonality There are
• 31:20
  Speaker 1: many questions of law and fact common to the claims
• 31:23
  Speaker 1: of plaintiff and the other class members, and those questions
• 31:26
  Speaker 1: predominate over any questions that That may affect only individual
• 31:30
  Speaker 1: class members within the meaning of FedR-CIVP. Class Treatment of
• 31:34
  Speaker 1: Common Issues under FedR-CIVP 23. Common questions of fact and
• 31:39
  Speaker 1: law affecting class members include, but are not limited to
• 31:42
  Speaker 1: the following. Whether the Epstein sex trafficking venture caused its
• 31:46
  Speaker 1: victim to engage in commercial sex acts in violation of
• 31:50
  Speaker 1: the Trafficking Victims Protection Act. Whether the Epstein sex trafficking
• 31:54
  Speaker 1: venture recruited, enticed, solicited, harbored, provided, obtained, and transported victims
• 31:59
  Speaker 1: in ways that were in or affecting interstate or foreign commerce.
• 32:04
  Speaker 1: Whether Epstein and his co-conspirators used means of force, fraud, coercion,
• 32:08
  Speaker 1: and abuse of legal process, or a combination of such means,
• 32:12
  Speaker 1: to sexually abuse the victims and to cause victims to
• 32:15
  Speaker 1: engage in commercial sex acts. Whether J.P. Morgan knowingly and
• 32:19
  Speaker 1: intentionally assisted, facilitated, and supported the the Epstein sex trafficking venture, pattern,
• 32:25
  Speaker 1: and practice of coercively forcing victims to engage in commercial
• 32:28
  Speaker 1: sex acts. Whether J.P. Morgan benefited financially or by receiving
• 32:33
  Speaker 1: things of value from its participation in a venture which
• 32:36
  Speaker 1: has engaged in sex trafficking in violation of TVPA. Whether J.P.
• 32:41
  Speaker 1: Morgan knew or should have known that Epstein's sex trafficking
• 32:44
  Speaker 1: venture had engaged in violations of the TVPA. whether J.P.
• 32:49
  Speaker 1: Morgan committed negligent acts or omissions that facilitated sexual abuse,
• 32:53
  Speaker 1: which would constitute a sexual offense as defined in Article
• 32:57
  Speaker 1: 130 of the penal law committed against such persons who
• 33:01
  Speaker 1: were 18 years of age or older. Absent a class action,
• 33:06
  Speaker 1: most of the class members would find the cost of
• 33:08
  Speaker 1: litigating their claims to be cost prohibitive and will have
• 33:11
  Speaker 1: no effective remedy. The class treatment of common questions of
• 33:15
  Speaker 1: law and fact is also superior to multiple individual actions
• 33:19
  Speaker 1: or piecemeal litigation in that it conserves the resources of
• 33:23
  Speaker 1: the courts and the litigants and promotes consistency and efficiency
• 33:27
  Speaker 1: of adjudication. Adequacy. Jane Doe 1 will fairly and adequately
• 33:33
  Speaker 1: represent and protect the interests of the other class member
• 33:36
  Speaker 1: she seeks to represent. Jane Doe 1 has retained counsel
• 33:39
  Speaker 1: with substantial experience in prosecuting complex litigation and class actions.
• 33:44
  Speaker 1: Plaintiff and her counsel are committed to vigorously prosecuting this
• 33:48
  Speaker 1: action on behalf of the other class members and have
• 33:51
  Speaker 1: the financial resources to do so. Neither plaintiff nor her
• 33:55
  Speaker 1: counsel have any interest adverse to those of the other
• 33:58
  Speaker 1: class members. This action has been brought and may properly
• 34:03
  Speaker 1: be maintained as a class action against the defendant pursuant
• 34:06
  Speaker 1: to Rule 23 of the Federal Rules of Civil Procedure,
• 34:10
  Speaker 1: because there is a well-defined community of interest in the litigation,
• 34:13
  Speaker 1: and the proposed class is easily ascertainable from defendant's records.
