1 00:00:00,160 --> 00:00:02,960 Speaker 1: What's up, everyone, and welcome to another episode of the 2 00:00:02,960 --> 00:00:06,480 Epstein Chronicles. In this episode, we're going to begin taking 3 00:00:06,480 --> 00:00:09,119 a look at the lawsuit that was filed by the 4 00:00:09,119 --> 00:00:13,359 Epstein Survivors against JP Morgan. And this is a pretty 5 00:00:13,400 --> 00:00:17,199 massive lawsuit, so it runs seventy five pages. So in 6 00:00:17,239 --> 00:00:19,879 this episode, we're going to begin eating the elephant, one 7 00:00:19,920 --> 00:00:24,440 bite at a time. Case number one twenty two DASH 8 00:00:24,519 --> 00:00:30,719 CV DASH one zero zero one nine DASH JSR Jang 9 00:00:30,719 --> 00:00:35,960 DO one individually and on behalf of all others similarly situated. First, 10 00:00:36,039 --> 00:00:41,600 JP Morgan, Chase and Company Class Action Complaint Individual and 11 00:00:41,640 --> 00:00:45,479 Class action complaint. Plaintiff Chang Do one files this individual 12 00:00:45,679 --> 00:00:49,679 and civil class action complaint for damages and other relief under, 13 00:00:49,920 --> 00:00:53,159 among other provisions of law, the US Federal Anti Sex 14 00:00:53,159 --> 00:00:57,359 Trafficking Statute US Code eighteen, Section fifteen ninety one through 15 00:00:57,439 --> 00:01:02,560 ninety five, the Trafficking Victims Protection ACTIVPA, and for intentional 16 00:01:02,759 --> 00:01:05,799 and negligent acts as omissions under the New York Adult 17 00:01:05,840 --> 00:01:10,079 Survivors Act. The pseud arises from defendant JP Morgan, Chase 18 00:01:10,280 --> 00:01:15,280 and Company hereinafter JP Morgan financially benefiting from participating in 19 00:01:15,359 --> 00:01:19,799 Jeffrey Epstein sex trafficking by providing the requisite financial support 20 00:01:20,040 --> 00:01:24,280 for the continued operation of Epstein's International sex Trafficking Organization 21 00:01:24,719 --> 00:01:29,159 from nineteen ninety eight through August of twenty thirteen. JP 22 00:01:29,280 --> 00:01:33,439 Morgan knowingly and intentionally benefited and received things of value 23 00:01:33,439 --> 00:01:38,040 for assisting, supporting, facilitating, and otherwise providing the most critical 24 00:01:38,079 --> 00:01:43,920 service for the Jeffrey Epstein Sex Trafficking Organization to successfully rape, sexually, assault, 25 00:01:44,120 --> 00:01:47,719 and coercively sex traffic Plaintiff Jane one and the numerous 26 00:01:47,760 --> 00:01:51,680 other members of the class proposed below. JP Morgan knew 27 00:01:51,840 --> 00:01:55,439 that Epstein was regularly committing violations of New York Penal 28 00:01:55,519 --> 00:01:59,599 Law Article one thirty, including and especially New York Penal 29 00:01:59,680 --> 00:02:02,879 Laws Section one thirty dot twenty one, thirty dot thirty five, 30 00:02:03,159 --> 00:02:06,159 one thirty dot fifty one, thirty dot fifty two, and 31 00:02:06,280 --> 00:02:09,639 one thirty dot sixty six, and acted in a negligent 32 00:02:09,680 --> 00:02:13,560 manner so as to enable Epstein to commit such offenses 33 00:02:13,759 --> 00:02:18,599 against countless young women. JP Morgan also knew that Epstein 34 00:02:18,639 --> 00:02:22,080 would use means of force, threats of force, fraud, abuse 35 00:02:22,080 --> 00:02:26,319 a legal process, exploitation of power, disparity, and a variety 36 00:02:26,360 --> 00:02:29,159 of other forms of coercion to cause young women and 37 00:02:29,280 --> 00:02:32,719 girls to engage in commercial sex acts, knowing that they 38 00:02:32,719 --> 00:02:36,080 would earn millions of dollars from facilitating Epstein's sex abuse 39 00:02:36,120 --> 00:02:41,280 in trafficking. JP Morgan chose profits over following the law. Specifically, 40 00:02:41,400 --> 00:02:45,599 JP Morgan chose facilitating the sexual abuse and sex trafficking 41 00:02:45,639 --> 00:02:49,879 operation for many years, including through the criminal investigation and 42 00:02:49,960 --> 00:02:55,599 incarceration of Jeffrey Epstein, in order to turn profits. Plaintiff 43 00:02:55,639 --> 00:02:59,520 makes the following allegations on information and belief and believes 44 00:02:59,520 --> 00:03:03,919 that substantial additional evidentiary support will exist for the allegation 45 00:03:04,000 --> 00:03:08,159 set fourth here in after a reasonable opportunity for discovery 46 00:03:09,159 --> 00:03:13,560 one jurisdiction venue in timelines. This action is brought pursuing 47 00:03:13,879 --> 00:03:17,719 two various federal and state statutes, including the Federal TVPA 48 00:03:18,719 --> 00:03:22,360 US Code eighteen, section fifteen eighty nine through section fifteen 49 00:03:22,400 --> 00:03:26,280 ninety five. The Court has Federal question subject matter jurisdiction 50 00:03:26,639 --> 00:03:29,759 pursuing to US Code twenty eight, section thirteen thirty one. 51 00:03:30,199 --> 00:03:33,080 Because Jane do One individually and on behalf of the 52 00:03:33,120 --> 00:03:38,319 other class members proceeds under the Federal TVPA statute. This 53 00:03:38,439 --> 00:03:42,080 Court also has supplemental jurisdiction over the state law claims 54 00:03:42,159 --> 00:03:45,680 recounted below, pursuing to US Code twenty eight, section thirteen 55 00:03:45,719 --> 00:03:49,360 sixty seven A. Because all claims alleged here in are 56 00:03:49,439 --> 00:03:52,240 part of a uniform pattern in practice and form part 57 00:03:52,439 --> 00:03:56,000 of the same case and controversy, this court is an 58 00:03:56,039 --> 00:03:59,000 appropriate district court of the United States in accordance with 59 00:03:59,159 --> 00:04:02,719 US Code eighteen, section fifteen ninety five, in which to 60 00:04:02,719 --> 00:04:05,840 bring this action. Venue is proper in this district under 61 00:04:05,919 --> 00:04:09,240 US Code twenty eight section thirteen ninety one B two 62 00:04:09,680 --> 00:04:13,719 because Epstein and his co conspirators and JP Morgan all 63 00:04:13,759 --> 00:04:18,959 conducted substantial activities in this district and knowingly aided and abetted, facilitated, 64 00:04:19,120 --> 00:04:23,399 and directly participated in Epstein's legal venture through actions that 65 00:04:23,480 --> 00:04:28,040 originated in this district. In addition, Epstein's actually abused in 66 00:04:28,040 --> 00:04:31,480 traffic Jane Doe and members of the class in this district. 