Latest / Beyond The Horizon / Mega Edition: The Epstein Survivors Class Action Suit Filed Against JP Morgan (Part 1-4) (10/31/26)

Transcript

Mega Edition: The Epstein Survivors Class Action Suit Filed Against JP Morgan (Part 1-4) (10/31/26) · 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 going to begin taking
• 0:06
  Speaker 1: a look at the lawsuit that was filed by the
• 0:09
  Speaker 1: Epstein survivors against J.P. Morgan. And this is a pretty
• 0:13
  Speaker 1: massive lawsuit, so it runs 75 pages. So in this episode,
• 0:17
  Speaker 1: we're going to begin eating the elephant one bite at
• 0:20
  Speaker 1: a time. Case number 122-CV-10019-JSR. Jane Doe 1, individually, and
• 0:32
  Speaker 1: on behalf of all others, similarly situated, vs. JPMorgan Chase
• 0:37
  Speaker 1: and Company. Class Action Complaint Individual and Class Action Complaint
• 0:43
  Speaker 1: Plaintiff Jane Doe 1 files this individual and civil class
• 0:46
  Speaker 1: action complaint for damages and other relief under, among other
• 0:50
  Speaker 1: provisions of law, the U.S. Federal Anti-Sex Trafficking Statute, U.S.
• 0:54
  Speaker 1: Code 18, Section 1591-95, the Trafficking Victims Protection Act, TVPA,
• 1:01
  Speaker 1: and four intentional and negligent acts as omissions under the
• 1:05
  Speaker 1: New York Adult Survivors Act. The suit arises from defendant
• 1:09
  Speaker 1: JPMorgan Chase and company, hereinafter JPMorgan, financially benefiting from participating
• 1:15
  Speaker 1: in Jeffrey Epstein's sex trafficking by providing the requisite financial
• 1:19
  Speaker 1: support for the continued operation of Epstein's international sex trafficking
• 1:23
  Speaker 1: organization from 1998 through August of 2013. J.P. Morgan, knowingly
• 1:30
  Speaker 1: and intentionally, benefited and received things of value for assisting, supporting, facilitating,
• 1:35
  Speaker 1: and otherwise providing the most critical service for the Jeffrey
• 1:39
  Speaker 1: Epstein sex trafficking organization to successfully rape, sexually assault, and
• 1:44
  Speaker 1: coercively sex traffic Plaintiff Jane Doe 1 and the numerous
• 1:47
  Speaker 1: other members of the class proposed below. J.P. Morgan knew
• 1:51
  Speaker 1: that Epstein was regularly committing violations of New York Penal
• 1:55
  Speaker 1: Law Article 130, including and especially New York Penal Law
• 1:59
  Speaker 1: Section 130.20, 130.35, 130.50, 130.52, and 130.66, and acted in
• 2:09
  Speaker 1: a negligent manner so as to enable Epstein to commit
• 2:12
  Speaker 1: such offenses against countless young women. J.P. Morgan also knew
• 2:18
  Speaker 1: that Epstein would use means of force, threats of force, fraud,
• 2:21
  Speaker 1: abuse of legal process, exploitation of power disparity, and a
• 2:25
  Speaker 1: variety of other forms of coercion to cause young women
• 2:29
  Speaker 1: and girls to engage in commercial sex acts. Knowing that
• 2:32
  Speaker 1: they would earn millions of dollars from facilitating Epstein's sex
• 2:35
  Speaker 1: abuse and trafficking, J.P. Morgan chose profits over following the law. Specifically, J.P.
• 2:41
  Speaker 1: Morgan chose facilitating the sexual abuse and sex trafficking operation
• 2:46
  Speaker 1: for many years, including through the criminal investigation and incarceration
• 2:51
  Speaker 1: of Jeffrey Epstein, in order to turn profits. plaintiff makes
• 2:55
  Speaker 1: the following allegations on information and belief and believes that
• 2:59
  Speaker 1: substantial additional evidentiary support will exist for the allegations set
• 3:04
  Speaker 1: forth herein after a reasonable opportunity for discovery. 1. Jurisdiction, Venue,
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  Speaker 1: and Timelines This action is brought pursuant to various federal
• 3:14
  Speaker 1: and state statutes, including the Federal TVPA, U.S. Code 18,
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  Speaker 1: Section 1589, through Section 1595. The court has federal question
• 3:25
  Speaker 1: subject matter jurisdiction pursuant to U.S. Code 28 Section 1331
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  Speaker 1: because Jane Doe 1, individually and on behalf of the
• 3:33
  Speaker 1: other class members, proceeds under the federal TVPA statute. This
• 3:38
  Speaker 1: court also has supplemental jurisdiction over the state law claims
• 3:42
  Speaker 1: recounted below pursuant to U.S. Code 28 Section 1367A because
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  Speaker 1: all claims alleged herein are part of a uniform pattern
• 3:50
  Speaker 1: and practice and form part of the same case and controversy.
• 3:55
  Speaker 1: This court is an appropriate district court of the United
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  Speaker 1: States in accordance with U.S. Code 18, Section 1595, in
• 4:02
  Speaker 1: which to bring this action, venue is proper in this
• 4:05
  Speaker 1: district under U.S. Code 28, Section 1391B2, because Epstein and
• 4:10
  Speaker 1: his co-conspirators and J.P. Morgan all conducted substantial activities in
• 4:15
  Speaker 1: this district and knowingly aided and abetted, facilitated, and directly
• 4:19
  Speaker 1: participated in Epstein's illegal venture through actions that originated in
• 4:24
  Speaker 1: this district. In addition, Epstein sexually abused and trafficked Jane
• 4:28
  Speaker 1: Doe and members of the class in this district. Often
• 4:32
  Speaker 1: these acts of sexual abuse and commercial sex acts committed
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  Speaker 1: by Jeffrey Epstein and certain select friends of his took
• 4:39
  Speaker 1: place in Jeffrey Epstein's New York mansion located within the
• 4:42
  Speaker 1: district at 9 East 71st Street in New York City.
• 4:47
  Speaker 1: Epstein also used his New York mansion to harbor his
• 4:50
  Speaker 1: victims as a base from which to transport them to
• 4:53
  Speaker 1: other locations outside of New York. A substantial part of
• 4:57
  Speaker 1: the acts, events, and omissions giving rise to the cause
• 5:00
  Speaker 1: of action occurred in this district. This action has been
• 5:05
  Speaker 1: timely filed pursuant to U.S. Code 18, Section 1595C1, which
• 5:10
  Speaker 1: provides that the plaintiff shall have ten years after the
• 5:13
  Speaker 1: cause of action arose to file suit against any person
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  Speaker 1: who knowingly benefits financially or by receiving anything of value
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  Speaker 1: from participation in a venture which that person knew or
• 5:24
  Speaker 1: should have known violated laws against sex trafficking. Two parties.
• 5:31
  Speaker 1: Jang Do is a U.S. citizen and was at all
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  Speaker 1: relevant times a resident and domiciled in the state of
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  Speaker 1: New York. Plaintiff Jang Do Won is using a pseudonym
• 5:40
  Speaker 1: to protect her identity because of the sensitive and highly
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  Speaker 1: personal nature of this matter, which involves sexual assault. Jane
• 5:47
  Speaker 1: Doe One is also at serious risk of retaliatory harm
• 5:51
  Speaker 1: because the co-conspirators who participated in the Epstein sex trafficking
• 5:55
  Speaker 1: venture had and continue to possess tremendous wealth and power
• 6:00
  Speaker 1: and have demonstrated a clear ability to cause her serious harm.