• 34:19
  Speaker 1: A class action is superior to all other available methods
• 34:22
  Speaker 1: for the fair adjudication of this controversy because a joinder
• 34:27
  Speaker 1: of the class members is impracticable. The prosecution of individual
• 34:31
  Speaker 1: remedies by members of the class will tend to establish
• 34:34
  Speaker 1: inconsistent standards of conduct for defendant and result in the
• 34:38
  Speaker 1: impairment of class members' rights and the disposition of their
• 34:41
  Speaker 1: interests through actions to which they are not parties. Class
• 34:45
  Speaker 1: action treatment will permit a large number of similarly situated
• 34:48
  Speaker 1: persons to prosecute their common claim in a single forum simultaneously, efficiently,
• 34:54
  Speaker 1: and without the unnecessary duplication of effort and expense that
• 34:58
  Speaker 1: numerous individual actions would engender. Absent a class action, Class
• 35:03
  Speaker 1: members will continue to suffer losses and be aggrieved, and
• 35:06
  Speaker 1: defendant will continue to violate New York and federal law
• 35:09
  Speaker 1: without remedy. Class treatment of this action will cause an
• 35:13
  Speaker 1: orderly and expeditious administration of class claims, economies of time, effort,
• 35:18
  Speaker 1: and expense will be fostered, and uniformity of decision will
• 35:22
  Speaker 1: be ensured. Plaintiff and her counsel are unaware of any
• 35:26
  Speaker 1: class action brought against any defendant for the violations alleged
• 35:29
  Speaker 1: in the action. The forum is desirable because defendant conducted
• 35:33
  Speaker 1: the subject business with Jeffrey Epstein in this district, and
• 35:37
  Speaker 1: class members were consequently trafficked in this district, and this
• 35:41
  Speaker 1: action presents no difficulty that would impede its management by
• 35:45
  Speaker 1: the court as a class action. All right, we're going
• 35:49
  Speaker 1: to wrap up right here, and in the next episode
• 35:51
  Speaker 1: dealing with the topic, we're going to pick up where
• 35:53
  Speaker 1: we left off. All of the information that goes with
• 35:55
  Speaker 1: this episode can be found in the description box. What's
• 35:59
  Speaker 1: up everyone and welcome to another episode of the Epstein Chronicles.
• 36:03
  Speaker 1: In this episode we're going to pick up where we
• 36:05
  Speaker 1: left off with the lawsuit filed by the survivors against J.P. Morgan.
• 36:11
  Speaker 1: Causes of action. Count one. Intentional and negligent acts and
• 36:15
  Speaker 1: omissions under the New York Adult Survivors Act, New York CPLR,
• 36:19
  Speaker 1: section 214J. Plaintiff Jangdo 1, re-alleges and incorporates by paragraphs
• 36:25
  Speaker 1: 1 through 236 as if fully set forth in this count.
• 36:29
  Speaker 1: Plaintiff Jane Doe 1 brings this count individually and on
• 36:32
  Speaker 1: behalf of the other class members they respectfully seek to represent.
• 36:36
  Speaker 1: Pursuant to New York civil practice law and rules section 214J,
• 36:41
  Speaker 1: this count for intentional and negligent acts and omissions has
• 36:45
  Speaker 1: been timely filed, as every civil claim or cause of
• 36:48
  Speaker 1: action brought against any party alleging intentional or and negligent
• 36:51
  Speaker 1: acts or omissions by a person for physical, psychological, or
• 36:55
  Speaker 1: other injury or condition suffered as a result of conduct
• 36:58
  Speaker 1: which would constitute a sexual offense as defined in Article
• 37:02
  Speaker 1: 130 of the Penal Law committed against such person who
• 37:06
  Speaker 1: was 18 years of age or older was revived effective
• 37:10
  Speaker 1: November 24, 2022. Intentional and negligent actions and omissions committed
• 37:16
  Speaker 1: by J.P. Morgan within this district and elsewhere directly and
• 37:19
  Speaker 1: proximately resulted in sexual offenses by Epstein and his co-conspirators
• 37:24
  Speaker 1: under the laws of the state of New York. As
• 37:27
  Speaker 1: a financial institution operating within this district and within the
• 37:30
  Speaker 1: state of New York, J.P. Morgan owed legal duties to
• 37:33
  Speaker 1: Plaintiff Jangdo 1 and the class members to exercise reasonable
• 37:37
  Speaker 1: care to monitor J.P. Morgan's customers, including Jeffrey Epstein, for
• 37:41
  Speaker 1: the purpose of preventing them from facilitating and engaging in
• 37:45
  Speaker 1: foreseeable criminal activity using banks' facilities that could harm the
• 37:49
  Speaker 1: plaintiff and the class members. The legal duties of J.P. Morgan,
• 37:53
  Speaker 1: described in the two preceding paragraphs, also extended to the
• 37:57
  Speaker 1: other class members whom Plaintiff Jane Doe I seeks to represent.
• 38:01
  Speaker 1: The legal duties of J.P. Morgan include, but are not
• 38:04
  Speaker 1: limited to, following the Know Your Customer laws and related
• 38:08
  Speaker 1: regulations described above. Under KYC laws, banks have special duties
• 38:13
  Speaker 1: to inquire about possible crimes being committed by their customers,
• 38:17
  Speaker 1: duties above and beyond any duties that the general public
• 38:20
  Speaker 1: may have. The inquiries that banks must make include duties
• 38:24
  Speaker 1: to inquire about specific individuals who are being harmed. The
• 38:28
  Speaker 1: regulations establish the duty of care that must be followed
• 38:31
  Speaker 1: by banks, including J.P. Morgan. But for J.P. Morgan, Epstein
• 38:36
  Speaker 1: could not have successfully run and expanded his sexual abuse organization,
• 38:41
  Speaker 1: While Wood have wanted to sexually abuse women, he could
• 38:44
  Speaker 1: not have abused hundreds of victims that he did without J.P. Morgan. J.P.
