1 00:00:00,040 --> 00:00:02,720 Speaker 1: What's up, everyone, and welcome to another episode of the 2 00:00:02,759 --> 00:00:05,799 Epstein Chronicles. In this episode, we're going to pick up 3 00:00:05,799 --> 00:00:09,759 where he left off with the survivor's lawsuit filed against 4 00:00:09,839 --> 00:00:14,279 JP Morgan. Epstein uses JP morgan accounts for the sex 5 00:00:14,320 --> 00:00:18,440 trafficking venture. Over the course of the relationship, Epstein and 6 00:00:18,480 --> 00:00:21,640 his representatives used JP Morgan accounts to send dozens of 7 00:00:21,640 --> 00:00:25,800 wires directly and indirectly to co conspirators in the sex 8 00:00:25,839 --> 00:00:30,120 trafficking venture. JP Morgan was aware that the recipients of 9 00:00:30,239 --> 00:00:33,719 some of these wire transfers described in the previous paragraph 10 00:00:33,920 --> 00:00:37,119 were to Epstein's co conspirators, and that the wire transfers 11 00:00:37,320 --> 00:00:41,119 were in furtherance of the Epstein sex trafficking venture. Epstein 12 00:00:41,240 --> 00:00:44,439 used JP Morgan accounts to pay for course commercial sex 13 00:00:44,799 --> 00:00:48,479 by Jane do One. Given JP Morgan's knowledge about Epstein's 14 00:00:48,479 --> 00:00:52,520 past sex trafficking, its continuation of its financial relationship with 15 00:00:52,560 --> 00:00:55,840 Epstein was at a minimum in reckless disregard of the 16 00:00:55,880 --> 00:00:59,240 fact that Epstein was using means of force, threats of 17 00:00:59,280 --> 00:01:02,600 force for all coercion, and a combination of such means 18 00:01:02,840 --> 00:01:06,280 to cause Epstein's victims to engage in commercial sex acts. 19 00:01:06,840 --> 00:01:09,719 In addition to actual knowledge that it was facilitating the 20 00:01:09,719 --> 00:01:15,040 Epstein sex trafficking venture. JP Morgan benefited financially by participating 21 00:01:15,239 --> 00:01:17,799 in the venture that it should have known had engaged 22 00:01:17,840 --> 00:01:21,359 in coercive sex trafficking in violation of US Code eighteen, 23 00:01:21,439 --> 00:01:26,280 Section fifteen ninety one A. If a financial institution decides 24 00:01:26,319 --> 00:01:29,319 to do business with a high risk client, that institution 25 00:01:29,480 --> 00:01:32,799 is required to conduct due diligence, commeasure it with the risk, 26 00:01:33,079 --> 00:01:36,799 and to tailor its transaction monitoring to detect suspicious or 27 00:01:36,840 --> 00:01:42,799 unlawful activity based on what the risk is. JP Morgan knowingly, intentionally, deliberately, 28 00:01:43,000 --> 00:01:45,959 and maliciously failed to do so. With regard to its 29 00:01:46,000 --> 00:01:50,599 relationship with Epstein, the bank was well aware not only 30 00:01:50,599 --> 00:01:53,239 that Epstein had pled guilty and serve prison time for 31 00:01:53,319 --> 00:01:56,079 engaging in sex with a minor, but also that there 32 00:01:56,079 --> 00:02:00,000 were public allegations that his conduct was facilitated by sex 33 00:02:00,000 --> 00:02:03,959 several named co conspirators. Despite this knowledge of the bank 34 00:02:04,000 --> 00:02:07,439 did little or nothing to inquire into or block numerous 35 00:02:07,439 --> 00:02:11,159 payments to name co conspirators and two or on behalf 36 00:02:11,240 --> 00:02:14,520 of numerous young women, or to inquire how Epstein was 37 00:02:14,599 --> 00:02:17,840 using hundreds of thousands of dollars in cash per year. 38 00:02:18,120 --> 00:02:22,240 Hush money, financial compensation or recruiters, and compensation of victims 39 00:02:22,400 --> 00:02:26,479 was integral Dapstein's scheme, without which his sex trafficking operation 40 00:02:26,800 --> 00:02:30,680 could not exist. The ability to obtain exorbitant amounts of 41 00:02:30,680 --> 00:02:34,199 money and wires to young females and obtain unlimited cash 42 00:02:34,520 --> 00:02:38,520 was critical of de Epstein's operation. Suspicious wire transfers and 43 00:02:38,560 --> 00:02:42,240 withdrawals of millions of dollars in cash are basic hallmarks 44 00:02:42,360 --> 00:02:45,840 of any major criminal enterprise. A bank that would allow 45 00:02:45,879 --> 00:02:49,759 Epstein to operate in this blatant criminal fashion was necessary 46 00:02:50,159 --> 00:02:52,960 for the growth of his trafficking operation and for the 47 00:02:53,000 --> 00:02:57,879 continued abuse of hundreds of young women. Before JP Morgan 48 00:02:58,039 --> 00:03:01,800 facilitated Epstein's operation with aout question, Epstein was able to 49 00:03:01,840 --> 00:03:05,599 abuse young women sporadically and in fear of being caught. 