Speaker 1: What's up, everyone, and welcome to another episode of the
Epstein Chronicles. In this episode, we're going to begin taking
a look at the lawsuit that was filed by the
Epstein Survivors against JP Morgan. And this is a pretty
massive lawsuit, so it runs seventy five pages. So in
this episode, we're going to begin eating the elephant, one
bite at a time. Case number one twenty two DASH
CV DASH one zero zero one nine DASH JSR Jang
DO one individually and on behalf of all others similarly situated. First,
JP Morgan, Chase and Company Class Action Complaint Individual and
Class action complaint. Plaintiff Chang Do one files this individual
and civil class action complaint for damages and other relief under,
among other provisions of law, the US Federal Anti Sex
Trafficking Statute US Code eighteen, Section fifteen ninety one through
ninety five, the Trafficking Victims Protection ACTIVPA, and for intentional
and negligent acts as omissions under the New York Adult
Survivors Act. The pseud arises from defendant JP Morgan, Chase
and Company hereinafter JP Morgan financially benefiting from participating in
Jeffrey Epstein sex trafficking by providing the requisite financial support
for the continued operation of Epstein's International sex Trafficking Organization
from nineteen ninety eight through August of twenty thirteen. JP
Morgan knowingly and intentionally benefited and received things of value
for assisting, supporting, facilitating, and otherwise providing the most critical
service for the Jeffrey Epstein Sex Trafficking Organization to successfully rape, sexually, assault,
and coercively sex traffic Plaintiff Jane one and the numerous
other members of the class proposed below. JP Morgan knew
that Epstein was regularly committing violations of New York Penal
Law Article one thirty, including and especially New York Penal
Laws Section one thirty dot twenty one, thirty dot thirty five,
one thirty dot fifty one, thirty dot fifty two, and
one thirty dot sixty six, and acted in a negligent
manner so as to enable Epstein to commit such offenses
against countless young women. JP Morgan also knew that Epstein
would use means of force, threats of force, fraud, abuse
a legal process, exploitation of power, disparity, and a variety
of other forms of coercion to cause young women and
girls to engage in commercial sex acts, knowing that they
would earn millions of dollars from facilitating Epstein's sex abuse
in trafficking. JP Morgan chose profits over following the law. Specifically,
JP Morgan chose facilitating the sexual abuse and sex trafficking
operation for many years, including through the criminal investigation and
incarceration of Jeffrey Epstein, in order to turn profits. Plaintiff
makes the following allegations on information and belief and believes
that substantial additional evidentiary support will exist for the allegation
set fourth here in after a reasonable opportunity for discovery
one jurisdiction venue in timelines. This action is brought pursuing
two various federal and state statutes, including the Federal TVPA
US Code eighteen, section fifteen eighty nine through section fifteen
ninety five. The Court has Federal question subject matter jurisdiction
pursuing to US Code twenty eight, section thirteen thirty one.
Because Jane do One individually and on behalf of the
other class members proceeds under the Federal TVPA statute. This
Court also has supplemental jurisdiction over the state law claims
recounted below, pursuing to US Code twenty eight, section thirteen
sixty seven A. Because all claims alleged here in are
part of a uniform pattern in practice and form part
of the same case and controversy, this court is an
appropriate district court of the United States in accordance with
US Code eighteen, section fifteen ninety five, in which to
bring this action. Venue is proper in this district under
US Code twenty eight section thirteen ninety one B two
because Epstein and his co conspirators and JP Morgan all
conducted substantial activities in this district and knowingly aided and abetted, facilitated,
and directly participated in Epstein's legal venture through actions that
originated in this district. In addition, Epstein's actually abused in
traffic Jane Doe and members of the class in this district.