67 00:04:32,480 --> 00:04:35,160 Often these acts of sexual abuse and commercial sex acts 68 00:04:35,279 --> 00:04:38,600 committed by Jeffrey Epstein and certain select friends of his 69 00:04:39,199 --> 00:04:42,759 took place in Jeffrey Epstein's New York mansion, located within 70 00:04:42,800 --> 00:04:46,079 the district at nine East seventy first Street in New 71 00:04:46,160 --> 00:04:49,519 York City. Epstein also used his New York mansion to 72 00:04:49,560 --> 00:04:52,959 harbor his victims as a base from which to transport 73 00:04:53,000 --> 00:04:57,040 them to other locations outside of New York. A substantial 74 00:04:57,079 --> 00:05:00,240 part of the acts, events, and omissions giving right to 75 00:05:00,279 --> 00:05:04,480 the cause of action occurred in this district. This action 76 00:05:04,839 --> 00:05:08,000 has been timely filed pursuing the US Code eighteen, Section 77 00:05:08,360 --> 00:05:11,879 fifteen ninety five c one, which provides that the plaintiff 78 00:05:12,160 --> 00:05:14,759 shall have ten years after the cause of action arose 79 00:05:14,920 --> 00:05:19,160 to file suit against any person who knowingly benefits financially 80 00:05:19,519 --> 00:05:22,680 or by receiving anything of value from participation in a 81 00:05:22,800 --> 00:05:25,959 venture which that person knew or should have known violated 82 00:05:26,040 --> 00:05:31,839 laws against sex trafficking. Two parties. Jang Doe is a 83 00:05:31,920 --> 00:05:35,240 US citizen and was at all relevant times a resident 84 00:05:35,279 --> 00:05:38,519 and domiciled in the state of New York. Plaintiff Jang 85 00:05:38,560 --> 00:05:41,399 Do one is using a pseudonym to protect her identity 86 00:05:41,680 --> 00:05:45,000 because of the sensitive and highly personal nature of this matter, 87 00:05:45,319 --> 00:05:49,240 which involves sexual assault. Jan Do one is also at 88 00:05:49,279 --> 00:05:53,279 serious risk of retaliatory harm because the co conspirators who 89 00:05:53,319 --> 00:05:57,199 participated in the Epstein sex trafficking venture had and continue 90 00:05:57,240 --> 00:06:01,120 to possess tremendous wealth and power and have demonstrated a 91 00:06:01,160 --> 00:06:05,279 clear ability to cause her serious harm. Jan do One's safety, 92 00:06:05,480 --> 00:06:08,959 rite to privacy and security outweigh the public interest in 93 00:06:09,000 --> 00:06:14,040 her identification. Jan do One's legitimate concerns outweigh any prejudice 94 00:06:14,079 --> 00:06:18,120 to defendant by allowing her to proceed anonymously. Accordingly, Jane 95 00:06:18,199 --> 00:06:22,600 Doe will be filing a motion to proceed anonymously as 96 00:06:22,639 --> 00:06:25,839 discussed below. Many of the women are similarly situated to 97 00:06:25,920 --> 00:06:29,079 Jang Do One and also need to proceed anonymously for 98 00:06:29,120 --> 00:06:32,120 the same reasons. The identities of most of these other 99 00:06:32,199 --> 00:06:36,519 women are known to the defendant. Defendant JP Morgan is 100 00:06:36,560 --> 00:06:40,240 a global financial institution headquartered in New York, New York. 101 00:06:40,879 --> 00:06:43,879 Defendant JP Morgan is licensed by the New York State 102 00:06:43,920 --> 00:06:47,839 Department of Financial Services to operate a foreign bank branch 103 00:06:48,000 --> 00:06:51,319 in the state of New York. Defendant JP Morgan currently 104 00:06:51,399 --> 00:06:56,240 conducts substantial business in this district and conducted substantial business 105 00:06:56,279 --> 00:06:59,839 at the time of the events covered in the complaints. 106 00:07:00,120 --> 00:07:03,480 One example of business conducted in this district, JP Morgan 107 00:07:03,759 --> 00:07:06,759 ord narrowly shares trade on the New York Stock Exchange, 108 00:07:07,000 --> 00:07:11,279 located in this district. As another example, JP Morgan maintains 109 00:07:11,319 --> 00:07:16,040 branch banks within the district. JP Morgan's financial activity, including 110 00:07:16,079 --> 00:07:19,480 the events alleged here in, were in and affecting interest 111 00:07:20,079 --> 00:07:23,079 and foreign commerce. In connection with the acts alleged in 112 00:07:23,120 --> 00:07:26,959 the complaint, Defendant directly or indirectly use the means and 113 00:07:27,000 --> 00:07:32,639 instrumentalities of interstate commerce, including but not limited to the males, 114 00:07:32,959 --> 00:07:37,680 interstate telephone communications, and the facilities of national securities markets. 115 00:07:38,279 --> 00:07:41,519 JP Morgan is responsible under the United States law and 116 00:07:41,639 --> 00:07:46,639 otherwise for the acts of its officers, directors, employees, and agents, 117 00:07:46,680 --> 00:07:52,360 including the acts described in the complaint introduction. Jeffrey Epstein's 118 00:07:52,360 --> 00:07:56,360 sex trafficking venture operated in many respects as a sex 119 00:07:56,439 --> 00:07:59,600 theme cult designed to ensnare vulnerable young women and in 120 00:07:59,639 --> 00:08:04,160 doctrine them into Epstein's carefully constructed world in which Epstein 121 00:08:04,399 --> 00:08:08,279 was there Messiah. Epstein and his co conspirators preach the 122 00:08:08,319 --> 00:08:11,720 gospel of Epstein. Epstein's victims were taught to do what 123 00:08:11,800 --> 00:08:15,079 he said, and he would protect them. But disobey him, 124 00:08:15,279 --> 00:08:18,480 and he would punish them and continue to disobey, and 125 00:08:18,519 --> 00:08:21,319 he would cause them serious harm from which they could 126 00:08:21,360 --> 00:08:25,920 never recover. Once in Epstein's clutches, each victim was taught 127 00:08:26,040 --> 00:08:29,240 and understood that she must be completely compliant with every 128 00:08:29,279 --> 00:08:33,679 wish or demand that Epstein had for otherwise she would 129 00:08:33,720 --> 00:08:39,039 certainly suffer a serious reputational, financial, and psychological harm. By 130 00:08:39,120 --> 00:08:42,240 using these and other means of force, threats of force, fraud, 131 00:08:42,440 --> 00:08:46,279 threats of abuse of the legal process, and coercion, Epstein 132 00:08:46,279 --> 00:08:50,120 and his co conspirators sexually trafficked and sexually abused plaintiff 133 00:08:50,200 --> 00:08:53,600 Chane do I and other members of the class. The 134 00:08:53,639 --> 00:08:58,320 Epstein Sex Trafficking Venture originated in the early nineties, and 135 00:08:58,360 --> 00:09:01,559 from its inception until Jeffrey Epstein's arrest by the FBI 136 00:09:01,840 --> 00:09:05,480 for sex trafficking in twenty nineteen and his subsequent death 137 00:09:05,519 --> 00:09:09,360 on August tenth, twenty nineteen, by apparent suicide. The venture 138 00:09:09,480 --> 00:09:12,799 operated primarily for the