• 38:49
  Speaker 1: Morgan breached its legal duties to Plaintiff Jane Doe One
• 38:51
  Speaker 1: and the class members by failing to discharge its legal
• 38:54
  Speaker 1: duty to prevent Jeffrey Epstein and others from using the
• 38:58
  Speaker 1: bank's facilities to facilitate and commit criminal activity harming Jane
• 39:02
  Speaker 1: Doe One and the class members. The criminal activity that
• 39:06
  Speaker 1: harmed Plaintiff and class members included foreseeable federal crimes committed
• 39:10
  Speaker 1: by the Epstein sex trafficking enterprise described above, as well
• 39:14
  Speaker 1: as the state sex offense crimes. As a direct and
• 39:18
  Speaker 1: proximate result of the breach of legal duties by J.P. Morgan,
• 39:21
  Speaker 1: Plaintiff Jane Doe won, and the class members repeatedly suffered
• 39:25
  Speaker 1: foreseeable injuries from Epstein and his co-conspirators, including federal, and
• 39:30
  Speaker 1: state sexual offenses and resulting emotional distress, mental pain, and suffering,
• 39:35
  Speaker 1: and other physical, psychological, and other injuries. The breaches of
• 39:40
  Speaker 1: legal duty were the direct, i.e., the but-for-cause of these injuries.
• 39:45
  Speaker 1: Without J.P. Morgan's breaches of its legal duties, those injuries
• 39:49
  Speaker 1: would not have occurred. the breaches of legal duty were
• 39:52
  Speaker 1: the direct, i.e. but for cause of these injuries, without
• 39:57
  Speaker 1: defendant's breaches of legal duties, those injuries would not have occurred.
• 40:01
  Speaker 1: The injuries that occurred were readily foreseeable by J.P. Morgan.
• 40:06
  Speaker 1: The injuries that Plaintiff Jangdo won and the class members
• 40:09
  Speaker 1: suffered included injuries directly and proximately suffered while they were
• 40:13
  Speaker 1: adults who were present in this district. These injuries are
• 40:16
  Speaker 1: permanent in nature and Jangdo won and other class members
• 40:20
  Speaker 1: will continue to suffer these losses in the future. The
• 40:24
  Speaker 1: injuries that Plaintiff Jangdo won and the class members suffered
• 40:27
  Speaker 1: included injuries directly and proximately suffered as a result of
• 40:31
  Speaker 1: sex offenses committed by Epstein and other co-conspirators and criminalized
• 40:36
  Speaker 1: under Article 130. The offenses included sexual intercourse without consent
• 40:41
  Speaker 1: and oral sexual conduct without consent forbidden by New York
• 40:44
  Speaker 1: Penal Law Section 130.20. The offenses included forcible touching of sexual,
• 40:50
  Speaker 1: or other intimate parts without consent, forbidden by New York
• 40:53
  Speaker 1: Penal Law Section 130.20. The breaches of legal duties by J.P.
• 40:58
  Speaker 1: Morgan proximately caused Plaintiff Jang Do-won and the class members
• 41:03
  Speaker 1: to repeatedly suffer injuries from Epstein and his co-conspirators, including
• 41:07
  Speaker 1: sexual assaults and resulting emotional distress, mental pain and suffering,
• 41:12
  Speaker 1: and other physical and psychological trauma. These injuries were easily
• 41:16
  Speaker 1: foreseeable because J.P. Morgan knew and acted in reckless disregard
• 41:20
  Speaker 1: of the fact that their actions and omissions, supporting and
• 41:23
  Speaker 1: facilitating Epstein, would lead to, among other crimes, sex offenses
• 41:27
  Speaker 1: by Epstein and his co-conspirators forbidden by Article 130 of
• 41:31
  Speaker 1: the New York Penal Law against the victims, including Jang
• 41:34
  Speaker 1: Do-won and the class members. In the exercise of reasonable care, J.P.
• 41:39
  Speaker 1: Morgan and its employees knew, or should have known, of
• 41:42
  Speaker 1: the dangerous propensities of Jeffrey Epstein, and the harm that
• 41:45
  Speaker 1: would be caused by his likely sexual crimes and various
• 41:48
  Speaker 1: violations of Article 130 of the New York Penal Law. J.P.