Often these acts of sexual abuse and commercial sex acts
committed by Jeffrey Epstein and certain select friends of his
took place in Jeffrey Epstein's New York mansion, located within
the district at nine East seventy first Street in New
York City. Epstein also used his New York mansion to
harbor his victims as a base from which to transport
them to other locations outside of New York. A substantial
part of the acts, events, and omissions giving right to
the cause of action occurred in this district. This action
has been timely filed pursuing the US Code eighteen, Section
fifteen ninety five c one, which provides that the plaintiff
shall have ten years after the cause of action arose
to file suit against any person who knowingly benefits financially
or by receiving anything of value from participation in a
venture which that person knew or should have known violated
laws against sex trafficking. Two parties. Jang Doe is a
US citizen and was at all relevant times a resident
and domiciled in the state of New York. Plaintiff Jang
Do one is using a pseudonym to protect her identity
because of the sensitive and highly personal nature of this matter,
which involves sexual assault. Jan Do one is also at
serious risk of retaliatory harm because the co conspirators who
participated in the Epstein sex trafficking venture had and continue
to possess tremendous wealth and power and have demonstrated a
clear ability to cause her serious harm. Jan do One's safety,
rite to privacy and security outweigh the public interest in
her identification. Jan do One's legitimate concerns outweigh any prejudice
to defendant by allowing her to proceed anonymously. Accordingly, Jane
Doe will be filing a motion to proceed anonymously as
discussed below. Many of the women are similarly situated to
Jang Do One and also need to proceed anonymously for
the same reasons. The identities of most of these other
women are known to the defendant. Defendant JP Morgan is
a global financial institution headquartered in New York, New York.
Defendant JP Morgan is licensed by the New York State
Department of Financial Services to operate a foreign bank branch
in the state of New York. Defendant JP Morgan currently
conducts substantial business in this district and conducted substantial business
at the time of the events covered in the complaints.
One example of business conducted in this district, JP Morgan
ord narrowly shares trade on the New York Stock Exchange,
located in this district. As another example, JP Morgan maintains
branch banks within the district. JP Morgan's financial activity, including
the events alleged here in, were in and affecting interest
and foreign commerce. In connection with the acts alleged in
the complaint, Defendant directly or indirectly use the means and
instrumentalities of interstate commerce, including but not limited to the males,
interstate telephone communications, and the facilities of national securities markets.
JP Morgan is responsible under the United States law and
otherwise for the acts of its officers, directors, employees, and agents,
including the acts described in the complaint introduction. Jeffrey Epstein's
sex trafficking venture operated in many respects as a sex
theme cult designed to ensnare vulnerable young women and in
doctrine them into Epstein's carefully constructed world in which Epstein
was there Messiah. Epstein and his co conspirators preach the
gospel of Epstein. Epstein's victims were taught to do what
he said, and he would protect them. But disobey him,
and he would punish them and continue to disobey, and
he would cause them serious harm from which they could
never recover. Once in Epstein's clutches, each victim was taught
and understood that she must be completely compliant with every
wish or demand that Epstein had for otherwise she would
certainly suffer a serious reputational, financial, and psychological harm. By
using these and other means of force, threats of force, fraud,
threats of abuse of the legal process, and coercion, Epstein
and his co conspirators sexually trafficked and sexually abused plaintiff
Chane do I and other members of the class. The
Epstein Sex Trafficking Venture originated in the early nineties, and
from its inception until Jeffrey Epstein's arrest by the FBI
for sex trafficking in twenty nineteen and his subsequent death
on August tenth, twenty nineteen, by apparent suicide. The venture
operated primarily for the purpose of learning young women and
girls into a position where Jeffrey Epstein and his co
conspirators could course them to engage in commercial sex acts
and commit sexual offenses against them. His venture also operated
to conceal its sex trafficking from law enforcement organizations. The
Epstein Sex Trafficking Venture was well structured from the beginning
and grew increasingly more complex and powerful as it victimized
more young women and as its relationship with Defend and
JP Morgan grew. Epstein did not act alone. He created
and maintained a sex trafficking venture with the assistance of
other influential individuals and entities who knew he was sexually
abusing and sexually trafficking young women and girls and provided
support to facilitate his sexual abuse and secret trafficking operation.
Epstein sex trafficking venture was not possible without the assistance
and complicity of a financial institution, specifically banking institution, which
provided special treatment to the sex trafficking venture, thereby ensuring
its continued operation and sexual abuse and sex trafficking of
young women and girls. Without the financial institution's participation, Epstein's
sex trafficking scheme could not have existed. Epstein's victims were
young women and girls who suffered severe abuse as Epstein's
sex trafficking victims, and who believed that they had to
remain loyal to the venture at all costs in order
to survive. Epstein victimized hundreds of young women and girls.