purpose of learning young women and 139 00:09:12,879 --> 00:09:16,399 girls into a position where Jeffrey Epstein and his co 140 00:09:16,399 --> 00:09:20,080 conspirators could course them to engage in commercial sex acts 141 00:09:20,279 --> 00:09:25,200 and commit sexual offenses against them. His venture also operated 142 00:09:25,240 --> 00:09:30,080 to conceal its sex trafficking from law enforcement organizations. The 143 00:09:30,120 --> 00:09:33,639 Epstein Sex Trafficking Venture was well structured from the beginning 144 00:09:33,840 --> 00:09:37,799 and grew increasingly more complex and powerful as it victimized 145 00:09:37,840 --> 00:09:40,840 more young women and as its relationship with Defend and 146 00:09:40,879 --> 00:09:45,840 JP Morgan grew. Epstein did not act alone. He created 147 00:09:45,879 --> 00:09:48,960 and maintained a sex trafficking venture with the assistance of 148 00:09:49,080 --> 00:09:53,240 other influential individuals and entities who knew he was sexually 149 00:09:53,320 --> 00:09:57,320 abusing and sexually trafficking young women and girls and provided 150 00:09:57,360 --> 00:10:01,000 support to facilitate his sexual abuse and secret trafficking operation. 151 00:10:02,120 --> 00:10:05,879 Epstein sex trafficking venture was not possible without the assistance 152 00:10:06,080 --> 00:10:11,480 and complicity of a financial institution, specifically banking institution, which 153 00:10:11,519 --> 00:10:15,159 provided special treatment to the sex trafficking venture, thereby ensuring 154 00:10:15,440 --> 00:10:19,279 its continued operation and sexual abuse and sex trafficking of 155 00:10:19,320 --> 00:10:24,600 young women and girls. Without the financial institution's participation, Epstein's 156 00:10:24,600 --> 00:10:29,600 sex trafficking scheme could not have existed. Epstein's victims were 157 00:10:29,679 --> 00:10:33,480 young women and girls who suffered severe abuse as Epstein's 158 00:10:33,480 --> 00:10:36,279 sex trafficking victims, and who believed that they had to 159 00:10:36,320 --> 00:10:39,360 remain loyal to the venture at all costs in order 160 00:10:39,480 --> 00:10:43,480 to survive. Epstein victimized hundreds of young women and girls. 161 00:10:44,279 --> 00:10:47,639 Epstein's sexual abuse and sex trafficking scheme was supported by 162 00:10:47,720 --> 00:10:52,279 virtually unlimited wealth derived from select wealthy individuals who acted 163 00:10:52,279 --> 00:10:56,600 as the financial engine behind the sex trafficking operation. Epstein 164 00:10:56,720 --> 00:11:00,480 masterfully assessed the specific needs and vulnerability of each of 165 00:11:00,519 --> 00:11:03,440 his targeted victims. He then closed the trap on his 166 00:11:03,519 --> 00:11:07,039 victims with offers of money, food, shelter, medical care for 167 00:11:07,120 --> 00:11:12,600 them or family members, travel, schooling, and career opportunities. Epstein 168 00:11:12,679 --> 00:11:15,480 groomed the young women and girls in doctrinating them to 169 00:11:15,519 --> 00:11:21,000 believe that the sexual abuse was normal. Epstein fraudulently represented 170 00:11:21,039 --> 00:11:22,879 to the victims that he would take care of them 171 00:11:22,879 --> 00:11:26,279 in various ways, which ultimately allowed Epstein to cause them 172 00:11:26,440 --> 00:11:30,639 to engage in commercial sex acts with himself and on occasion, others, 173 00:11:31,080 --> 00:11:33,840 as well as to create the opportunity for Epstein to 174 00:11:33,879 --> 00:11:40,480 sexually abuse them. The Epstein sex trafficking venture's purpose including enticing, obtaining, harboring, 175 00:11:40,679 --> 00:11:44,279 and transporting the young victims without drawing unwonted attention from 176 00:11:44,360 --> 00:11:50,679 law enforcement. The venture had everything a sex trafficking organization needed, funding, infrastructure, 177 00:11:50,879 --> 00:11:55,720 the appearance of legitimacy, and a complicit banking institution. It was, 178 00:11:55,759 --> 00:11:59,360 by many accounts, the most powerful and wealthiest sex trafficking 179 00:11:59,480 --> 00:12:03,360 venture ever created. All right, folks, we're gonna wrap up 180 00:12:03,440 --> 00:12:05,519 right here, and in the next episode, we're gonna pick 181 00:12:05,600 --> 00:12:08,440 up where we left off. All of the information that 182 00:12:08,440 --> 00:12:11,919 goes with this episode can be found in the description box. 183 00:12:12,080 --> 00:12:14,840 What's up, everyone, and welcome to another episode of the 184 00:12:14,840 --> 00:12:18,240 Epstein Chronicles. In this episode, we're gonna pick up where 185 00:12:18,240 --> 00:12:21,399 we left off with the lawsuit filed by the Epstein 186 00:12:21,480 --> 00:12:28,279 survivors against JP Morgan. The Epstein Sex Trafficking Venture knowingly 187 00:12:28,519 --> 00:12:32,039 used means of force, threats of force, fraud, coercion, including 188 00:12:32,080 --> 00:12:35,879 threats of serious harm or physical restraint, and abuse of 189 00:12:36,000 --> 00:12:38,559 law and the legal process to cause Jane do One 190 00:12:38,840 --> 00:12:43,159 and many dozens of other similarly situated women to engage 191 00:12:43,399 --> 00:12:47,759 in commercial sex acts. The Epstein Sex Trafficking Venture operated 192 00:12:47,840 --> 00:12:53,960 in and affected interstate and foreign commerce. Epstein recruited, solicited, coerced, harbored, transported, 193 00:12:54,120 --> 00:12:57,039 and enticed some of his victims, including Jane doe One 194 00:12:57,279 --> 00:13:01,200 and others similarly situated, to engage in commercial sex acts in, 195 00:13:01,600 --> 00:13:05,600 among other places, New York, including the Southern District of 196 00:13:05,639 --> 00:13:10,120 New York, Florida, the US Virgin Islands, New Mexico, England, 197 00:13:10,279 --> 00:13:14,639 and France. The Epstein Sex Trafficking Venture operated throughout the 198 00:13:14,679 --> 00:13:18,159 world from in and around the early nineties through in 199 00:13:18,519 --> 00:13:22,399 and around August tenth, twenty nineteen, when Epstein died of 200 00:13:22,440 --> 00:13:26,360 an apparent suicide. Thereafter two and including the date of 201 00:13:26,360 --> 00:13:30,279 this complaint, members of the sex trafficking venture continued to 202 00:13:30,360 --> 00:13:33,679 further the venture by concealing the activities and the extent 203 00:13:34,000 --> 00:13:37,679 of the venture. The manner of operation of for Epstein's 204 00:13:37,679 --> 00:13:42,279 particular sexual abuse and sex trafficking operation was widely publicized. 