• 41:53
  Speaker 1: Morgan could reasonably foresee that its actions and omissions in
• 41:56
  Speaker 1: facilitating Epstein's sex trafficking enterprise would lead to sex offenses
• 42:01
  Speaker 1: against Jane Doe 1 and the class members. Among other things,
• 42:04
  Speaker 1: the defendant was specifically aware that Epstein had previously been
• 42:08
  Speaker 1: prosecuted for similar sex crimes and previously paid numerous civil
• 42:13
  Speaker 1: settlements associated with with similar sex crimes. Indeed, the defendant
• 42:17
  Speaker 1: was aware, and should have been aware that Epstein was
• 42:20
  Speaker 1: a high risk to commit, sex offenses against young women
• 42:23
  Speaker 1: and girls. Plaintiff Jang Do-won and the class members were
• 42:27
  Speaker 1: easily within the zone of foreseeable harm from J.P. Morgan's
• 42:31
  Speaker 1: intentional and negligent acts and omissions. J.P. Morgan's intentional and
• 42:36
  Speaker 1: negligent acts and omissions foreseeably created substantial risk of Jeffrey
• 42:40
  Speaker 1: Epstein and his co-conspirators committing sex crimes against young women
• 42:44
  Speaker 1: with whom he was in contact. Tragically, Jane Doe 1
• 42:47
  Speaker 1: and the master class members fell within that zone. The
• 42:51
  Speaker 1: sex offenses Jeffrey Epstein committed against Jane Doe 1 and
• 42:54
  Speaker 1: the class members were easily within the zone of foreseeable
• 42:57
  Speaker 1: risk that J.P. Morgan created with its intentionally and negligent
• 43:01
  Speaker 1: actions and omissions. Those actions and omissions foreseeably risked further
• 43:06
  Speaker 1: sex crimes by Jeffrey Epstein and his co-conspirators, which is
• 43:10
  Speaker 1: exactly and tragically the harm that he inflicted on Jane
• 43:14
  Speaker 1: Doe 1 and the class members. While the foregoing allegations
• 43:18
  Speaker 1: easily made out a clear case of negligence, the case
• 43:21
  Speaker 1: does not involve mere negligence. Instead, defendants' torteous conduct in
• 43:26
  Speaker 1: this case evinced a high degree of moral turpitude and
• 43:29
  Speaker 1: demonstrated such wanton dishonesty. as to imply a criminal indifference
• 43:34
  Speaker 1: to civil obligation. It also involved outrageous and intentional acts
• 43:38
  Speaker 1: and omissions because it was a deliberate attempt to further
• 43:41
  Speaker 1: the crimes of a widespread and dangerous criminal sex trafficking organization.
• 43:46
  Speaker 1: Defendants' tortious conduct was directed specifically at Jane Doe 1
• 43:50
  Speaker 1: and the class members who were the victims of Epstein's
• 43:53
  Speaker 1: sexual abuse and sex trafficking organization. As a result of
• 43:57
  Speaker 1: the intentional and negligent actions and omissions described in this count,
• 44:01
  Speaker 1: Plaintiff Jane Doe 1 and the class members have sustained
• 44:05
  Speaker 1: both general and specified damages in substantial amounts, by virtue
• 44:09
  Speaker 1: of acting intentionally outrageously and with a high degree of
• 44:12
  Speaker 1: moral turpitude, and demonstrating such wanton dishonesty as to imply
• 44:17
  Speaker 1: a criminal indifference to civil obligation, defendant is liable to
• 44:20
  Speaker 1: Jane Doe 1 and other members of the class for
• 44:23
  Speaker 1: punitive damages. Count 2. Participating in a sex trafficking venture,
• 44:28
  Speaker 1: violation of the Trafficking Victims Protection Act. U.S. Code 18,
• 44:32
  Speaker 1: Section 1591A and 2, 1595. Plaintiff Jang Do-won re-alleges and
• 44:39
  Speaker 1: incorporates by reference paragraphs 1 through 236 as a fully
• 44:43
  Speaker 1: set forth in this count. Plaintiff Jang Do-won brings this
• 44:46
  Speaker 1: count individually and on behalf of the other class members
• 44:50
  Speaker 1: she seeks to represent. J.P. Morgan knowingly and intentionally participated in, assisted, supported,
• 44:56
  Speaker 1: and facilitated a sex trafficking venture that was in and
• 44:59
  Speaker 1: affecting interstate and foreign commerce. together with others, in violation
• 45:04
  Speaker 1: of U.S. Code 18, Section 1591A2. J.P. Morgan knowingly and
• 45:10
  Speaker 1: intentionally benefited financially from, and received value for, its participation
• 45:15
  Speaker 1: in the sex trafficking venture, in which Epstein, with J.P.
• 45:18
  Speaker 1: Morgan's knowledge, or a reckless disregard of the fact, that
• 45:21
  Speaker 1: Epstein would use means of force, threats of force, fraud, coercion,
• 45:25
  Speaker 1: and a combination of such means to sexually abuse Cheng Do-1,
• 45:29
  Speaker 1: as well as other class members and and cause Jane
• 45:31
  Speaker 1: Doe 1, as well as other class members, to engage
• 45:35
  Speaker 1: in commercial sex acts. Some of Epstein's victims were under
• 45:38
  Speaker 1: the age of 18. Among the financial benefits that J.P.
• 45:42
  Speaker 1: Morgan received for participating in and facilitating Epstein's sex trafficking
• 45:46
  Speaker 1: venture were the deposit of funds that Epstein and Epstein-controlled
• 45:50
  Speaker 1: entities made to J.P. Morgan. J.P. Morgan profited from the
• 45:54
  Speaker 1: use of these deposits. Epstein and Epstein-controlled entities deposited these
• 45:59
  Speaker 1: funds in exchange for J.P. Morgan's facilitation and participation in
• 46:04
  Speaker 1: the sex trafficking venture. Among the financial benefits that the
• 46:07
  Speaker 1: defendant received for participating in Epstein's sex trafficking venture was
• 46:11
  Speaker 1: referral of business opportunities from Epstein and his co-conspirators. J.P.