Epstein's sexual abuse and sex trafficking scheme was supported by
virtually unlimited wealth derived from select wealthy individuals who acted
as the financial engine behind the sex trafficking operation. Epstein
masterfully assessed the specific needs and vulnerability of each of
his targeted victims. He then closed the trap on his
victims with offers of money, food, shelter, medical care for
them or family members, travel, schooling, and career opportunities. Epstein
groomed the young women and girls in doctrinating them to
believe that the sexual abuse was normal. Epstein fraudulently represented
to the victims that he would take care of them
in various ways, which ultimately allowed Epstein to cause them
to engage in commercial sex acts with himself and on occasion, others,
as well as to create the opportunity for Epstein to
sexually abuse them. The Epstein sex trafficking venture's purpose including enticing, obtaining, harboring,
and transporting the young victims without drawing unwonted attention from
law enforcement. The venture had everything a sex trafficking organization needed, funding, infrastructure,
the appearance of legitimacy, and a complicit banking institution. It was,
by many accounts, the most powerful and wealthiest sex trafficking
venture ever created. All right, folks, we're gonna wrap up
right here, and in the next episode, we're gonna pick
up where we left off. All of the information that
goes with this episode can be found in the description box.
What's up, everyone, and welcome to another episode of the
Epstein Chronicles. In this episode, we're gonna pick up where
we left off with the lawsuit filed by the Epstein
survivors against JP Morgan. The Epstein Sex Trafficking Venture knowingly
used means of force, threats of force, fraud, coercion, including
threats of serious harm or physical restraint, and abuse of
law and the legal process to cause Jane do One
and many dozens of other similarly situated women to engage
in commercial sex acts. The Epstein Sex Trafficking Venture operated
in and affected interstate and foreign commerce. Epstein recruited, solicited, coerced, harbored, transported,
and enticed some of his victims, including Jane doe One
and others similarly situated, to engage in commercial sex acts in,
among other places, New York, including the Southern District of
New York, Florida, the US Virgin Islands, New Mexico, England,
and France. The Epstein Sex Trafficking Venture operated throughout the
world from in and around the early nineties through in
and around August tenth, twenty nineteen, when Epstein died of
an apparent suicide. Thereafter two and including the date of
this complaint, members of the sex trafficking venture continued to
further the venture by concealing the activities and the extent
of the venture. The manner of operation of for Epstein's
particular sexual abuse and sex trafficking operation was widely publicized.
He would lure young girls or women to one of
his luxurious mansions under the guise of being a wealthy
philanthropist able to advance careers, education, or provide other life necessities,
and once inside, he would force his would be victim
into providing a massage that would turn sexual, and from
there he would cause each of the unsuspecting victims to
engage in a variety of commercial sex acts. Once in
his presence, each victim knew it was no option to
disobey Epstein. It was well known and understood that he
was one of the most powerful and connected people in
the United States, able to help any of these young victims,
and also capable and willing to hurt any of these victims.