205 00:13:42,919 --> 00:13:45,639 He would lure young girls or women to one of 206 00:13:45,679 --> 00:13:48,679 his luxurious mansions under the guise of being a wealthy 207 00:13:48,720 --> 00:13:54,440 philanthropist able to advance careers, education, or provide other life necessities, 208 00:13:54,879 --> 00:13:58,279 and once inside, he would force his would be victim 209 00:13:58,440 --> 00:14:02,000 into providing a massage that would turn sexual, and from 210 00:14:02,000 --> 00:14:05,080 there he would cause each of the unsuspecting victims to 211 00:14:05,159 --> 00:14:09,919 engage in a variety of commercial sex acts. Once in 212 00:14:09,919 --> 00:14:12,720 his presence, each victim knew it was no option to 213 00:14:12,720 --> 00:14:17,000 disobey Epstein. It was well known and understood that he 214 00:14:17,080 --> 00:14:19,759 was one of the most powerful and connected people in 215 00:14:19,799 --> 00:14:23,200 the United States, able to help any of these young victims, 216 00:14:23,440 --> 00:14:27,440 and also capable and willing to hurt any of these victims. 217 00:14:28,759 --> 00:14:31,559 While the first sexual abuse was discovered to have likely 218 00:14:31,559 --> 00:14:33,840 occurred in the early nineties with the use of his 219 00:14:33,879 --> 00:14:37,840 then paramour, Glenn Maxwell. His appetite for sexually abusing young 220 00:14:37,879 --> 00:14:41,639 women and girls grew over the years. By two thousand, 221 00:14:41,840 --> 00:14:44,759 each victim was being directed to bring other victims and 222 00:14:44,840 --> 00:14:49,519 being paid handsomely in cash for recruiting other victims. The 223 00:14:49,639 --> 00:14:54,039 Florida Criminal Investigation uncovered that epstein sex trafficking operation grew 224 00:14:54,080 --> 00:14:57,879 its number of victims exponentially in the late nineties and 225 00:14:58,000 --> 00:15:02,519 early two thousands. One major reason why epstein sex trafficking 226 00:15:02,600 --> 00:15:05,879 venture accumulated new victims at an alarming rate in the 227 00:15:05,960 --> 00:15:09,519 late nineties and accelerating even faster by two thousand was 228 00:15:09,559 --> 00:15:14,559 his access to unlimited amounts of cash. Without exorbitantly large 229 00:15:14,600 --> 00:15:18,240 amounts of cash, Epstein's operation could not run, as newly 230 00:15:18,279 --> 00:15:21,159 recruited victims were each paid hundreds of dollars in cash 231 00:15:21,200 --> 00:15:26,240 immediately after Epstein's sexually abused them as hush money. Each 232 00:15:26,320 --> 00:15:29,440 victim was also informed that she would be paid hundreds 233 00:15:29,480 --> 00:15:33,200 of dollars for each additional victims she recruited, and Epstein 234 00:15:33,240 --> 00:15:36,600 made good on that promise of large cash payments. The 235 00:15:36,759 --> 00:15:39,679 public documents and articles stemming from the two thousand six 236 00:15:39,799 --> 00:15:44,240 arrest made abundantly clear that Epstein was doling out thousands 237 00:15:44,240 --> 00:15:47,279 of dollars in cash every single day as hush money 238 00:15:47,320 --> 00:15:50,440 to victims he was sexually abusing, and to victims he 239 00:15:50,519 --> 00:15:55,679 was using to recruit additional victims. If Epstein paid every 240 00:15:55,759 --> 00:15:59,120 victim with wire transfers and left a documented money trail, 241 00:15:59,480 --> 00:16:02,720 his illegal sexual abuse in sex trafficking operation would have 242 00:16:02,759 --> 00:16:07,039 been easily uncovered. However, with access to unlimited amounts of cash, 243 00:16:07,279 --> 00:16:12,159 Epstein was able to commit ogregious sexual crimes many times 244 00:16:12,159 --> 00:16:16,080 a day without leaving a paper trail. The constant expansion 245 00:16:16,080 --> 00:16:19,639 of sexual abuse and sex trafficking victims required cash on 246 00:16:19,759 --> 00:16:22,639 hand for Epstein to pay each victim as hush money 247 00:16:22,720 --> 00:16:25,360 for the abuse she was suffering, as well as each 248 00:16:25,440 --> 00:16:30,159 victim's find your fee for bringing another victim. Because Epstein's 249 00:16:30,240 --> 00:16:33,200 vast wealth, said to have been more than a billion dollars, 250 00:16:33,480 --> 00:16:38,559 was maintained in seemingly legitimate financial institutions, he needed complicit 251 00:16:38,639 --> 00:16:43,120 financial institution that would allow large, regular cash withdrawals in 252 00:16:43,279 --> 00:16:47,320 order to operate his sex trafficking operation. In order to 253 00:16:47,399 --> 00:16:50,559 access the large amount of cash needed to maintain his 254 00:16:50,720 --> 00:16:53,840 active sexual abuse of young women. It was essential that 255 00:16:53,879 --> 00:16:57,879 the financial institution where he banked be complicit in his operation, 256 00:16:58,720 --> 00:17:01,720 and more specifically, that at Epstein's bank at a financial 257 00:17:01,720 --> 00:17:05,240 institution that would allow him to constantly withdraw cash from 258 00:17:05,240 --> 00:17:09,599 his accounts without following anti money laundering and reporting laws. 259 00:17:10,119 --> 00:17:12,640 To put it plainly, Epstein needed a bank that he 260 00:17:12,680 --> 00:17:16,079 knew was engaging in ilegal activity and did not care, 261 00:17:16,799 --> 00:17:19,279 because the bank only cared about the money that it 262 00:17:19,359 --> 00:17:24,279 was making from its relationship with Epstein. This scheme of 263 00:17:24,319 --> 00:17:27,680 paying victims to bring other victims work effectively because it 264 00:17:27,759 --> 00:17:31,240 not only allowed expansion through the recruitment of other victims 265 00:17:31,359 --> 00:17:34,319 in a pyramid scheme fashion, but it also allowed each 266 00:17:34,400 --> 00:17:38,519 victim the possibility to avoid future sexual abuse she could 267 00:17:38,519 --> 00:17:41,279 bring someone else who would get abused in her place. 