• 6:04
  Speaker 1: Jane Doe One's safety, right to privacy, and security outweigh
• 6:07
  Speaker 1: the public interest in her identification. Jane Doe One's legitimate
• 6:12
  Speaker 1: concerns outweigh any prejudice to defendant by allowing her to
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  Speaker 1: proceed anonymously Accordingly, Jane Doe will be filing a motion
• 6:19
  Speaker 1: to proceed anonymously. As discussed below, many of the women
• 6:24
  Speaker 1: are similarly situated to Jane Doe 1 and also need
• 6:27
  Speaker 1: to proceed anonymously for the same reasons. The identities of
• 6:31
  Speaker 1: most of these other women are known to the defendant.
• 6:34
  Speaker 1: Defendant JP Morgan is a global financial institution headquartered in
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  Speaker 1: New York, New York. Defendant JP Morgan is licensed by
• 6:43
  Speaker 1: the New York State Department of Financial Services and to
• 6:46
  Speaker 1: operate a foreign bank branch in the state of New York.
• 6:49
  Speaker 1: Defendant J.P. Morgan currently conducts substantial business in this district
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  Speaker 1: and conducted substantial business at the time of the events
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  Speaker 1: covered in the complaint. As one example of business conducted
• 7:01
  Speaker 1: in this district, J.P. Morgan ordinarily shares trade on the
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  Speaker 1: New York Stock Exchange, located in this district. As another example, J.P.
• 7:10
  Speaker 1: Morgan maintains branch banks within the district. J.P. Morgan's financial activity,
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  Speaker 1: including the events alleged herein, were in and affecting interest
• 7:20
  Speaker 1: and foreign commerce, in connection with the acts alleged in
• 7:23
  Speaker 1: the complaint, defendant directly or indirectly, use the means and
• 7:27
  Speaker 1: instrumentalities of interstate commerce, including, but not limited to, the mails,
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  Speaker 1: interstate telephone communications, and the facilities of national securities markets. J.P.
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  Speaker 1: Morgan is responsible under the United States law and otherwise.
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  Speaker 1: for the acts of its officers, directors, employees, and agents,
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  Speaker 1: including the acts described in the complaint. Introduction Jeffrey Epstein's
• 7:52
  Speaker 1: sex trafficking venture operated, in many respects, as a sex-themed
• 7:56
  Speaker 1: cult designed to ensnare vulnerable young women and indoctrinate them
• 8:01
  Speaker 1: into Epstein's carefully constructed world in which Epstein was their messiah.
• 8:06
  Speaker 1: Epstein and his co-conspirators preached the gospel of Epstein, Epstein's
• 8:10
  Speaker 1: victims were taught to do what he said, and he
• 8:13
  Speaker 1: would protect them, but disobey them, and he would punish them,
• 8:17
  Speaker 1: and continue to disobey, and he would cause them serious harm,
• 8:20
  Speaker 1: from which they could never recover. Once in Epstein's clutches,
• 8:24
  Speaker 1: each victim was taught and understood that she must be
• 8:27
  Speaker 1: completely compliant with every wish or demand that Epstein had
• 8:31
  Speaker 1: for her. Otherwise, she would certainly suffer serious reputational, financial,
• 8:36
  Speaker 1: and psychological harm. By using these and other means of force,
• 8:41
  Speaker 1: threats of force, fraud, threats of abuse, of the legal
• 8:44
  Speaker 1: process and coercion, Epstein and his co-conspirators sexually trafficked and
• 8:49
  Speaker 1: sexually abused Plaintiff Jane Doe One and other members of
• 8:52
  Speaker 1: the class. The Epstein sex trafficking venture originated in the
• 8:56
  Speaker 1: early 90s and from its inception until Jeffrey Epstein's arrest
• 9:00
  Speaker 1: by the FBI for sex trafficking in 2019 and his
• 9:04
  Speaker 1: subsequent death on August 10th, 2019 by apparent suicide. The
• 9:09
  Speaker 1: venture operated primarily for the purpose of luring young women
• 9:12
  Speaker 1: and girls into a position where Jeffrey Epstein and his
• 9:16
  Speaker 1: co-conspirators could coerce them to engage in commercial sex acts
• 9:20
  Speaker 1: and commit sexual offenses against them. His venture also operated
• 9:25
  Speaker 1: to conceal its sex trafficking from law enforcement organizations. The
• 9:30
  Speaker 1: Epstein sex trafficking venture was well-structured from the beginning and
• 9:34
  Speaker 1: grew increasingly more complex and powerful as it victimized more
• 9:38
  Speaker 1: young women and And as its relationship with defendant J.P.
• 9:41
  Speaker 1: Morgan grew, Epstein did not act alone. He created and
• 9:46
  Speaker 1: maintained a sex trafficking venture with the assistance of other
• 9:49
  Speaker 1: influential individuals and entities who knew he was sexually abusing
• 9:54
  Speaker 1: and sexually trafficking young women and girls and provided support
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  Speaker 1: to facilitate his sexual abuse and sexual abuse. trafficking operation.
• 10:01
  Speaker 1: Epstein's sex trafficking venture was not possible without the assistance
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  Speaker 1: and complicity of a financial institution, specifically banking institution, which
• 10:11
  Speaker 1: provided special treatment to the sex trafficking venture, thereby ensuring
• 10:15
  Speaker 1: its continued operation and and sexual abuse and sex trafficking
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  Speaker 1: of young women and girls. Without the financial institution's participation,
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  Speaker 1: Epstein's sex trafficking scheme could not have existed. Epstein's victims
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  Speaker 1: were young women and girls who suffered severe abuse as
• 10:33
  Speaker 1: Epstein's sex trafficking victims and who believed that they had
• 10:36
  Speaker 1: to remain loyal to the venture at all costs in
• 10:39
  Speaker 1: order to survive. Epstein victimized hundreds of young women and girls.