While the first sexual abuse was discovered to have likely
occurred in the early nineties with the use of his
then paramour, Glenn Maxwell. His appetite for sexually abusing young
women and girls grew over the years. By two thousand,
each victim was being directed to bring other victims and
being paid handsomely in cash for recruiting other victims. The
Florida Criminal Investigation uncovered that epstein sex trafficking operation grew
its number of victims exponentially in the late nineties and
early two thousands. One major reason why epstein sex trafficking
venture accumulated new victims at an alarming rate in the
late nineties and accelerating even faster by two thousand was
his access to unlimited amounts of cash. Without exorbitantly large
amounts of cash, Epstein's operation could not run, as newly
recruited victims were each paid hundreds of dollars in cash
immediately after Epstein's sexually abused them as hush money. Each
victim was also informed that she would be paid hundreds
of dollars for each additional victims she recruited, and Epstein
made good on that promise of large cash payments. The
public documents and articles stemming from the two thousand six
arrest made abundantly clear that Epstein was doling out thousands
of dollars in cash every single day as hush money
to victims he was sexually abusing, and to victims he
was using to recruit additional victims. If Epstein paid every
victim with wire transfers and left a documented money trail,
his illegal sexual abuse in sex trafficking operation would have
been easily uncovered. However, with access to unlimited amounts of cash,
Epstein was able to commit ogregious sexual crimes many times
a day without leaving a paper trail. The constant expansion
of sexual abuse and sex trafficking victims required cash on
hand for Epstein to pay each victim as hush money
for the abuse she was suffering, as well as each
victim's find your fee for bringing another victim. Because Epstein's
vast wealth, said to have been more than a billion dollars,
was maintained in seemingly legitimate financial institutions, he needed complicit
financial institution that would allow large, regular cash withdrawals in
order to operate his sex trafficking operation. In order to
access the large amount of cash needed to maintain his
active sexual abuse of young women. It was essential that
the financial institution where he banked be complicit in his operation,
and more specifically, that at Epstein's bank at a financial
institution that would allow him to constantly withdraw cash from
his accounts without following anti money laundering and reporting laws.
To put it plainly, Epstein needed a bank that he
knew was engaging in ilegal activity and did not care,
because the bank only cared about the money that it
was making from its relationship with Epstein. This scheme of
paying victims to bring other victims work effectively because it
not only allowed expansion through the recruitment of other victims
in a pyramid scheme fashion, but it also allowed each
victim the possibility to avoid future sexual abuse she could
bring someone else who would get abused in her place.
Epstein's aptitude as a sex trafficker and appetite as a
sexual abuser did not suffer because of his Florida incarceration
in two thousand and eight. Even while he was in
jail in Florida, Epstein continued to sexually abuse young girls
and women from his work release office. Once out of
jail and off work release, Epstein continued to collect young
women and lure them through force, fraud, or coercion into
one of his mansions, primarily his townhouse located at nine
East seventy first Street in New York, where he would
sexually abuse each one. His sexual abuse and sex trafficking
operation continued as it had in the past, although it
became more elaborate, creating more phony companies, opening more bank accounts,
with drawing excessive amounts of cash, and delivering money to
victims through wires, payroll, direct deposits, and other means known
to his financial institution as evidence of the continuation of
his criminal sex trafficking scheme. As time went by, news
articles and lawsuits continued to mount, and more information became
publicly available that Epstein was continuing to abuse young women
and was using professionals on his payroll to help him
conceal his illegal activity and give them cover as a
well connected money manager. As a red disted sex offender
discovered to be sexually abusing multiple young girls each day
through a pyramid type recruiting scheme that required the transfer
of millions of dollars to continue the operation, a complicit
bank became more important than ever, as is more detailed below.
Defending JP Morgan work closely with Epstein through every step
of Epstein's sex trafficking operations, expansion and growth in its
most prolific of years between two thousand and twenty thirteen.
The Trafficking Victims Protection Act the Trafficking Victims Protection Act
TVPA outlaws sex trafficking activities that affect interstate or foreign
commerce or take place within the territorial jurisdiction of the
United States. It is to be construed broadly because it
serves a remedial purpose and uses intentionally broad language. The
TVPA forbids the following sex trafficking conduct a whoever knowingly
won one in or affecting interstate, foreign commerce, or within
the special maritime and territorial jurisdiction of the United States, recruits, entices, harbors, transports, provides, obtains, advertises, maintains, patronizes,
or solicits by any means. A person or two benefits
financially or by receiving anything of value from participation in
a venture which has engaged in an act described in
violation of Paragraph one, knowing or accept where the act
constituting the violation of paragraph is advertising in a reckless
disregard of the fact that means of force, threats of force,
fraud coercion described in Subsection E two, or any combination
of such means, will be used to cause the person
to engage in a commercial sex act, and that the
person has not attained the age of eighteen years and
will be caused to engage in a commercial sex act
shall be punished as provided in sub Section B eighteen
US Code Section fifteen ninety one A. The TVPA also
contains an explicit civil remedy provision, which allows an individual
who is a victim of a violation of Chapter seventy
seven of Title eighteen to bring civil action against the
perpetrator and any person or entity who knowingly benefits financially
or by receiving anything of value from participation in an
illegal sex trafficking venture. Unlike the criminal penalties provision in
the TVPA, the civil remedies provision contains a constructive knowledge provision.