50 00:03:06,400 --> 00:03:10,159 JP Morgan eliminated that fear, making sure that the suspicious 51 00:03:10,159 --> 00:03:13,599 money trail that would unveil Epstein's operation as the criminal 52 00:03:13,639 --> 00:03:16,479 sexual abuse machine that it was, would be covered up 53 00:03:16,800 --> 00:03:19,759 and would lead to his downfall. The negligence of JP 54 00:03:19,840 --> 00:03:23,960 Morgan is clear. The complicity, though far extended, negligence as 55 00:03:24,039 --> 00:03:27,319 JP Morgan acted with a high degree of moral turpitude 56 00:03:27,520 --> 00:03:31,120 and demonstrated such wanton dishonesty as to imply a criminal 57 00:03:31,120 --> 00:03:36,319 indifference to civil obligations, and JP Morgan also acted outrageously 58 00:03:36,639 --> 00:03:41,039 and intentionally. JP Morgan knew Epstein had no college degree, 59 00:03:41,319 --> 00:03:45,199 no ongoing legitimate business, and was engaging in sexual abuse 60 00:03:45,479 --> 00:03:49,479 of females on a daily basis. JP Morgan recognized its 61 00:03:49,479 --> 00:03:53,400 importance to Ebstein as the exclusive financial institution that was 62 00:03:53,439 --> 00:03:57,159 willing to allow Epstein to engage in obvious criminal financial 63 00:03:57,199 --> 00:04:01,639 activities to fund his sex trafficking venture. JP Morgan, acting 64 00:04:01,639 --> 00:04:05,000 through Staley, was a criminal co conspirator of the operation. 65 00:04:05,919 --> 00:04:09,479 There came a time when JP Morgan absolutely knew Epstein 66 00:04:09,560 --> 00:04:13,159 was running a sex trafficking venture, and JP Morgan chose 67 00:04:13,199 --> 00:04:16,480 to remain Epstein's banking partner to receive financial benefits in 68 00:04:16,519 --> 00:04:21,600 exchange for ensuring the ventures continued operation. In order to 69 00:04:21,600 --> 00:04:24,120 make hundreds of millions of dollars off of Epstein and 70 00:04:24,160 --> 00:04:29,079 his contacts, JP Morgan facilitated Epstein's sex trafficking network, which 71 00:04:29,199 --> 00:04:31,800 caused billions of dollars in damages from the pain and 72 00:04:31,839 --> 00:04:36,839 suffering of hundreds of Epstein's sexual abuse and sex trafficking victims. 73 00:04:37,079 --> 00:04:41,600 JP Morgan's desire to maintain its profitable relationship with Epstein 74 00:04:42,120 --> 00:04:44,879 let it avoid taking steps that would have documented its 75 00:04:44,920 --> 00:04:50,600 involvement in Epstein's sex trafficking venture the statute of limitations. 76 00:04:51,279 --> 00:04:54,759 The statute of limitations under the TVPA is ten years 77 00:04:54,800 --> 00:04:57,600 after the cause of action arose, or ten years after 78 00:04:57,639 --> 00:05:00,839 the victim reaches eighteen years of age if the victim 79 00:05:00,959 --> 00:05:03,079 was a minor at the time of the alleged defense. 80 00:05:03,759 --> 00:05:07,040 The TVPA causes of action for Jane do One and 81 00:05:07,160 --> 00:05:10,360 other class members all arose within ten years of the 82 00:05:10,399 --> 00:05:13,800 filing of this complaint. The New York Adult Survivors Act 83 00:05:14,000 --> 00:05:16,519 has opened up a one year revival window for the 84 00:05:16,519 --> 00:05:21,920 statute of limitations class action allegations. Plaintiff Chang do One 85 00:05:22,160 --> 00:05:25,399 brings this action pursuant to Federal Rule of Civil Procedure 86 00:05:25,439 --> 00:05:28,920 twenty three B three twenty three C four on behalf 87 00:05:28,959 --> 00:05:32,079 of themselves and the following class all women who are 88 00:05:32,079 --> 00:05:35,680 sexually trafficked by Jeffrey Epstein during the time when JP 89 00:05:35,839 --> 00:05:40,160 Morgan maintained bank accounts for Epstein and or Epstein related entities, 90 00:05:40,519 --> 00:05:43,199 which was in or about two thousand through in or 91 00:05:43,240 --> 00:05:48,360 about August of twenty thirteen, both dates inclusive the class period. 92 00:05:48,959 --> 00:05:52,720 Plaintiff reserves the right to seek leave to modify the definition, 93 00:05:53,000 --> 00:05:55,920 including the addition of one or more sub classes, after 94 00:05:55,959 --> 00:06:01,639 having the opportunity to conduct discovery. The class consists of 95 00:06:01,680 --> 00:06:06,600 dozens of women, making joinder impracticable in satisfaction of Federar civp. 96 00:06:06,759 --> 00:06:09,720 Twenty three one. The exact size of the class and 97 00:06:09,800 --> 00:06:14,000 the identities of the individual class members are ascertainable through 98 00:06:14,079 --> 00:06:17,759 records maintained by the Epstein Estate and the defendant, including 99 00:06:17,800 --> 00:06:20,360 but not limited to J. P. Morgan's records for Epstein's 100 00:06:20,360 --> 00:06:25,240 related accounts account ledgers reflecting payments from Epstein to class members. 