• 10:44
  Speaker 1: Epstein's sexual abuse and sex trafficking scheme was supported by
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  Speaker 1: virtually unlimited wealth derived from select, wealthy individuals who acted
• 10:52
  Speaker 1: as the financial engine behind the sex trafficking operation. Epstein
• 10:56
  Speaker 1: masterfully assessed the specific needs and vulnerability of each of
• 11:00
  Speaker 1: his targeted victims. He then closed the trap on his
• 11:03
  Speaker 1: victims with offers of money, food, shelter, medical care for
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  Speaker 1: them or family members, travel, schooling, and career opportunities. Epstein
• 11:12
  Speaker 1: groomed the young women and girls, indoctrinating them to believe
• 11:16
  Speaker 1: that the sexual abuse was normal. Epstein fraudulently represented to
• 11:21
  Speaker 1: the victims that he would take care of them in
• 11:22
  Speaker 1: various ways, which ultimately allowed Epstein to cause them to
• 11:26
  Speaker 1: engage in commercial sex acts with himself and on occasion others,
• 11:31
  Speaker 1: as well as to create the opportunity for Epstein to
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  Speaker 1: sexually abuse them. The Epstein sex trafficking venture's purpose, including enticing, obtaining, harboring,
• 11:40
  Speaker 1: and transporting the young victims without drawing unwanted attention from
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  Speaker 1: law enforcement. The venture had everything a sex trafficking organization needed, funding, infrastructure,
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  Speaker 1: the appearance of legitimacy, and a complicit banking institution. It
• 11:55
  Speaker 1: was by many accounts the most powerful and wealthiest sex
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  Speaker 1: trafficking venture ever created. All right, folks, we're going to
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  Speaker 1: wrap up right here. And in the next episode, we're
• 12:05
  Speaker 1: going to pick up where we left off. All of
• 12:07
  Speaker 1: the information that goes with this episode can be found
• 12:10
  Speaker 1: in the description box. What's up, everyone? And welcome to
• 12:13
  Speaker 1: another episode of the Epstein Chronicles. In this episode, we're
• 12:17
  Speaker 1: going to pick up where we left off with the
• 12:19
  Speaker 1: lawsuit filed by the Epstein survivors against JP Morgan. The
• 12:26
  Speaker 1: Epstein sex trafficking venture knowingly used means of force, threats
• 12:30
  Speaker 1: of force, fraud, coercion, including threats of serious harm or
• 12:33
  Speaker 1: physical restraint, and abuse of law and the legal process
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  Speaker 1: to cause Jane Doe 1 and many dozens of other
• 12:40
  Speaker 1: similarly situated women to engage in commercial sex acts. The
• 12:45
  Speaker 1: Epstein sex trafficking venture operated in and affected interstate and
• 12:49
  Speaker 1: foreign commerce. Epstein recruited, solicited, coerced, harbored, transported, and enticed
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  Speaker 1: some of his victims, including Jane Doe 1 and others
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  Speaker 1: similarly situated, to engage in commercial sex acts in among
• 13:02
  Speaker 1: other places, New York, including the Southern District of New York, Florida,
• 13:07
  Speaker 1: the U.S. Virgin Islands, New Mexico, England, and France. The
• 13:11
  Speaker 1: Epstein sex trafficking venture operated throughout the world from in
• 13:16
  Speaker 1: and around the early 90s through in and around August 10th, 2019,
• 13:19
  Speaker 1: when Epstein died of an apparent suicide. Thereafter, too, and
• 13:25
  Speaker 1: including the date of this complaint, members of the sex
• 13:28
  Speaker 1: trafficking venture continued to further the venture by concealing the
• 13:32
  Speaker 1: activities and the extent of the venture. The manner of
• 13:36
  Speaker 1: operation of For Epstein's particular sexual abuse and sex trafficking
• 13:40
  Speaker 1: operation was widely publicized. He would lure young girls or
• 13:44
  Speaker 1: women to one of his luxurious mansions under the guise
• 13:47
  Speaker 1: of being a wealthy philanthropist, able to advance careers, education,
• 13:52
  Speaker 1: or provide other life necessities, and once inside, he would
• 13:56
  Speaker 1: force his would-be victim into providing a massage that would
• 14:00
  Speaker 1: turn sexual. And from there, he would cause each of
• 14:03
  Speaker 1: the unsuspecting victims to engage in a variety of commercial
• 14:07
  Speaker 1: sex acts. Once in his presence, each victim knew it
• 14:11
  Speaker 1: was no option to disobey Epstein. It was well known
• 14:15
  Speaker 1: and understood that he was one of the most powerful
• 14:18
  Speaker 1: and connected people in the United States, able to help
• 14:21
  Speaker 1: any of these young victims, and also capable and willing
• 14:25
  Speaker 1: to hurt any of these victims. While the first sexual
• 14:29
  Speaker 1: abuse was discovered to have likely occurred in the early
• 14:32
  Speaker 1: 90s with the use of his then paramour, Glenn Maxwell,
• 14:36
  Speaker 1: his appetite for sexually abusing young women and girls grew
• 14:39
  Speaker 1: over the years. By 2000, each victim was being directed
• 14:43
  Speaker 1: to bring other victims and being paid handsomely in cash
• 14:46
  Speaker 1: for recruiting other victims. The Florida criminal investigation uncovered that
• 14:51
  Speaker 1: Epstein's sex trafficking operation grew its number of victims exponentially
• 14:56
  Speaker 1: in the late 90s and early 2000s. One major reason
• 15:01
  Speaker 1: why Epstein's sex trafficking venture accumulated new victims at an
• 15:04
  Speaker 1: alarming rate in the late 90s and accelerating even faster
• 15:08
  Speaker 1: by 2000 was his access to unlimited amounts of cash.
• 15:13
  Speaker 1: Without exorbitantly large amounts of cash, Epstein's operation could not run,
• 15:17
  Speaker 1: as newly recruited victims were each paid hundreds of dollars
• 15:20
  Speaker 1: in cash immediately after Epstein sexually abused them as hush money.
• 15:26
  Speaker 1: Each victim was also informed that she would be paid
• 15:29
  Speaker 1: hundreds of dollars for each additional victim she recruited, and
• 15:32
  Speaker 1: Epstein made good on that promise of large cash payments.
• 15:36
  Speaker 1: The public documents and articles stemming from the 2006 arrest
• 15:40
  Speaker 1: made abundantly clear that Epstein was doling out thousands of
• 15:44
  Speaker 1: dollars in cash every single day as hush money to
• 15:47
  Speaker 1: victims he was sexually abusing and to victims he was
• 15:50
  Speaker 1: using to recruit additional victims. If Epstein paid every victim
• 15:56
  Speaker 1: with wire transfers and left a documented money trail, his
• 15:59
  Speaker 1: illegal sexual abuse and sex trafficking operation would have been
• 16:02
  Speaker 1: easily uncovered. However, with access to unlimited amounts of cash,
• 16:07
  Speaker 1: Epstein was able to commit egregious sexual crimes many times
• 16:12
  Speaker 1: a day without leaving a paper trail. The constant expansion
• 16:16
  Speaker 1: of sexual abuse and sex trafficking victims required cash on
• 16:19
  Speaker 1: hand for Epstein to pay each victim as hush money
• 16:22
  Speaker 1: for the abuse she was suffering as well as each
• 16:25
  Speaker 1: victim's finder fee for bringing another victim. Because Epstein's vast wealth,
• 16:31
  Speaker 1: said to have been more than a billion dollars, was
• 16:33
  Speaker 1: maintained in seemingly legitimate financial institutions, he needed complicit financial
• 16:39
  Speaker 1: institution that would allow large, regular cash withdrawals in order
• 16:43
  Speaker 1: to operate his sex trafficking operation. In order to access
• 16:47
  Speaker 1: the large amount of cash needed to maintain his active
• 16:51
  Speaker 1: sexual abuse of young women, It was essential that the
• 16:54
  Speaker 1: financial institution where he banked be complicit in his operation,
• 16:58
  Speaker 1: and more specifically that Epstein's bank had a financial institution
• 17:02
  Speaker 1: that would allow him to constantly withdraw cash from his
• 17:05
  Speaker 1: accounts without following anti-money laundering and reporting laws. To put
• 17:10
  Speaker 1: it plainly, Epstein needed a bank that he knew was
• 17:13
  Speaker 1: engaging in illegal activity and did not care, because the
• 17:17
  Speaker 1: bank only cared about the money that it was making
• 17:20
  Speaker 1: from its relationship with Epstein. This scheme of paying victims
• 17:25
  Speaker 1: to bring other victims worked effectively because it not only
• 17:28
  Speaker 1: allowed expansion through the recruitment of other victims in a
• 17:31
  Speaker 1: pyramid scheme fashion, but it also allowed each victim the
• 17:34
  Speaker 1: possibility to avoid future sexual abuse. She could bring someone
• 17:39
  Speaker 1: else who would get abused in her place. Epstein's aptitude
• 17:44
  Speaker 1: as a sex trafficker and appetite as a sexual abuser
• 17:47
  Speaker 1: did not suffer because of his Florida incarceration in 2008.