This provision allows a civil action to be brought not
only against a person or entity who participated in a
venture known to have engaged in illegal sex trafficking, but
also against a person or entity who participated in a
venture that the person or entity should have known had
engaged in illegal sex trafficking. This expanse of provision is
known as the constructive knowledge provision, which provides an alternative
to proving aca xtual knowledge as part of civil damage claims.
In the paragraphs that follow, wherever, plaintiff alleges that the
defendant acted with actual knowledge or in reckless disregard of
the fact that the Epstein sex trafficking venture use means
of force, threats of force, fraud, coercion, abusive process, or
some combination thereof to cause a person to engage in
commercial sex acts. The plaintiff also alleged that, at a
bare minimum, the defendant should have known that Epstein's sex
trafficking venture had used such means to engage in illegal
sex trafficking in violation of US Code eighteen, Section fifteen
ninety one through ninety four, i e. That they had
constructive knowledge of Epstein's sex trafficking. All right, we're going
to wrap up this episode right here, and in the
next episode dealing with the topic, we're going to pick
up with factual allegations. All of the information that goes
with this episode can be found in the description box.
What's up, everyone, and welcome to another episode of the
Epstein Chronicles. In this episode, we're going to get right
back to it and pick up where we left off
with the survivor's lawsuit filed against JP Morgan. Factual allegations
during all times relevant to this complaint, Jeffrey Epstein was
an extraordinarily wealthy man with multiple residences in the United States,
including a New York City mansion, a U Palm Beach mansion,
and an island in the US Virgin Islands. Beginning in
the early nineties and continuing through the summer of twenty nineteen,
Jeffrey Epstein knowingly established and ran a sex trafficking venture
in violation of US Code eighteen, Section fifteen ninety one
through ninety five. As part of that venture, Epstein used
means of force, threats of force, fraud, coercion, abuse, a
legal process, and a combination of these means to cause
young women and girls from all over the world to
engage in commercial sex acts and to sexually abuse them.
In creating and maintaining this network of victims in multiple
states and in other countries, to sexually abuse and explore
Epstein worked and conspired with others, including employees and dissociates,
who facilitated his conduct by, among other things, recruiting victims,
coercing victims, and scheduling their sexual abuse by Epstein at
his New York mansion, his Palm Beach mansion, and his
island in the US Virgin Islands. In this district and elsewhere,
Epstein perpetuated this abuse in similar ways. Epstein and his
co conspirators used Epstein's vast yet mysterious wealth and connections
to other rich and powerful individuals to learn new victims
into his home for seemingly innocuous activity. Victims were initially
recruited to speak with an alleged philanthropic Epstein and provide
massages to him. Once in the home and trapped in
Epstein's bedroom, the victims would be instructed to remove their clothing.
Epstein would then force the massages to become increasingly sexual
in nature, typically including one or more four sex acts.
Epstein would use the means of force, threats of force,
or fraud to coerce the victims to pret dissipate in
these sex acts and to cause them to return and
continue to engage in commercial sex acts with them. Epstein
and his associates then paid his victims hundreds of dollars
in cash for each sexual encounter. Moreover, Epstein actively encouraged
his victims to recruit additional girls to be similarly sexually abused,
causing the number of victims to grow exponentially. Epstein incentivized
his victims to become recruiters by paying these victim recruiters
hundreds of dollars for each girl that they brought to Ebstein.