• 46:16
  Speaker 1: Morgan profited from these referred business opportunities. Epstein referred business
• 46:21
  Speaker 1: entities and business opportunities to J.P. Morgan in exchange for
• 46:25
  Speaker 1: its facilitation and participation in his sex trafficking venture. J.P.
• 46:30
  Speaker 1: Morgan knew and recklessly disregarded the fact that it was
• 46:33
  Speaker 1: Epstein's pattern and practice to use the channels and instrumentalities
• 46:37
  Speaker 1: of interstate and foreign commerce to entice, recruit, solicit, harbor, provide, obtain,
• 46:42
  Speaker 1: and transport young women and underage girls for the purpose
• 46:45
  Speaker 1: of causing commercial sex acts in violation of U.S. Code 18,
• 46:49
  Speaker 1: Section 1591. J.P. Morgan and its employees had actual knowledge
• 46:55
  Speaker 1: that they were facilitating Epstein's sexual abuse and sex trafficking
• 46:58
  Speaker 1: conspiracy to recruit, solicit, entice, coerce, harbor, transport, obtain, and
• 47:04
  Speaker 1: provide Jane Doe 1, as well as other members of
• 47:06
  Speaker 1: the class, into commercial sex acts through the means of force,
• 47:10
  Speaker 1: threats of force, fraud, abusive process, and coercion. Despite such knowledge, J.P.
• 47:16
  Speaker 1: Morgan intentionally paid for, facilitated, and participated in Epstein's violation
• 47:21
  Speaker 1: of U.S. Code 18, Section 1591A1 which defendant knew and
• 47:26
  Speaker 1: was in reckless disregard of the fact that Epstein would
• 47:29
  Speaker 1: coerce the fraud and force Jane Doe 1 as well
• 47:32
  Speaker 1: as other members of the class to engage in commercial
• 47:35
  Speaker 1: sex acts. All right, we're going to wrap up right here.
• 47:38
  Speaker 1: And in the next episode, we're going to pick up
• 47:41
  Speaker 1: where we left off. All of the information that goes
• 47:44
  Speaker 1: with this episode can be found in the description box.
• 47:47
  Speaker 1: What's up, everyone? And welcome to another episode of the
• 47:50
  Speaker 1: Epstein Chronicles. In this episode, we're going to get right
• 47:53
  Speaker 1: back to the survivor's lawsuit filed against J.P. Morgan. J.P. Morgan,
• 47:58
  Speaker 1: through its employees and agents, actively participated in the sex
• 48:02
  Speaker 1: trafficking conspiracy and led Jane Doe 1, as well as
• 48:05
  Speaker 1: other members of the class, to believe that they would
• 48:07
  Speaker 1: be rewarded if they cooperated and acquiesced to Epstein's demands. J.P.
• 48:12
  Speaker 1: Morgan's affirmative conduct was committed knowing, or in reckless disregard
• 48:16
  Speaker 1: of the facts, that Epstein would use cash and financial
• 48:19
  Speaker 1: support provided by J.P. Morgan as a means of defrauding, forcing,
• 48:23
  Speaker 1: and coercing sex acts from Jane Doe 1, as well
• 48:26
  Speaker 1: as other members of the class. Defendant's conduct was outrageous
• 48:30
  Speaker 1: and intentional. In addition to actual knowledge that they were
• 48:34
  Speaker 1: participating in and facilitating the Epstein sex trafficking venture, J.P.
• 48:38
  Speaker 1: Morgan also should have known that it was participating in
• 48:42
  Speaker 1: and facilitating a venture that had engaged in coercive sex
• 48:45
  Speaker 1: trafficking in violation of U.S. Code 18, Section 1591. In
• 48:50
  Speaker 1: exchange for facilitating and covering up Epstein's Commercial Sex Act, J.P.
• 48:54
  Speaker 1: Morgan's employees advanced their careers at J.P. Morgan and received
• 48:59
  Speaker 1: financial benefits from there. Facilitating and covering up Epstein's sexual
• 49:03
  Speaker 1: misconduct was a means of obtaining economic success and promotion
• 49:07
  Speaker 1: within the J.P. Morgan hierarchy. J.P. Morgan, knowing an intentional
• 49:13
  Speaker 1: conduct has caused Jane Doe 1 and the other members
• 49:17
  Speaker 1: of the class serious harm, including without limitation, physical, psychological, emotional, financial,
• 49:22
  Speaker 1: and reputational harm. J.P. Morgan's knowing and intentional conduct has
• 49:27
  Speaker 1: caused Jane Doe 1 and the other members of the
• 49:29
  Speaker 1: class harm that is sufficiently serious under all the surrounding
• 49:33
  Speaker 1: circumstances to compel a reasonable person of the same background
• 49:37
  Speaker 1: and in the same circumstance to perform or to continue
• 49:40
  Speaker 1: performing commercial sexual activity in order to avoid incurring that harm.