• 17:51
  Speaker 1: Even while he was in jail in Florida, Epstein continued
• 17:55
  Speaker 1: to sexually abuse young girls and women from his work
• 17:58
  Speaker 1: release office. Once out of jail and off work release,
• 18:02
  Speaker 1: Epstein continued to collect young women and lure them through
• 18:05
  Speaker 1: forced fraud or coercion into one of his mansions, primarily
• 18:10
  Speaker 1: his townhouse located at 9 East 71st Street in New York,
• 18:14
  Speaker 1: where he would sexually abuse each one. His sexual abuse
• 18:18
  Speaker 1: and sex trafficking operation continued as it had in the past,
• 18:22
  Speaker 1: although it became more elaborate, creating more phony companies, opening
• 18:26
  Speaker 1: more bank accounts, withdrawing excessive amounts of cash, and delivering
• 18:30
  Speaker 1: money to victims through wires, payroll, direct deposits, and other
• 18:35
  Speaker 1: means known to his financial institution as evidence of the
• 18:38
  Speaker 1: continuation of his criminal sex trafficking scheme. As time went by,
• 18:42
  Speaker 1: news articles and lawsuits continued to mount, And more information
• 18:46
  Speaker 1: became publicly available that Epstein was continuing to abuse young
• 18:50
  Speaker 1: women and was using professionals on his payroll to help
• 18:53
  Speaker 1: him conceal his illegal activity and give him cover as
• 18:57
  Speaker 1: a well-connected money manager. As a registered sex offender discovered
• 19:01
  Speaker 1: to be sexually abusing multiple young girls each day through
• 19:04
  Speaker 1: a pyramid-type recruiting scheme that required the transfer of millions
• 19:08
  Speaker 1: of dollars to continue the operation, a complicit bank became
• 19:13
  Speaker 1: more important than ever. As is more detailed below, defendant J.P.
• 19:18
  Speaker 1: Morgan worked closely with Epstein through every step of Epstein's
• 19:21
  Speaker 1: sex trafficking operations expansion and growth in its most prolific
• 19:26
  Speaker 1: of years between 2000 and 2013. The Trafficking Victims Protection
• 19:33
  Speaker 1: Act The Trafficking Victims Protection Act, TVPA, outlaws sex trafficking
• 19:39
  Speaker 1: activities that affect interstate or foreign commerce or take place
• 19:43
  Speaker 1: within the territorial jurisdiction of of the United States. It
• 19:48
  Speaker 1: is to be construed broadly because it's serves a remedial
• 19:50
  Speaker 1: purpose and uses intentionally broad language. The TVPA forbids the
• 19:56
  Speaker 1: following sex trafficking conduct. A. Whoever knowingly 1. in or
• 20:01
  Speaker 1: affecting interstate foreign commerce, or within the special maritime and
• 20:05
  Speaker 1: territorial jurisdiction of the United States recruits, entices, harbors, transports, provides, obtains, advertises, maintains, patronizes,
• 20:14
  Speaker 1: or solicits by any means a person or two, benefits
• 20:19
  Speaker 1: financially or by receiving anything of value from participation in
• 20:23
  Speaker 1: a venture which has engaged in an act described in
• 20:26
  Speaker 1: violation of paragraph 1. knowing or except where the act
• 20:30
  Speaker 1: constituting the violation of paragraph is advertising, in reckless disregard
• 20:35
  Speaker 1: of the fact, that means of force, threats of force, fraud, coercion,
• 20:40
  Speaker 1: described in subsection E2, or any combination of such means,
• 20:44
  Speaker 1: will be used to cause the person to engage in
• 20:47
  Speaker 1: a commercial sex act, and that the person has not
• 20:50
  Speaker 1: attained the age of 18 years and will be caused
• 20:52
  Speaker 1: to engage in a commercial sex act, shall be punished
• 20:55
  Speaker 1: as provided in subsection B, 18 U.S. Code Section 1591A.
• 21:02
  Speaker 1: The TVPA also contains an explicit civil remedy provision which
• 21:07
  Speaker 1: allows an individual who is a victim of a violation
• 21:10
  Speaker 1: of Chapter 77 of Title 18 to bring civil action
• 21:14
  Speaker 1: against the perpetrator and any person or entity who knowingly
• 21:18
  Speaker 1: benefits financially or by receiving anything of value from participation
• 21:23
  Speaker 1: in an illegal sex trafficking venture. Unlike the criminal penalties
• 21:27
  Speaker 1: provision in the TVPA, The civil remedies provision contains a
• 21:31
  Speaker 1: constructive knowledge provision. This provision allows a civil action to
• 21:35
  Speaker 1: be brought not only against a person or entity who
• 21:39
  Speaker 1: participated in a venture known to have engaged in illegal
• 21:42
  Speaker 1: sex trafficking, but also against a person or entity who
• 21:46
  Speaker 1: participated in a venture that the person or entity should
• 21:49
  Speaker 1: have known had engaged in illegal sex trafficking. This expansive
• 21:54
  Speaker 1: provision is known as the constructive knowledge provision. which provides
• 21:58
  Speaker 1: an alternative to proving actual knowledge as part of civil
• 22:02
  Speaker 1: damage claims. In the paragraphs that follow, wherever a plaintiff
• 22:06
  Speaker 1: alleges that the defendant acted with actual knowledge or in
• 22:09
  Speaker 1: reckless disregard of the fact that the Epstein sex trafficking
• 22:12
  Speaker 1: venture used means of force, threats of force, fraud, coercion,
• 22:16
  Speaker 1: abuse of process, or some combination thereof to cause a
• 22:20
  Speaker 1: person to engage in commercial sex acts, the plaintiff also
• 22:23
  Speaker 1: alleged that, at a bare minimum, The defendant should have
• 22:26
  Speaker 1: known that Epstein's sex trafficking venture had used such means
• 22:30
  Speaker 1: to engage in illegal sex trafficking in violation of U.S.
• 22:34
  Speaker 1: Code 18 Section 1591-94, i.e., that they had constructive knowledge
• 22:40
  Speaker 1: of Epstein's sex trafficking. Alright, we're going to wrap up
• 22:44
  Speaker 1: this episode right here, and in the next episode, dealing
• 22:46
  Speaker 1: with the topic, we're going to pick up with factual allegations.
• 22:51
  Speaker 1: All of the information that goes with this episode can
• 22:53
  Speaker 1: be found in the description box. What's up everyone and
• 22:57
  Speaker 1: welcome to another episode of the Epstein Chronicles. In this episode,
• 23:00
  Speaker 1: we're going to get right back to it and pick
• 23:02
  Speaker 1: up where we left off with the survivor's lawsuit filed
• 23:07
  Speaker 1: against J.P. Morgan. Factual Allegations During all times relevant to
• 23:13
  Speaker 1: this complaint, Jeffrey Epstein was an extraordinarily wealthy man with
• 23:16
  Speaker 1: multiple residences in the United States, including a New York
• 23:20
  Speaker 1: City mansion, a Palm Beach mansion, and an island in
• 23:23
  Speaker 1: the U.S. Virgin Islands. Beginning in the early 90s and
• 23:28
  Speaker 1: continuing through the summer of 2019, Jeffrey Epstein knowingly established
• 23:32
  Speaker 1: and ran a sex trafficking venture in violation of U.S.
• 23:36
  Speaker 1: Code 18, Section 1591-95. As part of that venture, Epstein
• 23:41
  Speaker 1: used means of force, threats of force, fraud, coercion, abuse
• 23:44
  Speaker 1: of legal process, and a combination of these means to
• 23:47
  Speaker 1: cause young women and girls from all over the world
• 23:50
  Speaker 1: to engage in commercial sex acts and to sexually abuse them.