In doing so, Epstein, through the system of paying victims
to recruit others, whom he would also pay for being
sexually abused as well as for recruiting, created a sexual
abuse and sex trafficking spider web and maintained a steady
supply of new victims to exploit. Epstein was skilled at
ascertaining his victim's greatest fears and aspirations, and targeted those
fears and aspirations to coerce and trap his victims into
performing commercial sex acts and to be subject to sexual abuse,
among other things. Epstein's sexually abused his many victims and
caused his victims to engage in commercial sex acts, specifically
sex acts for which his victims received things of value,
including cash, promises of educational and career infatsment, and promises
that Epstein would provide various forms of assistance. Epstein provided
things of value to his victims in order to cause
them to engage in sex acts with him and on occasion,
his friends, co conspirators, or other victims. As one means
of causing a victim to engage in commercial sex acts,
Epstein and his co conspirators threatened that harm would come
to victims if they did not comply with his demands
that they perform commercial sex acts. As another means of
causing victims to engage in commercial sex acts, Epstein and
his co conspirators fraudulently promised to further victims educational or
career aspirations if they would comply with his sexual demands.
These promises were a quid pro quo for this sex
acts that occurred. As one means of causing victims to
engage in commercial sex acts, Epstein and his co conspirators
would give his victims money to stay quiet about the
assault or as a finder's fee for bringing other young women,
or provide them with living accommodations, clothing, education, or other necessities.
Throughout most of the nineties through about July twenty nineteen,
the Epstein sex trafficking venture recruited, solicited, enticed, harbored, obtained, provided,
and transported hundreds of victims to cause them to engage
in commercial sex acts with Epstein and Epstein's friends. In
two thousand and six, Jeffrey Epstein was arrested in Florida
after state and federal law enforcement discovered he had sexually
abused more than thirty children in Palm Beach. During that investigation,
it was concluded that Epstein and his co conspirators had
committed federal criminal acts constituting violations of US Code eighteen,
Section twenty four to twenty two B twenty four to
twenty two to two, twenty four to twenty three, F
twenty four twenty three B twenty four to twenty four E.
US Code eighteen, Section three seventy one, US Code eighteen
Section fifteen ninety one C to one and fifteen ninety
one A and one and two, as well as state
crimes and violation of Florida Statute seven ninety six dot
oh seven and seven ninety six dot three against dozens
of young women as a consequence of the Florida investigation,
Epstein pled guilty to two felonies, was permanently labeled a
registered sex offender, and was jailed in two thousand and eight.
Epstein's criminal case in Florida and the many related news
reports left no doubt about Jeffrey Epstein and his extraordinary
pension for sexual abuse and the trafficking of young females.
For instance, it was revealed that until the time of
his Florida arrest, Jeffrey Epstein was sexually abusing three to
four young girls per day. It was a full time
job for him. Beginning with the Florida arrest and for
years moving forward, Epstein was embroiled in dozens of public
lawsuits pertaining to his sexual abuse of females, and hundreds,
if not thousands, of new story circulated worldwide about his
illegal sexual proclivities. In addition to the many civil lawsuits
seeking damages for sexual abuse, Epstein's victims also filed a
public lawsuit against the US under US Code Section thirty
seven seventy one the Crime Victims Rights Act CVRA, further
exposing Epstein's sexual crimes, as well as a secret non
prosecution agreement he entered into with the federal government. Epstein recruited, solicited, enticed, harbored, obtained, provided,
and transported his victims to cause them to engage in
commercial sex acts in ways that were in and affecting
interstate and foreign commerce, including using means of interstate communication
such as cellular telephones, and means of interstate and foreign
travel such as aircraft that he owned and controlled. Epstein
transported his victims in interstate and foreign cosme commerce, including
transportation to and from his mansion in this district. The
Epstein sex Trafficking Venture transported victims across state boundaries between
New York, Florida, New Mexico, New Jersey, Massachusetts, and the
US Virgin Islands and elsewhere, and in foreign commerce the places,
especially Eastern Europe. At all times relevant to this complaint,
Epstein's sex trafficking Venture was a group of two or
more individuals associated in fact, even if they were not
a formal legal entity. Indeed, members of the Epstein Sex
Trafficking Venture referred to it as the organization. On July
TEWO twenty nineteen, the US Attorney's Office for a Southern
District of New York filed the sealed to count indictment
against Epstein, including one count of sex trafficking conspiracy and
one count of sex trafficking for violation of US Code eighteen,
section fifteen ninety one, in part due to Epstein's criminal
activity in his New York mansion located at nine E
seventy first Street. On July eighth, twenty nineteen, Jeffrey Epstein
was arrested pursued into the New York indictment. On August tenth,
twenty nineteen, prison guards found Epstein on responsive at Metropolitan
Correctional Center jel Cell, where he was awaiting trial on
the federal sex trafficking charges. He was later pronounced dead
from apparent suicide. In July of twenty twenty, Epstein's co
conspirator in the Origin and the Sex Trafficking venture, Glenn Maxwell,
was arrested on federal sex trafficking charges filed in this court.