268 00:17:42,920 --> 00:17:46,200 Epstein's aptitude as a sex trafficker and appetite as a 269 00:17:46,200 --> 00:17:49,799 sexual abuser did not suffer because of his Florida incarceration 270 00:17:50,079 --> 00:17:52,519 in two thousand and eight. Even while he was in 271 00:17:52,599 --> 00:17:56,640 jail in Florida, Epstein continued to sexually abuse young girls 272 00:17:56,799 --> 00:18:00,200 and women from his work release office. Once out of 273 00:18:00,279 --> 00:18:04,319 jail and off work release, Epstein continued to collect young 274 00:18:04,359 --> 00:18:08,119 women and lure them through force, fraud, or coercion into 275 00:18:08,160 --> 00:18:12,240 one of his mansions, primarily his townhouse located at nine 276 00:18:12,319 --> 00:18:15,519 East seventy first Street in New York, where he would 277 00:18:15,519 --> 00:18:19,519 sexually abuse each one. His sexual abuse and sex trafficking 278 00:18:19,519 --> 00:18:23,000 operation continued as it had in the past, although it 279 00:18:23,039 --> 00:18:27,319 became more elaborate, creating more phony companies, opening more bank accounts, 280 00:18:27,519 --> 00:18:31,200 with drawing excessive amounts of cash, and delivering money to 281 00:18:31,279 --> 00:18:35,920 victims through wires, payroll, direct deposits, and other means known 282 00:18:36,200 --> 00:18:39,680 to his financial institution as evidence of the continuation of 283 00:18:39,680 --> 00:18:42,880 his criminal sex trafficking scheme. As time went by, news 284 00:18:43,000 --> 00:18:46,440 articles and lawsuits continued to mount, and more information became 285 00:18:46,480 --> 00:18:50,319 publicly available that Epstein was continuing to abuse young women 286 00:18:50,759 --> 00:18:53,480 and was using professionals on his payroll to help him 287 00:18:53,480 --> 00:18:57,440 conceal his illegal activity and give them cover as a 288 00:18:57,440 --> 00:19:01,000 well connected money manager. As a red disted sex offender 289 00:19:01,079 --> 00:19:04,440 discovered to be sexually abusing multiple young girls each day 290 00:19:04,680 --> 00:19:08,200 through a pyramid type recruiting scheme that required the transfer 291 00:19:08,240 --> 00:19:12,640 of millions of dollars to continue the operation, a complicit 292 00:19:12,720 --> 00:19:17,599 bank became more important than ever, as is more detailed below. 293 00:19:17,759 --> 00:19:21,319 Defending JP Morgan work closely with Epstein through every step 294 00:19:21,359 --> 00:19:25,559 of Epstein's sex trafficking operations, expansion and growth in its 295 00:19:25,599 --> 00:19:29,680 most prolific of years between two thousand and twenty thirteen. 296 00:19:31,880 --> 00:19:36,480 The Trafficking Victims Protection Act the Trafficking Victims Protection Act 297 00:19:36,640 --> 00:19:41,880 TVPA outlaws sex trafficking activities that affect interstate or foreign 298 00:19:41,880 --> 00:19:45,480 commerce or take place within the territorial jurisdiction of the 299 00:19:45,559 --> 00:19:49,960 United States. It is to be construed broadly because it 300 00:19:50,000 --> 00:19:54,680 serves a remedial purpose and uses intentionally broad language. The 301 00:19:54,799 --> 00:19:59,680 TVPA forbids the following sex trafficking conduct a whoever knowingly 302 00:19:59,759 --> 00:20:03,519 won one in or affecting interstate, foreign commerce, or within 303 00:20:03,559 --> 00:20:14,359 the special maritime and territorial jurisdiction of the United States, recruits, entices, harbors, transports, provides, obtains, advertises, maintains, patronizes, 304 00:20:14,599 --> 00:20:19,200 or solicits by any means. A person or two benefits 305 00:20:19,200 --> 00:20:23,119 financially or by receiving anything of value from participation in 306 00:20:23,200 --> 00:20:26,519 a venture which has engaged in an act described in 307 00:20:26,640 --> 00:20:30,480 violation of Paragraph one, knowing or accept where the act 308 00:20:30,559 --> 00:20:35,200 constituting the violation of paragraph is advertising in a reckless 309 00:20:35,200 --> 00:20:38,720 disregard of the fact that means of force, threats of force, 310 00:20:38,799 --> 00:20:43,319 fraud coercion described in Subsection E two, or any combination 311 00:20:43,400 --> 00:20:45,960 of such means, will be used to cause the person 312 00:20:46,200 --> 00:20:49,240 to engage in a commercial sex act, and that the 313 00:20:49,319 --> 00:20:52,240 person has not attained the age of eighteen years and 314 00:20:52,279 --> 00:20:54,839 will be caused to engage in a commercial sex act 315 00:20:55,119 --> 00:20:59,400 shall be punished as provided in sub Section B eighteen 316 00:20:59,519 --> 00:21:04,359 US Code Section fifteen ninety one A. The TVPA also 317 00:21:04,480 --> 00:21:08,359 contains an explicit civil remedy provision, which allows an individual 318 00:21:08,480 --> 00:21:11,240 who is a victim of a violation of Chapter seventy 319 00:21:11,279 --> 00:21:14,640 seven of Title eighteen to bring civil action against the 320 00:21:14,640 --> 00:21:19,519 perpetrator and any person or entity who knowingly benefits financially 321 00:21:19,920 --> 00:21:23,480 or by receiving anything of value from participation in an 322 00:21:23,519 --> 00:21:27,920 illegal sex trafficking venture. Unlike the criminal penalties provision in 323 00:21:27,960 --> 00:21:33,079 the TVPA, the civil remedies provision contains a constructive knowledge provision. 324 00:21:33,680 --> 00:21:36,559 This provision allows a civil action to be brought not 325 00:21:36,640 --> 00:21:40,039 only against a person or entity who participated in a 326 00:21:40,119 --> 00:21:43,680 venture known to have engaged in illegal sex trafficking, but 327 00:21:43,839 --> 00:21:47,440 also against a person or entity who participated in a 328 00:21:47,519 --> 00:21:50,400 venture that the person or entity should have known had 329 00:21:50,480 --> 00:21:55,160 engaged in illegal sex trafficking. This expanse of provision is 330 00:21:55,240 --> 00:21:59,160 known as the constructive knowledge provision, which provides an alternative 331 00:21:59,200 --> 00:22:03,240 to proving aca xtual knowledge as part of civil damage claims. 332 00:22:04,160 --> 00:22:07,119 In the paragraphs that follow, wherever, plaintiff alleges that the 333 00:22:07,160 --> 00:22:10,599 defendant acted with actual knowledge or in reckless disregard of 334 00:22:10,599 --> 00:22:13,720 the fact that the Epstein sex trafficking venture use means 335 00:22:13,759 --> 00:22:18,240 of force, threats of force, fraud, coercion, abusive process, or 336 00:22:18,279 --> 00:22:21,240 some combination thereof to cause a person to engage in 337 00:22:21,240 --> 00:22:25,000 commercial sex acts. The plaintiff also alleged that, at a 338 00:22:25,000 --> 00:22:28,440 bare minimum, the defendant should have known that Epstein's sex 339 00:22:28,440 --> 00:22:31,839 trafficking venture had used such means to engage in illegal 340 00:22:31,880 --> 00:22:36,359 sex trafficking in violation of US Code eighteen, Section fifteen 341 00:22:36,440 --> 00:22:39,400 ninety one through ninety four, i e. That they had 342 00:22:39,400 --> 00:22:43,599 constructive knowledge of Epstein's sex trafficking. All right, we're going 343 00:22:43,640 --> 