• 49:45
  Speaker 1: This case does not involve mere fraud. Instead, J.P. Morgan,
• 49:48
  Speaker 1: tortious conduct in violating the TVPA was outrageous and intentional
• 49:53
  Speaker 1: because it was a deliberate furtherance of a widespread and
• 49:56
  Speaker 1: dangerous criminal sex trafficking organization. J.P. Morgan's tortious conduct also
• 50:01
  Speaker 1: evinced a high degree of moral turpitude and demonstrated such
• 50:05
  Speaker 1: wanton dishonesty as to imply a criminal indifference to civil obligations. J.P.
• 50:10
  Speaker 1: Morgan's tortious conduct was directed specifically at Jane Doe 1
• 50:14
  Speaker 1: and other members of the class who were the victims
• 50:17
  Speaker 1: of Epstein's sexual abuse and sex trafficking organization. By virtue
• 50:21
  Speaker 1: of these violations, knowing an intentional violation of U.S. Code
• 50:25
  Speaker 1: 18 Section 1591-1595, J.P. Morgan is liable to Jane Doe
• 50:30
  Speaker 1: 1 and other members of the class for the damages
• 50:33
  Speaker 1: they sustained and reasonable attorney fees. By virtue of these
• 50:37
  Speaker 1: intentional and outrageous violations, U.S. Code 18, Section 1591A2-1595, J.P.
• 50:45
  Speaker 1: Morgan is liable to Jane Doe 1 and other members
• 50:48
  Speaker 1: of the class for punitive damages. Count number three. Conspiracy
• 50:52
  Speaker 1: to commit violations of the Sex Trafficking Victim Protection Act, U.S.
• 50:56
  Speaker 1: Code 18, Section 1594C and 1595. Plaintiff Jane Doe 1
• 51:03
  Speaker 1: re-alleges and incorporates by reference paragraphs 1 through 236 as
• 51:08
  Speaker 1: a fully set forth in this count. Plaintiff Jane Doe
• 51:11
  Speaker 1: 1 brings this count individually and on behalf of the
• 51:14
  Speaker 1: other class members she respectively seeks to represent. J.P. Morgan
• 51:19
  Speaker 1: intentionally conspired with others by agreement and understanding to violate U.S.
• 51:23
  Speaker 1: Code 18 Section 1591A and to further Epstein's sex trafficking
• 51:29
  Speaker 1: venture to coerce commercial sex acts from Jane Doe 1
• 51:32
  Speaker 1: and other class members, all in violation of U.S. Code
• 51:35
  Speaker 1: 18 Section 1594C. JPMorgan employees conspired with Epstein himself to
• 51:42
  Speaker 1: further the sex trafficking venture. JPMorgan conspired with Epstein and
• 51:47
  Speaker 1: his co-conspirators to further the Epstein sex trafficking venture with
• 51:51
  Speaker 1: the purpose of facilitating Epstein's illegal sex trafficking. JPMorgan intentionally
• 51:57
  Speaker 1: committed overt acts in furtherance of the conspiracy, agreement, and
• 52:01
  Speaker 1: understanding to violate U.S. Code 18, Section 1591 by knowingly
• 52:06
  Speaker 1: playing an active role in assisting, supporting, and facilitating the recruiting, enticing, coercing, harboring, transporting,
• 52:13
  Speaker 1: and inducing Jane Doe 1 and other class members to
• 52:16
  Speaker 1: engage in commercial sex acts through providing financial support for
• 52:20
  Speaker 1: the Epstein sex trafficking venture. Among the many overt acts
• 52:23
  Speaker 1: intentionally committed by J.P. Morgan in furtherance of the sex
• 52:27
  Speaker 1: trafficking venture were creating and maintaining a financial relationship between J.P.
• 52:32
  Speaker 1: Morgan and Epstein within the district. It was part of
• 52:36
  Speaker 1: the conspiracy that JPMorgan would financially benefit from providing financial
• 52:40
  Speaker 1: support for Epstein's sex trafficking venture. JPMorgan did financially benefit
• 52:46
  Speaker 1: from its participation in the venture, including receiving valuable deposits
• 52:50
  Speaker 1: from Epstein and Epstein-related entities into JPMorgan. JPMorgan's participation in
• 52:56
  Speaker 1: furthering Epstein's sex trafficking venture was intentional and willful, and
• 53:00
  Speaker 1: therefore JPMorgan intentionally and willfully caused Epstein's commission to of
• 53:05
  Speaker 1: the commercial sex acts with Jane Doe 1 and other
• 53:07
  Speaker 1: class members through its affirmative and overt acts supporting Epstein. J.P.