101 00:06:26,319 --> 00:06:29,959 Typicality Plaintiff's claims are typical of the claims of the 102 00:06:30,000 --> 00:06:32,800 other class members she seeks to represent. The claims of 103 00:06:32,800 --> 00:06:35,680 plaintiff and the other class members are based on the 104 00:06:35,720 --> 00:06:38,959 same legal theories and arise from the same unlawful pattern 105 00:06:39,040 --> 00:06:43,079 and practice of Defendant's participation in and funding of the 106 00:06:43,120 --> 00:06:48,519 Epstein's sexual abuse and Epstein's sex trafficking venture. Commonality, there 107 00:06:48,560 --> 00:06:50,959 are many questions of law and fact common to the 108 00:06:51,000 --> 00:06:53,879 claims of plaintiff and the other class members, and those 109 00:06:53,959 --> 00:06:58,439 questions predominate over any questions that may affect only individual 110 00:06:58,480 --> 00:07:02,680 class members within the meaning of FEDERCIVP. Class Treatment of 111 00:07:02,720 --> 00:07:08,120 common issues under fediarcivp. Twenty three. Common questions of fact 112 00:07:08,120 --> 00:07:11,160 and law affecting class members include, but are not limited to, 113 00:07:11,199 --> 00:07:15,160 the following. Whether the Epstein sex trafficking venture caused its 114 00:07:15,240 --> 00:07:18,720 victim to engage in commercial sex acts in violation of 115 00:07:18,720 --> 00:07:22,680 the Trafficking Victims Protection Act. Whether the Epstein sex trafficking 116 00:07:22,800 --> 00:07:28,199 venture recruited, entice, solicited, harbored, provided, obtained, and transported victims 117 00:07:28,199 --> 00:07:32,199 in ways that were in or affecting interstate or foreign commerce. 118 00:07:32,800 --> 00:07:36,800 Whether Epstein and his co conspirators use means of force, fraud, coercion, 119 00:07:37,079 --> 00:07:39,879 and abuse of legal process, or a combination of such 120 00:07:39,959 --> 00:07:43,319 means to sexually abuse the victims and to cause victims 121 00:07:43,360 --> 00:07:47,560 to engage in commercial sex acts. Whether JP Morgan knowingly 122 00:07:47,759 --> 00:07:52,160 and intentionally assisted, facilitated, and supported the Epstein sex trafficking 123 00:07:52,240 --> 00:07:56,360 venture pattern and practice of coercively forcing victims to engage 124 00:07:56,480 --> 00:08:00,519 in commercial sex acts. Whether JP Morgan benefited by financially 125 00:08:00,839 --> 00:08:03,600 or by receiving things of value, from its participation in 126 00:08:03,639 --> 00:08:06,879 a venture which has engaged in sex trafficking in violation 127 00:08:07,000 --> 00:08:11,000 of TVPA, Whether JP Morgan knew or should have known 128 00:08:11,199 --> 00:08:14,959 that Epstein's sex trafficking venture had engaged in violations of 129 00:08:15,040 --> 00:08:20,040 the TVPA, Whether JP Morgan committed negligent acts or omissions 130 00:08:20,160 --> 00:08:24,000 that facilitated sexual abuse which would constitute a sexual offense 131 00:08:24,240 --> 00:08:27,120 as defined in Article one hundred and thirty of the 132 00:08:27,160 --> 00:08:30,720 Penal Law committed against such persons who were eighteen years 133 00:08:30,720 --> 00:08:34,720 of age or older. Apsent a class action, Most of 134 00:08:34,720 --> 00:08:37,039 the class members would find the cost of litigating their 135 00:08:37,080 --> 00:08:40,759 claims to be cost prohibitive and will have no effective remedy. 136 00:08:41,360 --> 00:08:44,639 The class treatment of common questions of law and fact 137 00:08:44,960 --> 00:08:49,000 is also superior to multiple individual actions or piecemeal litigation 138 00:08:50,200 --> 00:08:52,799 in that it conserves the resources of the courts and 139 00:08:52,840 --> 00:08:58,679 the litigants, and promotes consistency and efficiency of adjudication adequacy. 140 00:08:59,039 --> 00:09:02,559 Jane I will fairly and adequately represent and protect the 141 00:09:02,559 --> 00:09:06,240 interests of the other class members she seeks to represent. Change. 