00:22:45,640 to wrap up this episode right here, and in the 344 00:22:45,680 --> 00:22:48,680 next episode dealing with the topic, we're going to pick 345 00:22:48,759 --> 00:22:52,440 up with factual allegations. All of the information that goes 346 00:22:52,480 --> 00:22:55,799 with this episode can be found in the description box. 347 00:22:56,000 --> 00:22:58,559 What's up, everyone, and welcome to another episode of the 348 00:22:58,640 --> 00:23:01,400 Epstein Chronicles. In this episode, we're going to get right 349 00:23:01,480 --> 00:23:03,640 back to it and pick up where we left off 350 00:23:04,359 --> 00:23:11,200 with the survivor's lawsuit filed against JP Morgan. Factual allegations 351 00:23:12,000 --> 00:23:15,079 during all times relevant to this complaint, Jeffrey Epstein was 352 00:23:15,079 --> 00:23:19,359 an extraordinarily wealthy man with multiple residences in the United States, 353 00:23:19,599 --> 00:23:22,359 including a New York City mansion, a U Palm Beach mansion, 354 00:23:22,480 --> 00:23:27,119 and an island in the US Virgin Islands. Beginning in 355 00:23:27,160 --> 00:23:30,440 the early nineties and continuing through the summer of twenty nineteen, 356 00:23:30,640 --> 00:23:34,599 Jeffrey Epstein knowingly established and ran a sex trafficking venture 357 00:23:34,599 --> 00:23:38,200 in violation of US Code eighteen, Section fifteen ninety one 358 00:23:38,200 --> 00:23:41,400 through ninety five. As part of that venture, Epstein used 359 00:23:41,440 --> 00:23:44,640 means of force, threats of force, fraud, coercion, abuse, a 360 00:23:44,720 --> 00:23:47,759 legal process, and a combination of these means to cause 361 00:23:47,799 --> 00:23:50,119 young women and girls from all over the world to 362 00:23:50,240 --> 00:23:53,759 engage in commercial sex acts and to sexually abuse them. 363 00:23:54,200 --> 00:23:57,279 In creating and maintaining this network of victims in multiple 364 00:23:57,319 --> 00:23:59,960 states and in other countries, to sexually abuse and explore 365 00:24:00,519 --> 00:24:04,839 Epstein worked and conspired with others, including employees and dissociates, 366 00:24:05,039 --> 00:24:08,880 who facilitated his conduct by, among other things, recruiting victims, 367 00:24:09,079 --> 00:24:12,799 coercing victims, and scheduling their sexual abuse by Epstein at 368 00:24:12,799 --> 00:24:15,359 his New York mansion, his Palm Beach mansion, and his 369 00:24:15,440 --> 00:24:19,599 island in the US Virgin Islands. In this district and elsewhere, 370 00:24:19,759 --> 00:24:23,640 Epstein perpetuated this abuse in similar ways. Epstein and his 371 00:24:23,680 --> 00:24:28,119 co conspirators used Epstein's vast yet mysterious wealth and connections 372 00:24:28,119 --> 00:24:31,480 to other rich and powerful individuals to learn new victims 373 00:24:31,599 --> 00:24:36,200 into his home for seemingly innocuous activity. Victims were initially 374 00:24:36,200 --> 00:24:39,680 recruited to speak with an alleged philanthropic Epstein and provide 375 00:24:39,720 --> 00:24:42,640 massages to him. Once in the home and trapped in 376 00:24:42,640 --> 00:24:46,359 Epstein's bedroom, the victims would be instructed to remove their clothing. 377 00:24:46,960 --> 00:24:50,400 Epstein would then force the massages to become increasingly sexual 378 00:24:50,440 --> 00:24:54,720 in nature, typically including one or more four sex acts. 379 00:24:54,920 --> 00:24:57,599 Epstein would use the means of force, threats of force, 380 00:24:57,799 --> 00:25:00,759 or fraud to coerce the victims to pret dissipate in 381 00:25:00,839 --> 00:25:03,400 these sex acts and to cause them to return and 382 00:25:03,519 --> 00:25:07,880 continue to engage in commercial sex acts with them. Epstein 383 00:25:08,039 --> 00:25:11,039 and his associates then paid his victims hundreds of dollars 384 00:25:11,200 --> 00:25:16,359 in cash for each sexual encounter. Moreover, Epstein actively encouraged 385 00:25:16,400 --> 00:25:20,440 his victims to recruit additional girls to be similarly sexually abused, 386 00:25:20,680 --> 00:25:26,720 causing the number of victims to grow exponentially. Epstein incentivized 387 00:25:26,720 --> 00:25:30,519 his victims to become recruiters by paying these victim recruiters 388 00:25:30,599 --> 00:25:33,319 hundreds of dollars for each girl that they brought to Ebstein. 389 00:25:33,799 --> 00:25:36,519 In doing so, Epstein, through the system of paying victims 390 00:25:36,519 --> 00:25:39,279 to recruit others, whom he would also pay for being 391 00:25:39,279 --> 00:25:42,720 sexually abused as well as for recruiting, created a sexual 392 00:25:42,720 --> 00:25:46,319 abuse and sex trafficking spider web and maintained a steady 393 00:25:46,359 --> 00:25:50,839 supply of new victims to exploit. Epstein was skilled at 394 00:25:50,880 --> 00:25:54,880 ascertaining his victim's greatest fears and aspirations, and targeted those 395 00:25:54,880 --> 00:25:58,240 fears and aspirations to coerce and trap his victims into 396 00:25:58,279 --> 00:26:01,880 performing commercial sex acts and to be subject to sexual abuse, 397 00:26:02,799 --> 00:26:07,319 among other things. Epstein's sexually abused his many victims and 398 00:26:07,440 --> 00:26:10,759 caused his victims to engage in commercial sex acts, specifically 399 00:26:10,799 --> 00:26:13,799 sex acts for which his victims received things of value, 400 00:26:14,119 --> 00:26:18,839 including cash, promises of educational and career infatsment, and promises 401 00:26:18,880 --> 00:26:23,200 that Epstein would provide various forms of assistance. Epstein provided 402 00:26:23,240 --> 00:26:25,480 things of value to his victims in order to cause 403 00:26:25,519 --> 00:26:28,200 them to engage in sex acts with him and on occasion, 404 00:26:28,240 --> 00:26:32,160 his friends, co conspirators, or other victims. As one means 405 00:26:32,160 --> 00:26:35,039 of causing a victim to engage in commercial sex acts, 406 00:26:35,279 --> 00:26:38,480 Epstein and his co conspirators threatened that harm would come 407 00:26:38,480 --> 00:26:41,039 to victims if they did not comply with his demands 408 00:26:41,400 --> 00:26:44,920 that they perform commercial sex acts. As another means of 409 00:26:45,000 --> 00:26:48,319 causing victims to engage in commercial sex acts, Epstein and 410 00:26:48,319 --> 00:26:52,480 his co conspirators fraudulently promised to further victims educational or 411 00:26:52,480 --> 00:26:56,200 career aspirations if they would comply with his sexual demands. 