• 23:54
  Speaker 1: In creating and maintaining this network of victims in multiple
• 23:57
  Speaker 1: states and in other countries to sexually abuse and exploit,
• 24:00
  Speaker 1: Epstein worked and conspired with others, including employees and associates,
• 24:05
  Speaker 1: who facilitated his conduct by, among other things, recruiting victims,
• 24:09
  Speaker 1: coercing victims, and scheduling their sexual abuse by Epstein at
• 24:12
  Speaker 1: his New York mansion, his Palm Beach mansion, and his
• 24:15
  Speaker 1: island in the U.S. Virgin Islands. In this district and elsewhere,
• 24:19
  Speaker 1: Epstein perpetuated this abuse in similar ways, Epstein and his
• 24:23
  Speaker 1: co-conspirators used Epstein's vast yet mysterious wealth and connections to
• 24:28
  Speaker 1: other rich and powerful individuals to lure new victims into
• 24:31
  Speaker 1: his home for seemingly innocuous activity. Victims were initially recruited
• 24:36
  Speaker 1: to speak with an alleged philanthropic Epstein and provide massages
• 24:40
  Speaker 1: to him. Once in the home and trapped in Epstein's bedroom,
• 24:43
  Speaker 1: the victims would be instructed to remove their clothing. Epstein
• 24:47
  Speaker 1: would then force the massages to become increasingly sexual in nature,
• 24:51
  Speaker 1: typically including one or more forced sex acts. Epstein would
• 24:55
  Speaker 1: use the means of force, threats of force, or fraud
• 24:58
  Speaker 1: to coerce the victims to participate in these sex acts
• 25:01
  Speaker 1: and to cause them to return and continue to engage
• 25:04
  Speaker 1: in commercial sex acts with them. Epstein and his associates
• 25:09
  Speaker 1: then paid his victims hundreds of dollars in cash for
• 25:12
  Speaker 1: each sexual encounter. Moreover, Epstein actively encouraged his victims to
• 25:17
  Speaker 1: recruit additional girls to be similarly sexually abused, causing the
• 25:21
  Speaker 1: number of victims to grow exponentially. Epstein incentivized his victims
• 25:27
  Speaker 1: to become recruiters by paying these victim recruiters hundreds of
• 25:30
  Speaker 1: dollars for each girl that they brought to Epstein. In
• 25:34
  Speaker 1: doing so, Epstein, through the system of paying victims to
• 25:36
  Speaker 1: recruit others whom he would also pay for being sexually
• 25:39
  Speaker 1: abused as well as for recruiting, created a sexual abuse
• 25:43
  Speaker 1: and sex trafficking spider web, and maintained a steady supply
• 25:46
  Speaker 1: of new victims to exploit. Epstein was skilled at ascertaining
• 25:51
  Speaker 1: his victims' greatest fears and aspirations and targeted those fears
• 25:55
  Speaker 1: and aspirations to coerce and trap his victims into performing
• 25:58
  Speaker 1: commercial sex acts and to be subject to sexual abuse.
• 26:02
  Speaker 1: Among other things, Epstein sexually abused his many victims and
• 26:07
  Speaker 1: caused his victims to engage in commercial sex acts, specifically
• 26:10
  Speaker 1: sex acts for which his victims received things of value,
• 26:14
  Speaker 1: including cash, promises of educational and career advancement, and promises
• 26:18
  Speaker 1: that Epstein would provide various forms of assistance. Epstein provided
• 26:23
  Speaker 1: things of value to his victims in order to cause
• 26:25
  Speaker 1: them to engage in sex acts with him and on
• 26:27
  Speaker 1: occasion his friends, co-conspirators, or other victims. As one means
• 26:32
  Speaker 1: of causing a victim to engage in commercial sex acts,
• 26:35
  Speaker 1: Epstein and his co-conspirators engaged threatened that harm would come
• 26:38
  Speaker 1: to victims if they did not comply with his demands,
• 26:41
  Speaker 1: that they perform commercial sex acts. As another means of
• 26:45
  Speaker 1: causing victims to engage in commercial sex acts, Epstein and
• 26:48
  Speaker 1: his co-conspirators fraudulently promised to further victims' educational or career
• 26:52
  Speaker 1: aspirations if they would comply with his sexual demands. These
• 26:56
  Speaker 1: promises were a quid pro quo for the sex acts
• 27:00
  Speaker 1: that occurred. As one means of causing victims to engage
• 27:03
  Speaker 1: in commercial sex acts, Epstein and his co-conspirators would give
• 27:07
  Speaker 1: his victims money to stay quiet about the assault, or
• 27:10
  Speaker 1: as a finder's fee for bringing other young women or
• 27:14
  Speaker 1: provide them with living accommodations, clothing, education, or other necessities.
• 27:19
  Speaker 1: Throughout most of the 90s, through about July 2019, the
• 27:23
  Speaker 1: Epstein sex trafficking venture recruited, solicited, enticed, harbored, obtained, provided,
• 27:30
  Speaker 1: and transported to hundreds of victims to cause them to
• 27:33
  Speaker 1: engage in commercial sex acts with Epstein and Epstein's friends.
• 27:38
  Speaker 1: In 2006, Jeffrey Epstein was arrested in Florida after state
• 27:41
  Speaker 1: and federal law enforcement discovered he had sexually abused more
• 27:45
  Speaker 1: than 30 children in Palm Beach. During that investigation, it
• 27:49
  Speaker 1: was concluded that Epstein and his co-conspirators were had committed
• 27:53
  Speaker 1: federal criminal acts constituting violations of U.S. Code 18, Section 2422B, 24222, 2423F, 2423B, 2424E, U.S.
• 27:56
  Speaker 1: Code 18, Section 371, U.S. Code 18, Section 1591C and 1,
• 27:58
  Speaker 1: and 1591A and 1 and 2, as well as state
• 27:59
  Speaker 1: crimes and violation of Florida Statute 16. 796.07 and 796.03
• 28:22
  Speaker 1: against dozens of young women. As a consequence of the
• 28:26
  Speaker 1: Florida investigation, Epstein pled guilty to two felonies, was permanently
• 28:30
  Speaker 1: labeled a registered sex offender, and was jailed in 2008.
• 28:34
  Speaker 1: Epstein's criminal case in Florida and the many related news
• 28:39
  Speaker 1: reports left no doubt about Jeffrey Epstein and his extraordinary
• 28:43
  Speaker 1: penchant for sexual abuse and the trafficking of young females.
• 28:47
  Speaker 1: For instance, it was revealed that until the time of
• 28:49
  Speaker 1: his Florida arrest, Jeffrey Epstein was sexually abusing three to
• 28:52
  Speaker 1: four young girls per day. It was a full-time job
• 28:56
  Speaker 1: for him. Beginning with the Florida arrest and for years
• 28:59
  Speaker 1: moving forward, Epstein was embroiled in dozens of public lawsuits
• 29:03
  Speaker 1: pertaining to his sexual abuse of females and hundreds, if
• 29:07
  Speaker 1: not thousands, of news stories circulated worldwide about his illegal
• 29:11
  Speaker 1: sexual proclivities. In addition to the many civil lawsuits seeking
• 29:15
  Speaker 1: damages for sexual abuse, Epstein's victims also filed a public
• 29:19
  Speaker 1: lawsuit against the U.S. under U.S. Code Section 3771, the
• 29:24
  Speaker 1: Crime Victims Rights Act, CVRA, further exposing Epstein's sexual crimes
• 29:29
  Speaker 1: as well as a secret non-prosecution agreement he entered into
• 29:33
  Speaker 1: with the federal government. Epstein recruited, solicited, enticed, harbored, obtained, provided,
• 29:39
  Speaker 1: and transferred his victims to cause them to engage in
• 29:42
  Speaker 1: commercial sex acts in ways that were in and affecting
• 29:45
  Speaker 1: interstate and foreign commerce, including using means of interstate communication,
• 29:50
  Speaker 1: such as cellular telephones, and means of interstate and foreign travel,
• 29:54
  Speaker 1: such as aircraft that he owned and controlled. Epstein transported
• 29:58
  Speaker 1: his victims in interstate and foreign commerce, including transportation to
• 30:02
  Speaker 1: and from his mansion in this district. The Epstein sex
• 30:06
  Speaker 1: trafficking venture transported victims across state boundaries between New York, Florida,
• 30:11
  Speaker 1: New Mexico, New Jersey, Massachusetts, and the U.S. Virgin Islands
• 30:15
  Speaker 1: and elsewhere, and in foreign commerce to places, especially Eastern Europe.