142 00:09:06,279 --> 00:09:10,200 No one has retained counsel with substantial experience in prosecuting 143 00:09:10,240 --> 00:09:14,440 complex litigation and class actions. Plaintiff and our counselor are 144 00:09:14,440 --> 00:09:18,440 committed to vigorously prosecuting this action on behalf of the 145 00:09:18,519 --> 00:09:22,159 other class members, and have the financial resources to do so. 146 00:09:22,559 --> 00:09:25,960 Neither plaintiff nor a council have any interests adverse to 147 00:09:26,000 --> 00:09:29,759 those of the other class members. This action has been 148 00:09:29,799 --> 00:09:32,919 brought and may properly be maintained as a class action 149 00:09:33,200 --> 00:09:36,080 against the defendant pursuant to Rule twenty three of the 150 00:09:36,120 --> 00:09:39,440 Federal Rules of Civil Procedure. Because there is a well 151 00:09:39,480 --> 00:09:42,960 defined community of interest in the litigation and the proposed 152 00:09:42,960 --> 00:09:48,279 class is easily ascertainable from defendant records, a class action 153 00:09:48,399 --> 00:09:51,399 is superior to all other available methods for the fair 154 00:09:51,960 --> 00:09:56,120 adjudication of this controversy. Because a joinder of the class 155 00:09:56,320 --> 00:10:01,039 members is impracticable. The prosecution of individuals remedies by members 156 00:10:01,039 --> 00:10:04,320 of the class will tend to establish inconsistent standards of 157 00:10:04,399 --> 00:10:07,399 conduct for defendant and result in the impairment of class 158 00:10:07,399 --> 00:10:11,080 members' rights and the disposition of their interests through actions 159 00:10:11,080 --> 00:10:14,399 to which they are not parties. Class action treatment will 160 00:10:14,399 --> 00:10:18,000 permit a large number of similarly situated persons to prosecute 161 00:10:18,039 --> 00:10:22,399 their common claim in a single forum, simultaneously, efficiently, and 162 00:10:22,440 --> 00:10:26,879 without the unnecessary duplication of effort and expense that numerous 163 00:10:26,919 --> 00:10:31,960 individual actions would engender. Absent a class action, class members 164 00:10:31,960 --> 00:10:35,200 will continue to suffer losses and be aggrieved, and defendant 165 00:10:35,240 --> 00:10:38,559 will continue to violate New York in federal law without remedy. 166 00:10:39,679 --> 00:10:42,679 Class treatment of this action will cause an orderly and 167 00:10:42,799 --> 00:10:47,039 expeditious administration of class claims. Economies of time, effort, and 168 00:10:47,080 --> 00:10:51,519 expense will be fostered, and uniformity of decision will be ensured. 169 00:10:52,120 --> 00:10:55,639 Plaintiffener council, or unaware of any class action brought against 170 00:10:55,639 --> 00:10:59,240 any defendant for the violations alleged in the action. The 171 00:10:59,360 --> 00:11:03,080 forum is desirable because defendant conducted the subject business with 172 00:11:03,200 --> 00:11:07,120 Jeffrey Epstein in this district and class members were consequently 173 00:11:07,159 --> 00:11:11,240 trafficked in this district. And this action presents no difficulty 174 00:11:11,519 --> 00:11:14,639 that would impede its management by the court as a 175 00:11:14,679 --> 00:11:18,279 class action. All right, We're going to wrap up right here, 176 00:11:18,399 --> 00:11:20,559 and in the next episode dealing with the topic, We're 177 00:11:20,559 --> 00:11:23,000 going to pick up where we left off. All of 178 00:11:23,000 --> 00:11:25,759 the information that goes with this episode can be found 179 00:11:26,080 --> 00:11:28,919 in the description box. What's up, everyone, and welcome to 180 00:11:28,960 --> 00:11:32,679 another episode of the Epstein Chronicles. In this episode, We're 181 00:11:32,679 --> 00:11:34,720 going to pick up where we left off with the 182 00:11:34,919 --> 00:11:40,000 lawsuit filed by the survivors against JP Morgan Causes of 183 00:11:40,039 --> 00:11:44,399 action Count one Intentional and negligent Acts and omissions under 184 00:11:44,440 --> 00:11:48,080 the New York Adult Survivors Act, New York CPLR. Section 185 00:11:48,360 --> 00:11:52,559 two fourteen J. Plaintiff Jane do One realleges and in 186 00:11:52,559 --> 00:11:55,639 corporates by paragraphs one through two thirty six, as if 187 00:11:55,679 --> 00:11:58,960 fully set forth in this count. Plaintiff Jang do One 188 00:11:59,000 --> 00:12:01,720 brings this count individual and on behalf of the other 189 00:12:01,759 --> 00:12:05,799 class members they respectfully seek to represent pursu into New 190 00:12:05,879 --> 00:12:08,759 York Civil Practice Law and Rules Section two fourteen J. 191 00:12:09,480 --> 00:12:13,279 This count for intentional and negligent Acts and omissions has 192 00:12:13,360 --> 00:12:16,279 been timely filed as every civil claim or cause of 193 00:12:16,320 --> 00:12:20,360 action brought against any party alleging intentional and negligent acts 194 00:12:20,519 --> 00:12:24,120 or omissions by a person