412 00:26:56,720 --> 00:27:00,279 These promises were a quid pro quo for this sex 413 00:27:00,279 --> 00:27:03,519 acts that occurred. As one means of causing victims to 414 00:27:03,559 --> 00:27:06,880 engage in commercial sex acts, Epstein and his co conspirators 415 00:27:06,960 --> 00:27:09,519 would give his victims money to stay quiet about the 416 00:27:09,519 --> 00:27:13,640 assault or as a finder's fee for bringing other young women, 417 00:27:13,960 --> 00:27:18,759 or provide them with living accommodations, clothing, education, or other necessities. 418 00:27:19,440 --> 00:27:23,319 Throughout most of the nineties through about July twenty nineteen, 419 00:27:23,599 --> 00:27:29,799 the Epstein sex trafficking venture recruited, solicited, enticed, harbored, obtained, provided, 420 00:27:30,000 --> 00:27:33,920 and transported hundreds of victims to cause them to engage 421 00:27:33,960 --> 00:27:38,079 in commercial sex acts with Epstein and Epstein's friends. In 422 00:27:38,119 --> 00:27:40,960 two thousand and six, Jeffrey Epstein was arrested in Florida 423 00:27:41,200 --> 00:27:44,319 after state and federal law enforcement discovered he had sexually 424 00:27:44,319 --> 00:27:49,279 abused more than thirty children in Palm Beach. During that investigation, 425 00:27:49,519 --> 00:27:52,680 it was concluded that Epstein and his co conspirators had 426 00:27:52,680 --> 00:27:56,559 committed federal criminal acts constituting violations of US Code eighteen, 427 00:27:56,680 --> 00:27:59,160 Section twenty four to twenty two B twenty four to 428 00:27:59,200 --> 00:28:01,519 twenty two to two, twenty four to twenty three, F 429 00:28:01,880 --> 00:28:04,880 twenty four twenty three B twenty four to twenty four E. 430 00:28:05,279 --> 00:28:09,519 US Code eighteen, Section three seventy one, US Code eighteen 431 00:28:09,599 --> 00:28:13,000 Section fifteen ninety one C to one and fifteen ninety 432 00:28:13,039 --> 00:28:16,160 one A and one and two, as well as state 433 00:28:16,200 --> 00:28:19,920 crimes and violation of Florida Statute seven ninety six dot 434 00:28:20,000 --> 00:28:23,519 oh seven and seven ninety six dot three against dozens 435 00:28:23,680 --> 00:28:27,799 of young women as a consequence of the Florida investigation, 436 00:28:28,079 --> 00:28:31,559 Epstein pled guilty to two felonies, was permanently labeled a 437 00:28:31,640 --> 00:28:35,119 registered sex offender, and was jailed in two thousand and eight. 438 00:28:36,279 --> 00:28:39,519 Epstein's criminal case in Florida and the many related news 439 00:28:39,559 --> 00:28:43,160 reports left no doubt about Jeffrey Epstein and his extraordinary 440 00:28:43,160 --> 00:28:46,519 pension for sexual abuse and the trafficking of young females. 441 00:28:47,119 --> 00:28:49,799 For instance, it was revealed that until the time of 442 00:28:49,799 --> 00:28:52,960 his Florida arrest, Jeffrey Epstein was sexually abusing three to 443 00:28:53,000 --> 00:28:55,920 four young girls per day. It was a full time 444 00:28:56,000 --> 00:28:59,119 job for him. Beginning with the Florida arrest and for 445 00:28:59,240 --> 00:29:02,480 years moving forward, Epstein was embroiled in dozens of public 446 00:29:02,559 --> 00:29:06,640 lawsuits pertaining to his sexual abuse of females, and hundreds, 447 00:29:06,839 --> 00:29:10,680 if not thousands, of new story circulated worldwide about his 448 00:29:10,799 --> 00:29:15,319 illegal sexual proclivities. In addition to the many civil lawsuits 449 00:29:15,440 --> 00:29:19,559 seeking damages for sexual abuse, Epstein's victims also filed a 450 00:29:19,559 --> 00:29:23,200 public lawsuit against the US under US Code Section thirty 451 00:29:23,240 --> 00:29:27,400 seven seventy one the Crime Victims Rights Act CVRA, further 452 00:29:27,480 --> 00:29:31,000 exposing Epstein's sexual crimes, as well as a secret non 453 00:29:31,039 --> 00:29:39,279 prosecution agreement he entered into with the federal government. Epstein recruited, solicited, enticed, harbored, obtained, provided, 454 00:29:39,519 --> 00:29:42,160 and transported his victims to cause them to engage in 455 00:29:42,160 --> 00:29:45,519 commercial sex acts in ways that were in and affecting 456 00:29:45,559 --> 00:29:49,799 interstate and foreign commerce, including using means of interstate communication 457 00:29:50,079 --> 00:29:53,480 such as cellular telephones, and means of interstate and foreign 458 00:29:53,559 --> 00:29:57,559 travel such as aircraft that he owned and controlled. Epstein 459 00:29:57,599 --> 00:30:01,039 transported his victims in interstate and foreign cosme commerce, including 460 00:30:01,039 --> 00:30:05,799 transportation to and from his mansion in this district. The 461 00:30:05,839 --> 00:30:10,240 Epstein sex Trafficking Venture transported victims across state boundaries between 462 00:30:10,279 --> 00:30:14,519 New York, Florida, New Mexico, New Jersey, Massachusetts, and the 463 00:30:14,599 --> 00:30:18,440 US Virgin Islands and elsewhere, and in foreign commerce the places, 464 00:30:18,720 --> 00:30:22,599 especially Eastern Europe. At all times relevant to this complaint, 465 00:30:22,920 --> 00:30:25,839 Epstein's sex trafficking Venture was a group of two or 466 00:30:25,880 --> 00:30:29,160 more individuals associated in fact, even if they were not 467 00:30:29,240 --> 00:30:33,079 a formal legal entity. Indeed, members of the Epstein Sex 468 00:30:33,079 --> 00:30:37,960 Trafficking Venture referred to it as the organization. On July 469 00:30:38,079 --> 00:30:41,240 TEWO twenty nineteen, the US Attorney's Office for a Southern 470 00:30:41,240 --> 00:30:44,079 District of New York filed the sealed to count indictment 471 00:30:44,119 --> 00:30:48,160 against Epstein, including one count of sex trafficking conspiracy and 472 00:30:48,200 --> 00:30:51,720 one count of sex trafficking for violation of US Code eighteen, 473 00:30:51,799 --> 00:30:55,160 section fifteen ninety one, in part due to Epstein's criminal 474 00:30:55,160 --> 00:30:58,480 activity in his New York mansion located at nine E 475 00:30:58,640 --> 00:31:03,039 seventy first Street. On July eighth, twenty nineteen, Jeffrey Epstein 476 00:31:03,119 --> 00:31:06,960 was arrested pursued into the New York indictment. On August tenth, 477 00:31:07,079 --> 00:31:11,240 twenty nineteen, prison guards found Epstein on responsive at Metropolitan 478 00:31:11,240 --> 00:31:14,720 Correctional Center jel Cell, where he was awaiting trial on 479 00:31:14,799 --> 00:31:18,319 the federal sex trafficking charges. He was later pronounced dead 480 00:31:18,480 --> 00:31:23,519 from apparent suicide. In July of twenty twenty, Epstein's co 481 00:31:23,519 --> 00:31:28,200 conspirator in the Origin and the Sex Trafficking venture, Glenn Maxwell, 482 00:31:28,480 --> 00:31:32,079 was arrested on federal sex trafficking charges filed in this court. 