• 30:20
  Speaker 1: At all times relevant to this complaint, Epstein Sex Trafficking
• 30:24
  Speaker 1: Venture was a group of two or more individuals associated,
• 30:27
  Speaker 1: in fact, even if they were not a formal legal entity. Indeed,
• 30:31
  Speaker 1: members of the Epstein Sex Trafficking Venture referred to it
• 30:35
  Speaker 1: as the organization. On July 2, 2019, the U.S. Attorney's
• 30:40
  Speaker 1: Office for Southern District of New York filed a sealed
• 30:43
  Speaker 1: two-count indictment against Epstein, including one count of sex trafficking. conspiracy,
• 30:48
  Speaker 1: and one count of sex trafficking for violation of U.S.
• 30:51
  Speaker 1: Code 18, Section 1591, in part due to Epstein's criminal
• 30:55
  Speaker 1: activity in his New York mansion, located at 9 East
• 30:59
  Speaker 1: 71st Street. On July 8, 2019, Jeffrey Epstein was arrested
• 31:03
  Speaker 1: pursuant to the New York indictment. On August 10, 2019,
• 31:08
  Speaker 1: prison guards found Epstein unresponsive at his Metropolitan Correctional Center
• 31:12
  Speaker 1: jail cell, where he was awaiting trial on the federal
• 31:15
  Speaker 1: sex trafficking charges. He was later pronounced dead from apparent suicide.
• 31:21
  Speaker 1: In July of 2020, Epstein's co-conspirator in The Origin and
• 31:25
  Speaker 1: the sex trafficking venture, Ghislaine Maxwell, was arrested on federal
• 31:29
  Speaker 1: sex trafficking charges filed in this court. The charges allege
• 31:33
  Speaker 1: that she had assisted, facilitated, and contributed to Epstein's abuse
• 31:37
  Speaker 1: of sex trafficking victims, helping Epstein to recruit, groom, and
• 31:42
  Speaker 1: ultimately abuse his victims. On December 29th, 2021, Maxwell was
• 31:47
  Speaker 1: found guilty in this court on five federal sex trafficking
• 31:50
  Speaker 1: counts in this court and is now serving close to
• 31:53
  Speaker 1: 20 years in federal prison for these crimes. Consistent with
• 31:58
  Speaker 1: his uniform pattern and practice, Jane Doe One was forced
• 32:01
  Speaker 1: to engage in commercial sex acts with Epstein by means
• 32:04
  Speaker 1: of force, fraud, and coercion. Jane Doe One was living
• 32:09
  Speaker 1: with her mother when she met Jeffrey Epstein in 2006.
• 32:12
  Speaker 1: Jane Doe One was a ballet dancer in New York
• 32:15
  Speaker 1: when she was recruited to meet Jeffrey Epstein by another
• 32:18
  Speaker 1: young female who had also fallen prey to Jeffrey Epstein's
• 32:21
  Speaker 1: sex trafficking scheme. Epstein and his co-conspirators had a long
• 32:25
  Speaker 1: history of grooming, indoctrinating, controlling, and ultimately committing sexual offenses
• 32:30
  Speaker 1: against young, vulnerable women like Jane Doe One. Epstein and
• 32:35
  Speaker 1: his co-conspirators constantly reminded Jane Doe One how powerful and
• 32:39
  Speaker 1: important Epstein was. Jane Doe 1 was chastised if she
• 32:43
  Speaker 1: refused Epstein's sexual demands and told she should be grateful
• 32:47
  Speaker 1: that Epstein was willing to help her with her career
• 32:49
  Speaker 1: and education. She came to believe what she was told.
• 32:53
  Speaker 1: The well-oiled Epstein sex abuse and trafficking venture included frequent
• 32:58
  Speaker 1: statements to Jane Doe 1 and other victims by Jeffrey
• 33:01
  Speaker 1: Epstein and his co-conspirators that 1. Jeffrey Epstein possessed extraordinary wealth, power,
• 33:07
  Speaker 1: and influence. 2. Jeffrey Epstein's businesses and political friends, including
• 33:12
  Speaker 1: world leaders, also included some of the most powerful people
• 33:15
  Speaker 1: in the world. Jeffrey Epstein had the ability to advance
• 33:19
  Speaker 1: or destroy nearly anyone financially, reputationally, and otherwise. Four medical
• 33:25
  Speaker 1: and normal life necessities would be denied victims if they,
• 33:29
  Speaker 1: including Jane Doe One, failed to perform commercial sex acts
• 33:32
  Speaker 1: for Epstein. M5. Epstein could take away Jane Doe 1
• 33:37
  Speaker 1: and other victims' life needs, such as shelter or housing,
• 33:41
  Speaker 1: if she or they failed to perform these sex acts.
• 33:44
  Speaker 1: Jane Doe 1 was exceptionally vulnerable to being victimized by Epstein.
• 33:48
  Speaker 1: His sex trafficking venture targeted vulnerable young women, and Jane
• 33:52
  Speaker 1: Doe 1 was soon indoctrinated and unable to extricate herself.
• 33:56
  Speaker 1: Jane Doe 1 was sexually abused and trafficked by Epstein
• 33:59
  Speaker 1: for several years. Having been conditioned that the sexual abuse
• 34:03
  Speaker 1: was normal, and knowing that everyone surrounding Epstein, including accountants, lawyers,
• 34:08
  Speaker 1: and other important people were aware of the sex abuse,
• 34:10
  Speaker 1: Jane Doe 1 was coerced into a cult-like life, controlled
• 34:14
  Speaker 1: and manipulated by Epstein, and others doing Epstein's bidding. Over
• 34:19
  Speaker 1: the ensuing years from 2006 to 2013, Epstein sexually abused
• 34:23
  Speaker 1: Jane Doe 1 on a number of occasions, in direct
• 34:26
  Speaker 1: violation of New York Penal Law 130-1. including sexual misconduct
• 34:32
  Speaker 1: as defined in 130.20, inasmuch as Jeffrey Epstein engaged in
• 34:37
  Speaker 1: sexual intercourse with plaintiff without plaintiff's consent. B. Rape in
• 34:41
  Speaker 1: the first degree as defined in 130.35. C. Criminal sexual
• 34:46
  Speaker 1: act in the first degree as defined in 130.50. D.
• 34:50
  Speaker 1: Forcible touching as defined in 130.52. E. Sexual abuse in
• 34:56
  Speaker 1: the third degree as defined in 130.66. Jane Doe 1
• 35:01
  Speaker 1: was also trafficked to Jeffrey Epstein's friends for commercial sex
• 35:04
  Speaker 1: acts in this district. Epstein used means of force, threats
• 35:08
  Speaker 1: of force, fraud, coercion, abuse of process, and a combination
• 35:12
  Speaker 1: of such means to cause Jane Doe 1 to engage
• 35:15
  Speaker 1: in commercial sex acts. Epstein recruited Jane Doe 1 to
• 35:19
  Speaker 1: cause her to engage in commercial sex acts in ways
• 35:22
  Speaker 1: that were and in affecting interstate and foreign commerce, including
• 35:26
  Speaker 1: the use of cellular telephones and and means of interstate transportation,
• 35:30
  Speaker 1: such as aircraft that he owned or controlled. Alright folks,
• 35:33
  Speaker 1: we're going to wrap up right there, and in the
• 35:35
  Speaker 1: next episode, dealing with the topic we're going to pick
• 35:37
  Speaker 1: up where we left off. All of the information that
• 35:39
  Speaker 1: goes with this episode can be found in the description box.
• 35:43
  Speaker 1: What's up everyone, and welcome to another episode of the
• 35:46
  Speaker 1: Epstein Chronicles. In this episode, we're going to pick up
• 35:50
  Speaker 1: with the lawsuit filed by the Epstein survivors against J.P. Morgan.