• 53:12
  Speaker 1: Morgan knew or acted in reckless disregard of the fact
• 53:16
  Speaker 1: that its acts and conduct supporting and facilitating Epstein would
• 53:19
  Speaker 1: lead to unlawful, coercive commercial sex acts by Epstein with
• 53:23
  Speaker 1: young women and girls, including Jane Doe 1 and other
• 53:26
  Speaker 1: class members. J.P. Morgan conspired with Epstein through their affirmative
• 53:31
  Speaker 1: acts and provided substantial support to Epstein committing commercial sex
• 53:35
  Speaker 1: acts upon Jane Doe 1 and other class members. In
• 53:40
  Speaker 1: addition to acting with knowledge that they were supporting the
• 53:43
  Speaker 1: Epstein sex trafficking venture, J.P. Morgan benefited financially from participating
• 53:48
  Speaker 1: in the Epstein sex trafficking venture, which J.P. Morgan should
• 53:51
  Speaker 1: have known that had engaged in coercive sex trafficking in
• 53:54
  Speaker 1: violation of U.S. Code 18, Section 1591a and 1. Defendant's
• 54:00
  Speaker 1: conduct has caused Jane Doe 1 and other class members
• 54:04
  Speaker 1: serious harm, including without limitation physical, psychological, financial, and reputational harm.
• 54:10
  Speaker 1: Defendant's conduct has caused Jane Doe 1 harm that is
• 54:13
  Speaker 1: sufficiently serious under all the surrounding circumstances to compel a
• 54:17
  Speaker 1: reasonable person of the same background and in the same
• 54:20
  Speaker 1: circumstance to perform or continue to performing commercial sex acts
• 54:24
  Speaker 1: in order to avoid incurring that harm. This case does
• 54:27
  Speaker 1: not involve mere fraud. Instead, defendants' tortious conduct in conspiring
• 54:31
  Speaker 1: to violate the TVPA was outrageous and intentional because it
• 54:36
  Speaker 1: was in deliberate furtherance of a widespread and dangerous criminal
• 54:39
  Speaker 1: sex trafficking organization. Defendants' tortious conspiracy also evinced a high
• 54:44
  Speaker 1: degree of moral turpitude and demonstrated such wanton dishonesty as
• 54:48
  Speaker 1: to imply criminal indifference to civil obligations. Defendants' tortious conspiracy
• 54:54
  Speaker 1: was directed specifically at Jane Doe 1 and other members
• 54:57
  Speaker 1: of the class who are the victims of Epstein's sex
• 55:00
  Speaker 1: trafficking organization. By virtue of these violations of U.S. Code 18,
• 55:05
  Speaker 1: Section 1594C, 1595, the defendant is liable to Jane Doe
• 55:11
  Speaker 1: 1 and the other members of the class for the
• 55:13
  Speaker 1: damages they sustained and reasonable attorney fees. By virtue of
• 55:18
  Speaker 1: its intentional and outrageous conspiracy to violate U.S. Code 18,
• 55:21
  Speaker 1: Section 1594C, and 1595, Defendant is liable to Jane Doe
• 55:26
  Speaker 1: 1 and other members of the class for punitive damages.
• 55:31
  Speaker 1: Count No. 4. Attempt to commit violations of the Trafficking
• 55:34
  Speaker 1: Victim Protection Act, U.S. Code 18, Section 1594A and 1595.
• 55:42
  Speaker 1: Plaintiff Jane Doe 1 re-alleges and incorporates by reference paragraphs
• 55:45
  Speaker 1: 1 through 236 as if fully set forth in this count.
• 55:51
  Speaker 1: Plaintiff Jane Doe One brings this count individually and on
• 55:53
  Speaker 1: behalf of the other class members she respectfully seeks to represent. J.P.
• 55:59
  Speaker 1: Morgan intentionally attempted to violate U.S. Code 18, Section 1591A1,
• 56:05
  Speaker 1: and to further Epstein's sex trafficking venture and to coerce
• 56:08
  Speaker 1: commercial sex acts from Jane Doe One and other class members,
• 56:12
  Speaker 1: all in violation of U.S. Code 18, Section 1594A. J.P.
• 56:17
  Speaker 1: Morgan employees deliberately took substantial steps to attempt to violate U.S.
• 56:21
  Speaker 1: Code 18 Section 1591 within the district. J.P. Morgan deliberately
• 56:28
  Speaker 1: took substantial steps toward attempting to violate U.S. Code 18
• 56:31
  Speaker 1: Section 1591, providing financial support for Epstein's sex trafficking venture.
• 56:37
  Speaker 1: Among the many substantial steps taken by J.P. Morgan to
• 56:40
  Speaker 1: deliberately attempt to violate U.S. Code 18 Section 1591A, were
• 56:45
  Speaker 1: creating a financial relationship between J.P. Morgan and Epstein within
• 56:49
  Speaker 1: the district. It was part of the attempt to violate U.S.
• 56:53
  Speaker 1: Code 18 Section 1591 that J.P. Morgan would financially benefit
• 56:58
  Speaker 1: from providing financial support for Epstein's sex trafficking venture. J.P.
• 57:02
  Speaker 1: Morgan did financially benefit from its participation in the venture,
• 57:07
  Speaker 1: including receiving valuable deposits from Epstein and Epstein-related entities into J.P.