The charges alleged that she had assisted, facilitated, and contributed
to Epstein's abuse of sex trafficking victims, helping Epstein to recruit,
groom and ultimately abuse his victims. On December twenty ninth,
twenty twenty one, Maxwell was found guilty in this Court
on five federal sex trafficking counts in this court and
is now serving close to twenty years in federal prison
for these crimes. Consistent with his uniform pattern and practice,
Jane do One was forced to engage in commercial sex
acts with Epstein by means of force, fraud, and coercion.
Jane do One was living with her mother when she
met Jeffrey Epstein in two thousand and six. Jane do
One was a ballet dancer in New York when she
was recruited to meet Jeffrey Epstein by another young female
who had also fallen prey to Jeffrey Epstein's sex trafficking scheme.
Epstein and his co conspirators had a long history of grooming, indoctrinating, controlling,
and ultimately committing sexual offenses against young, vulnerable women like
Jane do One. Epstein and his co conspirators constantly reminded
Jane do One how powerful and important Epstein was. Jane
do One was chastised if she refused Epstein's sexual demands
and told she should be grateful that Epstein was willing
to help her with her career and education. She came
to believe what she was told the well oiled Epstein's
sex abuse and trafficking venture included frequent statements to Jane
do One and other victims by Jeffrey Epstein and his
co conspirators that won Jeffrey Epstein possessed extraordinary wealth, power,
and influence. Two Jeffrey Epstein's businesses and political friends, including
world leaders, also included some of the most powerful people
in the world. Jeffrey Epstein had the ability to advance
or destroy nearly anyone financially, reputationally, and otherwise. Four medical
and normal life necessities would be denied victims if they,
including Jane do One, failed to perform commercial sex acts
for Epstein, and five Epstein could take away Jane do
One and other victims life needs such as shelter, warhousing,
if she or they failed to perform these sex acts.
Jane do One was exceptionally vulnerable to being victimized by Epstein.
His sex trafficking venture targeted vulnerable young women, and Jane
do One was soon indoctrinated and unable to extricate herself.
Jane do One was sexually abused in traffic by Epstein
for self years, having been conditioned that the sexual abuse
was normal and knowing that everyone surrounding Epstein, including accountants, lawyers,
and other important people, were aware of the sex abuse,
Jane do One was coerced into occult like life, controlled
and manipulated by Epstein and others doing Epstein's bidding. Over
the ensuing years from two thousand and six to twenty thirteen,
Epstein sexually abused Jane do One on a number of
occasions and direct violation of New York Penal Law one thirty,
including sexual misconduct as defined in one thirty dot twenty
inasmuch as Jeffrey Epstein engaged in sexual intercourse with plaintiff
without plaintiff's consent. B Rape in the first degree is
defined in one thirty dot thirty five. See criminal sexual
act in the first degree as defined in one thirty
dot fifty D. Forcible touching as defined in one thirty
dot fifty two E. Sexual abuse in the third degree
is defined in one thirty dout sixty six. Jane Doe
One was also traffied to Jeffrey Epstein's friends for commercial
sex acts. In this district, Epstein used means of force,
threats of force, fraud, coercion, abusive process, and a combination
of such means to cause Jane doe One to engage
in commercial sex acts. Epstein recruited Jane do One, the causer,
to engage in commercial sex acts in ways that were
and in affecting interstate and foreign commerce, including the use
of cellular telephones and means of interstate transportation such as
aircraft that he owned were controlled. All right, folks, we're
going to wrap up right there, and in the next
episode dealing with the topic, we're going to pick up
where we left off. All of the information that goes
with this episode can be found in the description box.