for physical, psychological, or other 195 00:12:24,200 --> 00:12:27,399 injury or condition suffered as a result of conduct which 196 00:12:27,440 --> 00:12:30,960 would constitute a sexual offense as defined an Article one 197 00:12:31,039 --> 00:12:33,840 hundred and thirty of the Penal Law committed against such 198 00:12:33,919 --> 00:12:37,240 person who was eighteen years of age or older. Was 199 00:12:37,360 --> 00:12:42,240 revived effective November twenty fourth, twenty twenty two. Intentional and 200 00:12:42,279 --> 00:12:46,240 negligent actions and omissions committed by JP Morgan within this 201 00:12:46,360 --> 00:12:50,159 district and elsewhere directly and approximately resulted in sexual offenses 202 00:12:50,320 --> 00:12:53,480 by Epstein and his co conspirators. Under the laws of 203 00:12:53,519 --> 00:12:57,480 the State of New York. As a financial institution operating 204 00:12:57,519 --> 00:12:59,799 within this district and within the State of New York, 205 00:13:00,080 --> 00:13:03,000 JP Morgan owed legal duties to plaintiff Channg do one 206 00:13:03,240 --> 00:13:06,679 and the class members to exercise reasonable care to monitor 207 00:13:06,759 --> 00:13:10,519 JP Morgan's customers, including Jeffrey Epstein, for the purpose of 208 00:13:10,559 --> 00:13:15,039 preventing them from facilitating and engaging in foreseeable criminal activity 209 00:13:15,399 --> 00:13:18,720 using banks facilities that could harm the plaintiff and the 210 00:13:18,720 --> 00:13:22,600 class members. The legal duties of JP Morgan described in 211 00:13:22,639 --> 00:13:26,080 the two preceding paragraphs also extended to the other class 212 00:13:26,080 --> 00:13:29,960 members whom Plaintiff Jang do one seeks to represent. The 213 00:13:30,039 --> 00:13:33,559 legal duties of JP Morgan include, but are not limited to, 214 00:13:33,960 --> 00:13:37,960 following the Know Your Customer laws and related regulations described above. 215 00:13:38,799 --> 00:13:42,559 Under KYC laws, banks have special duties to inquire about 216 00:13:42,559 --> 00:13:46,440 possible crimes being committed by their customers, duties above and 217 00:13:46,480 --> 00:13:50,200 beyond any duties that the general public may have. The 218 00:13:50,240 --> 00:13:54,000 inquiries that banks must make include duties to inquire about 219 00:13:54,039 --> 00:13:57,919 specific individuals who are being harmed. The regulations established a 220 00:13:58,000 --> 00:14:01,360 duty of care that must be followed by banks, including 221 00:14:01,440 --> 00:14:05,200 JP Morgan. But for JP Morgan, Epstein could not have 222 00:14:05,240 --> 00:14:10,440 successfully run and expanded his sexual abuse organization. While would 223 00:14:10,519 --> 00:14:13,000 have wanted to sexually abuse women, he could not have 224 00:14:13,039 --> 00:14:16,279 abused hundreds of victims that he did without JP Morgan. 225 00:14:17,000 --> 00:14:19,639 JP Morgan breached its legal duties to plaintiff Chane do 226 00:14:19,759 --> 00:14:22,879 One and the class members by failing to discharge its 227 00:14:22,919 --> 00:14:26,200 legal duty to prevent Jeffrey Epstein and others from using 228 00:14:26,240 --> 00:14:30,600 the bank's facilities to facilitate and commit criminal activity harming 229 00:14:30,679 --> 00:14:34,639 Jane do One and the class members. The criminal activity 230 00:14:34,639 --> 00:14:38,039 that harm plaintiff and class members included for seeable federal 231 00:14:38,080 --> 00:14:42,120 crimes committed by the Epstein sex trafficking enterprise described above, 232 00:14:42,639 --> 00:14:46,200 as well as the state sex offense crimes. As a 233 00:14:46,200 --> 00:14:48,759 direct and proximate result of the breach of legal duties 234 00:14:48,799 --> 00:14:52,120 by JP Morgan, Plaintiff Jane do One and the class 235 00:14:52,120 --> 00:14:55,840 members repeatedly suffered for seeable injuries from Epstein and his 236 00:14:55,960 --> 00:15:00,960 co conspirators, including federal and state sexual offenses and resulting 237 00:15:01,000 --> 00:15:05,840 emotional distress, mental pain and suffering, and other physical, psychological, 238 00:15:06,000 --> 00:15:09,440 and other injuries. The breaches of legal duty were the 239 00:15:09,559 --> 00:15:13,879 direct ie the but for cause of these injuries. Without 240 00:15:13,960 --> 00:15:17,600 JP Morgan's breaches of its legal duties, those injuries would 241 00:15:17,600 --> 00:15:20,799 not have occurred. The breaches of legal duty were the 242 00:15:20,840 --> 00:15:25,879 direct ie but for cause of these injuries. Without defendant's 243 00:15:25,879 --> 00:15:29,159 breaches of legal duties, those injuries would not have occurred. 