• 35:55
  Speaker 1: Jane Doe One wanted to escape from the Epstein trafficking venture,
• 35:59
  Speaker 1: yet Epstein and his supporting team of co-conspirators increased the
• 36:02
  Speaker 1: tactics of fraud, force, or coercion to cause her to
• 36:06
  Speaker 1: remain compliant in fulfilling Epstein's sexual demands. Jeffrey Epstein controlled
• 36:11
  Speaker 1: Jane Doe One. Financially, emotionally, and psychologically, he used his
• 36:16
  Speaker 1: knowledge of Jane Doe One's aspirations, fears, and problems to
• 36:20
  Speaker 1: manipulate her until she was completely controlled by and dependent
• 36:23
  Speaker 1: upon him. When Epstein went to jail for sex offenses
• 36:26
  Speaker 1: in Florida, he maintained contact with Jane Doe One. He
• 36:29
  Speaker 1: and his employees of his business entities, which were created
• 36:33
  Speaker 1: to support and legitimize Epstein's sexual abuse and sex trafficking enterprise,
• 36:38
  Speaker 1: including HBRK NES Financial Trust and Florida Science Foundation, caused
• 36:44
  Speaker 1: Jane Doe One to be transported to Florida in order
• 36:47
  Speaker 1: to engage in commercial sex with Epstein in his Florida
• 36:50
  Speaker 1: residence while on so-called work release from jail. while he
• 36:54
  Speaker 1: was still wearing his ankle monitor. There came a time
• 36:57
  Speaker 1: when Epstein forced Jang Do-won to give massages to his
• 37:00
  Speaker 1: powerful friends. During some of these massages, she was sexually abused,
• 37:04
  Speaker 1: by force and against her will, by Epstein's friends, whom
• 37:07
  Speaker 1: she had been required to massage. At least one of
• 37:10
  Speaker 1: Epstein's friends used aggressive force in his sexual assault of
• 37:13
  Speaker 1: her and informed Do-won that he had Epstein's permission to
• 37:16
  Speaker 1: do what he wanted to her. Out of fear, Jang
• 37:19
  Speaker 1: Do-won has still not named this powerful financial executive publicly.
• 37:24
  Speaker 1: Epstein and his co-conspirators withdrew large sums of cash from J.P.
• 37:28
  Speaker 1: Morgan to make cash payments to victims, including J-01, in
• 37:32
  Speaker 1: furtherance of the sex trafficking enterprise. J.P. Morgan knew that
• 37:36
  Speaker 1: its accounts were being used for this trafficking based on
• 37:39
  Speaker 1: a number of factors, including but not limited to the
• 37:42
  Speaker 1: identity of the individuals making the withdrawals and wire transfers,
• 37:46
  Speaker 1: the identity of the recipients, the account opening activity, the
• 37:50
  Speaker 1: pattern of financial activity, and Epstein's well-documented criminal history and
• 37:54
  Speaker 1: involvement in trafficking. Over the ensuing years, Epstein threatened Jane
• 37:59
  Speaker 1: Doe One in many ways, including threatening her that if
• 38:02
  Speaker 1: she did not abide by his demands, she would lose
• 38:04
  Speaker 1: contact with people that she cared about. Epstein would alternate
• 38:08
  Speaker 1: promises and threats to secure Jane Doe One's compliance with
• 38:11
  Speaker 1: his demands, including demands that she engage in commercial sex
• 38:14
  Speaker 1: acts with him and others. In some instances, Epstein would
• 38:18
  Speaker 1: pay Jane Doe 1 directly in cash obtained from J.P.
• 38:21
  Speaker 1: Morgan for the sex acts. Epstein and his co-conspirators continued
• 38:25
  Speaker 1: to coerce Jane Doe 1 in various ways until her
• 38:28
  Speaker 1: ultimate escape around the end of 2013. J.P. Morgan J.P.
• 38:34
  Speaker 1: Morgan's Participation in the Venture In or about 1998, in
• 38:39
  Speaker 1: furtherance of his rapidly growing sexual abuse and sex trafficking operation,
• 38:43
  Speaker 1: Jeffrey Epstein realized that he needed a reliable banking institution
• 38:47
  Speaker 1: that would provide the necessary legitimate appearance for his operation,
• 38:51
  Speaker 1: allow him to open many accounts for illegitimate companies, ignore
• 38:55
  Speaker 1: red flags, ignore federal banking laws, allow him to transfer
• 38:59
  Speaker 1: money without questioning, allow him access to abundant cash, and
• 39:04
  Speaker 1: to otherwise facilitate the commercial aspect of his commercial sex
• 39:07
  Speaker 1: trafficking enterprise. Epstein found all of those things in J.P. Morgan.
• 39:13
  Speaker 1: From about 2000 to 2013, JPMorgan knowingly and intentionally participated
• 39:19
  Speaker 1: in the Epstein sex trafficking venture by, among other things,
• 39:23
  Speaker 1: providing the essential financial underpinnings for the venture. There can
• 39:28
  Speaker 1: be no doubt that J.P. Morgan's conduct, as described below,
• 39:30
  Speaker 1: was outrageous and intentional. Around 2000, Epstein developed a key
• 39:35
  Speaker 1: relationship to expanding exploitative sexual abuse and his sex trafficking
• 39:40
  Speaker 1: operation when he began working with James Jess Staley, the
• 39:44
  Speaker 1: then head of J.P. Morgan's private banking division. Before meeting Staley,
• 39:47
  Speaker 1: Epstein was a serial sexual abuser of young girls and
• 39:50
  Speaker 1: women with an insatiable desire to sexually abuse females that were,
• 39:55
  Speaker 1: in his words, the younger the better. Before Staley, Epstein
• 39:59
  Speaker 1: relied heavily on the massive wealth bestowed upon him by
• 40:03
  Speaker 1: one individual, Leslie Herbert Wexner, to give him the appearance
• 40:07
  Speaker 1: of grand importance while relying on his madam, co-conspirator you mean,
• 40:11
  Speaker 1: Ghislaine Maxwell, to find and groom young women to be
• 40:14
  Speaker 1: abused by Epstein. However, Epstein could not expand his operation
• 40:17
  Speaker 1: to the level it ultimately reached without a complicit financial
• 40:21
  Speaker 1: banking institution that would ignore red flags to the point
• 40:24
  Speaker 1: of allowing him to pay hundreds of young females in
• 40:27
  Speaker 1: wire transfers and allow him to access to hundreds of
• 40:30
  Speaker 1: thousands of dollars in cash to pay hush money to
• 40:33
  Speaker 1: his growing number of victims. Staley was the key to
• 40:36
  Speaker 1: making all of Epstein's depraved dreams of sexual abuse and
• 40:39
  Speaker 1: sex trafficking countless young women possible. With his help, the
• 40:44
  Speaker 1: number of victims of the Epstein sex trafficking operation began
• 40:47
  Speaker 1: to grow on a vertical trajectory beginning in 2000. When
• 40:51
  Speaker 1: Epstein and Staley first teamed up, in or about 2000,
• 40:54
  Speaker 1: Staley was the head of J.P. Morgan's private banking division
• 40:58
  Speaker 1: and was later promoted to CEO of J.P. Morgan Asset Management.
• 41:03
  Speaker 1: The relationship between Epstein and Staley was symbiotic. Epstein agreed
• 41:07
  Speaker 1: to bring many high-ultra wealth clients to J.P. Morgan and
• 41:10
  Speaker 1: in exchange, Staley would use his clout within JP Morgan
• 41:14
  Speaker 1: to make Epstein untouchable. This meant that JP Morgan would
• 41:18
  Speaker 1: keep Epstein on as a client at all costs, including
• 41:21
  Speaker 1: failing to act on any red flags and ultimately allowing
• 41:24
  Speaker 1: him the ability to run and grow. What to the
• 41:27
  Speaker 1: bank was obviously an operation designed to sexually abuse and
• 41:31
  Speaker 1: traffic countless young women. There were several key figures who
• 41:35
  Speaker 1: created Epstein's international sex trafficking operation, most notably Glenn Maxwell.