483 00:31:32,759 --> 00:31:36,839 The charges alleged that she had assisted, facilitated, and contributed 484 00:31:36,839 --> 00:31:41,359 to Epstein's abuse of sex trafficking victims, helping Epstein to recruit, 485 00:31:41,400 --> 00:31:45,680 groom and ultimately abuse his victims. On December twenty ninth, 486 00:31:45,720 --> 00:31:48,720 twenty twenty one, Maxwell was found guilty in this Court 487 00:31:49,039 --> 00:31:52,440 on five federal sex trafficking counts in this court and 488 00:31:52,519 --> 00:31:55,279 is now serving close to twenty years in federal prison 489 00:31:55,480 --> 00:32:00,000 for these crimes. Consistent with his uniform pattern and practice, 490 00:32:00,440 --> 00:32:03,440 Jane do One was forced to engage in commercial sex 491 00:32:03,440 --> 00:32:06,920 acts with Epstein by means of force, fraud, and coercion. 492 00:32:08,079 --> 00:32:10,160 Jane do One was living with her mother when she 493 00:32:10,160 --> 00:32:12,960 met Jeffrey Epstein in two thousand and six. Jane do 494 00:32:13,119 --> 00:32:15,880 One was a ballet dancer in New York when she 495 00:32:16,000 --> 00:32:19,039 was recruited to meet Jeffrey Epstein by another young female 496 00:32:19,160 --> 00:32:22,480 who had also fallen prey to Jeffrey Epstein's sex trafficking scheme. 497 00:32:23,279 --> 00:32:28,319 Epstein and his co conspirators had a long history of grooming, indoctrinating, controlling, 498 00:32:28,559 --> 00:32:32,920 and ultimately committing sexual offenses against young, vulnerable women like 499 00:32:33,000 --> 00:32:37,720 Jane do One. Epstein and his co conspirators constantly reminded 500 00:32:37,799 --> 00:32:41,720 Jane do One how powerful and important Epstein was. Jane 501 00:32:41,799 --> 00:32:45,200 do One was chastised if she refused Epstein's sexual demands 502 00:32:45,359 --> 00:32:48,240 and told she should be grateful that Epstein was willing 503 00:32:48,279 --> 00:32:51,799 to help her with her career and education. She came 504 00:32:51,839 --> 00:32:55,400 to believe what she was told the well oiled Epstein's 505 00:32:55,400 --> 00:32:58,880 sex abuse and trafficking venture included frequent statements to Jane 506 00:32:58,920 --> 00:33:01,960 do One and other victims by Jeffrey Epstein and his 507 00:33:02,000 --> 00:33:07,079 co conspirators that won Jeffrey Epstein possessed extraordinary wealth, power, 508 00:33:07,319 --> 00:33:12,359 and influence. Two Jeffrey Epstein's businesses and political friends, including 509 00:33:12,440 --> 00:33:15,480 world leaders, also included some of the most powerful people 510 00:33:15,480 --> 00:33:19,079 in the world. Jeffrey Epstein had the ability to advance 511 00:33:19,319 --> 00:33:25,720 or destroy nearly anyone financially, reputationally, and otherwise. Four medical 512 00:33:25,759 --> 00:33:29,079 and normal life necessities would be denied victims if they, 513 00:33:29,160 --> 00:33:32,759 including Jane do One, failed to perform commercial sex acts 514 00:33:32,759 --> 00:33:36,880 for Epstein, and five Epstein could take away Jane do 515 00:33:37,000 --> 00:33:40,559 One and other victims life needs such as shelter, warhousing, 516 00:33:41,000 --> 00:33:43,799 if she or they failed to perform these sex acts. 517 00:33:44,359 --> 00:33:47,920 Jane do One was exceptionally vulnerable to being victimized by Epstein. 518 00:33:48,319 --> 00:33:52,039 His sex trafficking venture targeted vulnerable young women, and Jane 519 00:33:52,119 --> 00:33:56,039 do One was soon indoctrinated and unable to extricate herself. 520 00:33:56,720 --> 00:33:59,440 Jane do One was sexually abused in traffic by Epstein 521 00:33:59,599 --> 00:34:03,319 for self years, having been conditioned that the sexual abuse 522 00:34:03,400 --> 00:34:07,640 was normal and knowing that everyone surrounding Epstein, including accountants, lawyers, 523 00:34:07,960 --> 00:34:10,519 and other important people, were aware of the sex abuse, 524 00:34:10,800 --> 00:34:14,840 Jane do One was coerced into occult like life, controlled 525 00:34:14,840 --> 00:34:19,360 and manipulated by Epstein and others doing Epstein's bidding. Over 526 00:34:19,440 --> 00:34:22,280 the ensuing years from two thousand and six to twenty thirteen, 527 00:34:22,559 --> 00:34:25,519 Epstein sexually abused Jane do One on a number of 528 00:34:25,559 --> 00:34:30,559 occasions and direct violation of New York Penal Law one thirty, 529 00:34:30,599 --> 00:34:35,000 including sexual misconduct as defined in one thirty dot twenty 530 00:34:35,800 --> 00:34:39,119 inasmuch as Jeffrey Epstein engaged in sexual intercourse with plaintiff 531 00:34:39,239 --> 00:34:42,519 without plaintiff's consent. B Rape in the first degree is 532 00:34:42,519 --> 00:34:46,599 defined in one thirty dot thirty five. See criminal sexual 533 00:34:46,599 --> 00:34:48,960 act in the first degree as defined in one thirty 534 00:34:49,000 --> 00:34:53,000 dot fifty D. Forcible touching as defined in one thirty 535 00:34:53,039 --> 00:34:57,039 dot fifty two E. Sexual abuse in the third degree 536 00:34:57,159 --> 00:35:01,079 is defined in one thirty dout sixty six. Jane Doe 537 00:35:01,159 --> 00:35:04,559 One was also traffied to Jeffrey Epstein's friends for commercial 538 00:35:04,559 --> 00:35:08,400 sex acts. In this district, Epstein used means of force, 539 00:35:08,559 --> 00:35:12,239 threats of force, fraud, coercion, abusive process, and a combination 540 00:35:12,320 --> 00:35:15,239 of such means to cause Jane doe One to engage 541 00:35:15,440 --> 00:35:19,559 in commercial sex acts. Epstein recruited Jane do One, the causer, 542 00:35:19,639 --> 00:35:23,440 to engage in commercial sex acts in ways that were 543 00:35:23,639 --> 00:35:27,039 and in affecting interstate and foreign commerce, including the use 544 00:35:27,079 --> 00:35:30,760 of cellular telephones and means of interstate transportation such as 545 00:35:30,800 --> 00:35:33,639 aircraft that he owned were controlled. All right, folks, we're 546 00:35:33,639 --> 00:35:35,280 going to wrap up right there, and in the next 547 00:35:35,320 --> 00:35:37,360 episode dealing with the topic, we're going to pick up 548 00:35:37,360 --> 00:35:40,039 where we left off. All of the information that goes 549 00:35:40,079 --> 00:35:43,119 with this episode can be found in the description box.