244 00:15:29,879 --> 00:15:33,399 The injuries that occurred were readily foreseeable by JP Morgan. 245 00:15:34,759 --> 00:15:37,320 The injuries at plaintiff Channg do one and the class 246 00:15:37,360 --> 00:15:41,159 members suffered included injuries directly and proximately suffered while there 247 00:15:41,159 --> 00:15:44,759 were adults who were present in this district. These injuries 248 00:15:44,759 --> 00:15:47,519 are permanent in nature, and Jane do One and other 249 00:15:47,559 --> 00:15:51,120 class members will continue to suffer these losses in the future. 250 00:15:52,240 --> 00:15:54,759 The injuries that plaintiff Chang Do one and the class 251 00:15:54,759 --> 00:15:59,000 members suffered included injuries directly and proximately suffered as a 252 00:15:59,039 --> 00:16:02,480 result of sex offense committed by Epstein and other co 253 00:16:02,480 --> 00:16:07,399 conspirators and criminalized under Article one thirty. The offenses included 254 00:16:07,440 --> 00:16:11,320 sexual intercourse without consent and oral sexual conduct without consent 255 00:16:11,600 --> 00:16:14,919 forbidden by New York Penal Law Section one thirty dot twenty. 256 00:16:15,720 --> 00:16:19,519 The offenses included forcible touching of sexual or other intimate 257 00:16:19,519 --> 00:16:22,879 parts without consent, forbidden by New York Penal Law Section 258 00:16:23,200 --> 00:16:26,720 one thirty dot twenty. The breaches of legal duties by 259 00:16:26,799 --> 00:16:30,279 JP Morgan proximately caused plaintiff Chang Do I and the 260 00:16:30,320 --> 00:16:33,759 class members to repeatedly suffer injuries from Epstein and his 261 00:16:33,879 --> 00:16:39,039 co conspirators, including sexual assaults and resulting emotional distress, mental 262 00:16:39,039 --> 00:16:43,480 pain and suffering, and other physical and psychological trauma. These 263 00:16:43,480 --> 00:16:47,399 injuries were easily foreseeable because JP Morgan knew and acted 264 00:16:47,440 --> 00:16:50,000 in reckless disregard of the fact that their actions and 265 00:16:50,039 --> 00:16:54,519 omissions supporting and facilitating Epstein would lead to, among other crime, 266 00:16:54,600 --> 00:16:58,600 sex offenses by Epstein and his co conspirators forbidden by 267 00:16:58,759 --> 00:17:01,399 Article one thirty of the New York Penal Law against 268 00:17:01,440 --> 00:17:04,359 the victims, including Jane do One and the class members. 269 00:17:05,359 --> 00:17:08,440 In the exercise of reasonable care, JP Morgan and its 270 00:17:08,440 --> 00:17:11,880 employees knew or should have known of the dangerous propensities 271 00:17:11,920 --> 00:17:14,960 of Jeffrey Epstein and the harm that would be caused 272 00:17:14,960 --> 00:17:18,480 by his likely sexual crimes and various violations of Article 273 00:17:18,519 --> 00:17:22,200 one thirty of the New York Penal Law. JP Morgan 274 00:17:22,240 --> 00:17:25,640 could reasonably foresee that its actions and omissions in facilitating 275 00:17:25,680 --> 00:17:29,720 Epstein's sex trafficking enterprise would lead to sex offenses against 276 00:17:29,799 --> 00:17:33,000 Jane do One and the class members, among other things. 277 00:17:33,039 --> 00:17:36,839 The defendant was specifically aware that Epstein had previously been 278 00:17:36,880 --> 00:17:41,319 prosecuted for similar sex crimes and previously paid numerous civil 279 00:17:41,359 --> 00:17:46,079 settlements associated with similar sex crimes. Indeed, the defendant was 280 00:17:46,119 --> 00:17:48,559 aware and should have been aware, that Epstein was a 281 00:17:48,640 --> 00:17:52,440 high risk to commit sex offenses against young women and girls. 282 00:17:53,440 --> 00:17:56,279 Plaintiff Chang do One and the class members were easily 283 00:17:56,319 --> 00:17:59,960 within the zone of foreseeable harm from JP Morgan's intentional 284 00:18:00,240 --> 00:18:05,000 and negligent acts and omissions. JP Morgan's intentional and negligent 285 00:18:05,039 --> 00:18:08,799 acts and omissions for seeably created substantial risk of Jeffrey 286 00:18:08,799 --> 00:18:12,000 Epstein and his co conspirators committing sex crimes against young 287 00:18:12,039 --> 00:18:15,480 women with whom he was in contact. Tragically, Jane do 288 00:18:15,599 --> 00:18:19,359 One and the Master class members fell within that zone. 289 00:18:19,400 --> 00:18:22,440 The sex offenses Jeffrey Epstein committed against Jane do One 290 00:18:22,720 --> 00:18:25,559 and the class members were easily within