• 57:12
  Speaker 1: Morgan's Defendant's attempt to violate the TVPA by furthering Epstein's
• 57:17
  Speaker 1: sex trafficking venture was intentional and willful, and therefore defendant
• 57:22
  Speaker 1: intentionally and willfully caused Epstein's commission of sexual abuse and
• 57:25
  Speaker 1: commercial sex acts with Jane Doe 1 and other class
• 57:28
  Speaker 1: members through its affirmative and overt acts supporting Epstein. Defendant
• 57:33
  Speaker 1: knew and acted in reckless disregard of the fact that
• 57:36
  Speaker 1: its acts and conduct supporting and facilitating Epstein would lead
• 57:40
  Speaker 1: to sexual abuse and and unlawful coercive commercial sex acts
• 57:43
  Speaker 1: by Epstein with young women and girls, including Jang Do-won
• 57:47
  Speaker 1: and other class members. In addition to acting intentionally and
• 57:51
  Speaker 1: with knowledge that they were supporting the Epstein sex trafficking venture,
• 57:55
  Speaker 1: defendant benefited financially from participating in Epstein's sex trafficking venture,
• 58:00
  Speaker 1: with defendant should have known, would engage in coercive sex
• 58:04
  Speaker 1: trafficking in violation of U.S. Code 18 Section 1591A1. This
• 58:10
  Speaker 1: case does not involve mere fraud. Instead, defendants' torteous conduct
• 58:14
  Speaker 1: in attempting to violate the TVPA was outrageous and intentional
• 58:18
  Speaker 1: because it was a deliberate attempt to further the crimes
• 58:20
  Speaker 1: of a widespread and dangerous criminal sex trafficking organization. Defendants'
• 58:25
  Speaker 1: torteous attempts also evinced a high degree of moral turpitude
• 58:29
  Speaker 1: and demonstrated such wanton dishonesty as to imply a criminal
• 58:32
  Speaker 1: indifference to civil obligations. Defendant's tortious attempt was directed specifically
• 58:38
  Speaker 1: at Jane Doe 1 and other members of the class
• 58:41
  Speaker 1: who were the victims of Epstein's sex trafficking organization. Defendant's
• 58:45
  Speaker 1: conduct has caused Jane Doe 1 and other class members
• 58:48
  Speaker 1: serious harm, including without limitation, physical, psychological, financial, and reputational harm.
• 58:55
  Speaker 1: By virtue of these violations of U.S. Code 18, Section 1594A, 1595A,
• 58:58
  Speaker 1: defendant is liable to Jane Doe 1 and other members
• 59:04
  Speaker 1: of the class for the damages they sustained and reasonable
• 59:07
  Speaker 1: attorney fees. By virtue of this intentional and outrageous attempt
• 59:12
  Speaker 1: to violate U.S. Code 18, Section 1594A, 1595, defendant is
• 59:17
  Speaker 1: liable to Jane Doe 1 and other members of the
• 59:20
  Speaker 1: class for punitive damages. The Request for Relief Jane Doe
• 59:25
  Speaker 1: 1 respectfully requests that the court... enter judgment in her
• 59:28
  Speaker 1: favor and against J.P. Morgan as follows. That the court
• 59:32
  Speaker 1: certify the class named James Doe 1 as class representative
• 59:36
  Speaker 1: and appoint her lawyers as class counsel. B. That the
• 59:39
  Speaker 1: court award plaintiff and other members of the class compensatory, consequential, general, nominal,
• 59:45
  Speaker 1: and punitive damages against defendant in an amount to be
• 59:49
  Speaker 1: determined at trial. That the court award punitive and exemplary
• 59:52
  Speaker 1: damages against defendant in an amount to be determined at trial.
• 59:56
  Speaker 1: that the court award to a plaintiff the costs and
• 59:59
  Speaker 1: disbursements of the action, along with reasonable attorney fees, costs,
• 1:00:03
  Speaker 1: and expenses, that the court award pre- and post-judgment interest
• 1:00:07
  Speaker 1: at the maximum legal rate, and F, that the court
• 1:00:10
  Speaker 1: grant all such other and further relief as it deems
• 1:00:13
  Speaker 1: just and proper. Plaintiffs demand a trial by jury on
• 1:00:18
  Speaker 1: all claims that are triable. Dated November 24, 2022, and
• 1:00:21
  Speaker 1: it was signed by Bradley Edwards. Alright folks, so that's
• 1:00:27
  Speaker 1: the end of the lawsuit that was filed by the
• 1:00:29
  Speaker 1: survivors against J.P. Morgan. Now the next set of court
• 1:00:33
  Speaker 1: documents we're going to dive into are the court records
• 1:00:36
  Speaker 1: from the lawsuit filed by Virginia Roberts against the Joe
• 1:00:40
  Speaker 1: Exotic of the Windsor family. All of the information that
• 1:00:44
  Speaker 1: goes with this episode can be found in the description box.