• 41:39
  Speaker 1: Les Wexner, and Jess Staley through J.P. Morgan. In later years,
• 41:44
  Speaker 1: Deutsche Bank picked up where J.P. Morgan left off and
• 41:47
  Speaker 1: provided the necessary complicit financial institution for the operation. Without Maxwell,
• 41:53
  Speaker 1: Epstein would never have been able to recruit his first
• 41:56
  Speaker 1: victims and been able to bring them into his abusive lair.
• 42:00
  Speaker 1: She approached young, vulnerable victims and spread the word that
• 42:03
  Speaker 1: Epstein was this altruistic messiah who could help them. Once
• 42:07
  Speaker 1: they were in Epstein's clutches, she groomed them to make
• 42:10
  Speaker 1: them feel comfortable being sexually exploited and abused. Without Wexner,
• 42:14
  Speaker 1: Epstein's sex trafficking operation and sexual abuse of women could
• 42:18
  Speaker 1: never have occurred to the extent that it did, as
• 42:21
  Speaker 1: Epstein needed the appearance of extraordinary wealth to attract his
• 42:24
  Speaker 1: victims and force them to stay silent. However, even with
• 42:28
  Speaker 1: Wexner's funding of Epstein's operation, Epstein's sexual abuse of hundreds
• 42:32
  Speaker 1: of women would have been limited to because the money
• 42:35
  Speaker 1: trail from Epstein's accounts to the many victims and recruiters
• 42:38
  Speaker 1: would have exposed the operation quickly. Therefore, the final essential
• 42:42
  Speaker 1: ingredient Epstein needed to expand the sexual abuse of young
• 42:45
  Speaker 1: women and sex trafficking enterprise was a financial institution that
• 42:50
  Speaker 1: would not care that Epstein was sexually abusing women on
• 42:53
  Speaker 1: a daily basis and paying out millions in hush money. J.P.
• 42:57
  Speaker 1: Morgan provided the financial component Epstein needed, and Staley made
• 43:01
  Speaker 1: sure Epstein and his illegal sexual abuse organization was absolutely
• 43:05
  Speaker 1: protected by the bank. From the beginning of the Epstein-Staley relationship,
• 43:09
  Speaker 1: Staley understood that Epstein's money was only part of the
• 43:13
  Speaker 1: incentive to protect Epstein's operation. As long as Epstein's money
• 43:17
  Speaker 1: stayed at the bank, Staley also knew that Wexner, Epstein's client,
• 43:21
  Speaker 1: who had turned over a power of attorney to Epstein,
• 43:24
  Speaker 1: would likewise keep his money with J.P. Morgan and Wexner's
• 43:27
  Speaker 1: money was said to amount over a billion dollars. It
• 43:31
  Speaker 1: did not stop there. Epstein made it clear that he
• 43:34
  Speaker 1: collected people and was close with many ultra-wealthy individuals that
• 43:38
  Speaker 1: he could bring into the bank. These new customers made J.P.
• 43:42
  Speaker 1: Morgan even more profitable. Along the way, Epstein gave credit
• 43:46
  Speaker 1: for these new bank customers to Staley, which made Staley
• 43:49
  Speaker 1: enormously wealthy. Epstein controlled Staley like he did his many victims,
• 43:55
  Speaker 1: by flaunting his power and connections and extreme wealth. Epstein
• 44:00
  Speaker 1: made it clear to Staley that if J.P. Morgan ever
• 44:02
  Speaker 1: decided to terminate its relationship with Epstein, the bank would
• 44:06
  Speaker 1: lose Wexner and other wealthy connections Epstein had promised J.P. Morgan.
• 44:11
  Speaker 1: Staley was enamored with Epstein and driven by greed, which
• 44:14
  Speaker 1: made Epstein one of the most coveted clients of J.P. Morgan.
• 44:18
  Speaker 1: Through the years, Staley helped accumulate other protectors of Epstein
• 44:22
  Speaker 1: with J.P. Morgan, such as Mary Erdos, who were also
• 44:27
  Speaker 1: willing to turn a blind eye to Epstein's blatantly illegal operation.
• 44:31
  Speaker 1: With J.P. Morgan's complicity, Epstein was free to sexually abuse
• 44:35
  Speaker 1: hundreds of women, paying millions in hush money without the
• 44:38
  Speaker 1: fear of detection by law enforcement. Epstein used the support
• 44:42
  Speaker 1: from a reputable institution, J.P. Morgan, to help cover up
• 44:45
  Speaker 1: his criminal activity. J.P. Morgan cared about one thing, profit,
• 44:50
  Speaker 1: and showed absolute loyalty to Epstein, including a willingness to
• 44:53
  Speaker 1: violate banking laws and ignore multiple red flags of criminality
• 44:58
  Speaker 1: to enable Epstein to fulfill his abusive sexual appetite at
• 45:02
  Speaker 1: the expense of countless vulnerable young women. As Epstein's criminal
• 45:06
  Speaker 1: sex trafficking venture expanded and he needed more protection and
• 45:09
  Speaker 1: support from J.P. Morgan, Epstein continued to grow closer to Staley.
• 45:14
  Speaker 1: As another example of J.P. Morgan and Staley's Benefit from
• 45:17
  Speaker 1: assisting Epstein, another highly profitable deal for J.P. Morgan was
• 45:21
  Speaker 1: the Highbridge deal. In 2004, at the height of Epstein's
• 45:25
  Speaker 1: sex trafficking and abuse operation, when he was transferring massive
• 45:28
  Speaker 1: amounts of hush money to his victims and recruiters and
• 45:31
  Speaker 1: withdrawing hundreds of thousands of dollars in cash so that
• 45:35
  Speaker 1: all the payments were not traceable, the most obvious red
• 45:37
  Speaker 1: flag for any criminal enterprise, Epstein served up another big
• 45:41
  Speaker 1: financial payday to J.P. Morgan. Epstein was close friends with
• 45:45
  Speaker 1: Glenn Dubin, the billionaire who ran Highbridge Capital Management, whom
• 45:49
  Speaker 1: he introduced to Staley. Through Epstein's connection, it has been
• 45:53
  Speaker 1: reported that Staley arranged for JPMorgan to buy a majority
• 45:56
  Speaker 1: stake in Dubin's fund, which resulted in a sizable profit
• 46:00
  Speaker 1: for JPMorgan. This arrangement was profitable for both Staley and JPMorgan,
• 46:06
  Speaker 1: further incentivizing JPMorgan to ignore the suspicious activity in Epstein's accounts.
• 46:12
  Speaker 1: In addition to Epstein, JPMorgan also housed accounts for Epstein's
• 46:15
  Speaker 1: main sex trafficking madam, Ghislaine Maxwell, who is now serving
• 46:19
  Speaker 1: 20 years in prison for sex trafficking related to her
• 46:22
  Speaker 1: participation in Epstein's operation. In 2022, JPMorgan representative Patrick McHugh
• 46:31
  Speaker 1: testified in Maxwell's criminal sex trafficking trial that between 1999
• 46:36
  Speaker 1: and 2000, Epstein transferred approximately $ 31 million to Maxwell, an
• 46:40
  Speaker 1: amount believed to be payment for her role an Epstein
• 46:43
  Speaker 1: sex trafficking venture. All right, folks, we're going to wrap
• 46:46
  Speaker 1: up right here. And in the next episode dealing with
• 46:48
  Speaker 1: the topic, we're going to pick up where we left off.
• 46:52
  Speaker 1: All of the information that goes with this episode can
• 46:54
  Speaker 1: be found in the description box.