the zone of 291 00:18:25,640 --> 00:18:29,400 foreseeable risks that JP Morgan created with its intentionally and 292 00:18:29,440 --> 00:18:34,799 negligent actions and omissions. Those actions and omissions foreseeably risked 293 00:18:34,839 --> 00:18:38,119 further sex crimes by Jeffrey Epstein and his co conspirators, 294 00:18:38,400 --> 00:18:41,559 which is exactly and tragically the harm that he inflicted 295 00:18:41,920 --> 00:18:45,240 on Jane do One and the class members. While the 296 00:18:45,240 --> 00:18:48,960 foregoing allegations easily made out a clearer case of negligence, 297 00:18:49,440 --> 00:18:53,319 the case does not involve mere negligence. Instead, defendant's tortious 298 00:18:53,400 --> 00:18:56,960 conduct in this case evinced a high degree of moral 299 00:18:56,960 --> 00:19:01,279 tertitude and demonstrated such wanton dishonesty as to imply a 300 00:19:01,319 --> 00:19:06,200 criminal indifference to civil obligation. It also involved outrageous and 301 00:19:06,240 --> 00:19:09,519 intentional acts and omissions because it was a deliberate attempt 302 00:19:09,599 --> 00:19:13,079 to further the crimes of a widespread and dangerous criminal 303 00:19:13,079 --> 00:19:18,200 sex trafficking organization. Defendant's tortious conduct was directed specifically at 304 00:19:18,279 --> 00:19:20,720 Jane do One and the class members, who were the 305 00:19:20,839 --> 00:19:25,519 victims of Epstein's sexual abuse and sex trafficking organization. As 306 00:19:25,559 --> 00:19:28,839 a result of the intentional and negligent actions and omissions 307 00:19:28,839 --> 00:19:31,640 described in this count, Plaintiff Jang do One and the 308 00:19:31,680 --> 00:19:36,000 class members have sustained both general and specified damages in 309 00:19:36,039 --> 00:19:40,279 substantial amounts by virtue of acting intentionally, outrageously and with 310 00:19:40,319 --> 00:19:44,039 a high degree of moral tertitude, and demonstrating such wanton 311 00:19:44,039 --> 00:19:47,319 dishonesty as to imply a criminal indifference to civil obligation. 312 00:19:47,720 --> 00:19:50,640 Defendant is liable to Jane do One and other members 313 00:19:50,920 --> 00:19:55,359 of the class for punitive damages. Count two participating in 314 00:19:55,359 --> 00:19:59,079 a sex trafficking venture violation of the Trafficking Victims Protection 315 00:19:59,200 --> 00:20:02,720 Act US Code eighteen, section fifteen ninety one A and 316 00:20:02,759 --> 00:20:07,400 two fifteen ninety five. Plaintiff Chang do one realleges and 317 00:20:07,480 --> 00:20:11,000 incorporates by reference paragraphs one through two thirty six as 318 00:20:11,000 --> 00:20:14,160 a fully set fourth in this count. Plaintiff Chang do 319 00:20:14,240 --> 00:20:16,920 One brings this count individually and on behalf of the 320 00:20:16,960 --> 00:20:21,279 other class members she seeks to represent. JP Morgan knowingly 321 00:20:21,480 --> 00:20:25,920 and intentionally participated in, assisted, supported, and facilitated a sex 322 00:20:25,920 --> 00:20:29,839 trafficking venture that was in and affecting interstate and foreign commerce, 323 00:20:30,160 --> 00:20:34,119 together with others, in violation of US Code eighteen, section 324 00:20:34,359 --> 00:20:38,960 fifteen ninety one A two. JP Morgan knowingly and intentionally 325 00:20:39,000 --> 00:20:43,599 benefited financially from and received value four its participation in 326 00:20:43,680 --> 00:20:47,359 the sex trafficking venture in which Epstein, with JP Morgan's 327 00:20:47,359 --> 00:20:50,680 knowledge or reckless disregard of the fact that Epstein would 328 00:20:50,720 --> 00:20:54,079 use means of force, threats of force, fraud, coercion, and 329 00:20:54,160 --> 00:20:56,960 a combination of such means to sexually abuse Jang do 330 00:20:57,079 --> 00:21:00,519 One as well as other class members and cause Gai 331 00:21:00,839 --> 00:21:04,039 as well as other class members to engage in commercial 332 00:21:04,039 --> 00:21:07,319 sex acts. Some of Epstein's victims were under the age 333 00:21:07,319 --> 00:21:11,599 of eighteen. Among the financial benefits that JP Morgan received 334 00:21:11,599 --> 00:21:15,480 for participating in the and facilitating Epstein's sex trafficking venture 335 00:21:15,680 --> 00:21:18,480 were the deposit of funds that Epstein and Epstein controlled 336 00:21:18,559 --> 00:21:22,519 entities made the JP Morgan. JP Morgan profited from the 337 00:21:22,599 --> 00:21:27,440 use of these deposits. Epstein and Epstein controlled entities deposited 338 00:21:27,480 --> 00:21:31,799 these funds in exchange for JP Morgan's facilitation and participation 339 00:21:32,200 --> 00:21:35,839 in the sex trafficking venture. Among the financial benefits that 340 00:21:35,880 --> 00:21:39,519 the defendant received for participating in Epstein's sex trafficking venture 341 00:21:39,880 --> 00:21:43,039 was a referral of business opportunities from Epstein and his 342 00:21:43,160 --> 00:21:47,960 co conspirators. JP Morgan profited from these referred business opportunities. 343 00:21:48,400 --> 00:21:52,720 Epstein referred business entities and business opportunities to JP Morgan 344 00:21:53,319 --> 00:21:57,359 in exchange for its facilitation and participation in his sex 345 00:21:57,359 --> 00:22:01,319 trafficking venture. JP Morgan knew and rectly disregarded the fact 346 00:22:01,440 --> 00:22:03,799 that it was Epstein's pattern and practice to use the 347 00:22:03,880 --> 00:22:10,279 channels and instrumentalities of interstate and foreign commerce to entice, recruit, solicit, harbor, provide, obtain, 348 00:22:10,599 --> 00:22:14,079 and transport young women and underage girls for the purpose 349 00:22:14,119 --> 00:22:17,839 of causing commercial sex acts and violation of US Code eighteen, 350 00:22:17,920 --> 00:22:22,880 section fifteen ninety one. JP Morgan and its employees had 351 00:22:22,920 --> 00:22:26,359 actual knowledge that they were facilitating Epstein's sexual abuse and 352 00:22:26,440 --> 00:22:31,960 sex trafficking conspiracy to recruit, solicit, entice, coerce, harbor, transport, obtain, 353 00:22:32,240 --> 00:22:34,880 and provide Jane do One as well as other members 354 00:22:34,920 --> 00:22:37,880 of the class into commercial sex acts through the means 355 00:22:37,880 --> 00:22:42,200 of force, threats of force, fraud, abuse of process, and coercion. 356 00:22:43,319 --> 00:22:47,359 Despite such knowledge, JP Morgan intentionally paid for, facilitated, and 357 00:22:47,440 --> 00:22:51,680 participated in Epstein's violation of US Code eighteen, section fifteen 358 00:22:51,759 --> 00:22:55,319 ninety one, a one which defendant knew and was in 359 00:22:55,400 --> 00:22:58,759 reckless disregard of the fact that Epstein would coerce the 360 00:22:58,839 --> 00:23:01,960 fraud and force Jaine One as well as other members 361 00:23:02,000 --> 00:23:05,720 of the class to engage in commercial sex acts. All right, 362 00:23:05,720 --> 00:23:07,319 we're going to wrap up right here, and in the 363 00:23:07,359 --> 00:23:10,200 next episode, we're going to pick up where we left off. 364 00:23:11,039 --> 00:23:13,519 All of the information that goes with this episode can 365 00:23:13,559 --> 00:23:16,640 be found in the description box. What's up, everyone, and 366 00:23:16,720 --> 00:23:20,680 welcome to another episode of the Epstein Chronicles. In this episode, 367 00:23:20,680 --> 00:23:23,400 we're going to get right back to the survivor's lawsuit 368 00:23:23,440 --> 00:23:28,319 filed against JP Morgan. JP Morgan, through its employees and agents, 369 00:23:28,519 --> 00:23:32,039 actively participated in the sex trafficking conspiracy and led Jane 370 00:23:32,079 --> 00:23:34,680 Doe One as well as other members of the class 371 00:23:34,960 --> 00:23:37,839 to believe that they would be rewarded if they cooperated 372 00:23:38,000 --> 00:23:42,559 and acquiesced to Epstein's demands. JP Morgan's affirmative conduct was 373 00:23:42,559 --> 00:23:45,720 committed knowing or in reckless disregard of the facts that 374 00:23:45,720 --> 00:23:49,359 Epstein would use cash and financial support provided by JP 375 00:23:49,480 --> 00:23:53,079 Morgan as a means of defrauding, forcing, and coercing sex 376 00:23:53,119 --> 00:23:55,640 acts from Jane Doe One as well as other members 377 00:23:55,680 --> 00:24:00,480 of the class. Defendant's conduct was outrageous and intentional. In 378 00:24:00,519 --> 00:24:04,000 addition to actual knowledge that they were participating in and 379 00:24:04,039 --> 00:24:08,119 facilitating the Epstein's sex trafficking venture. JP Morgan also should 380 00:24:08,160 --> 00:24:11,279 have known that it was participating in and facilitating a 381 00:24:11,359 --> 00:24:14,680 venture that had engaged in course of sex trafficking in 382 00:24:14,799 --> 00:24:19,079 violation of US Code eighteen, section fifteen ninety one. In 383 00:24:19,160 --> 00:24:22,519 exchange for facilitating and covering up Epstein's commercial sex act, 384 00:24:22,880 --> 00:24:26,880 JP Morgan's employees advanced their careers at JP Morgan and 385 00:24:26,920 --> 00:24:31,599 receive financial benefits from there. Facilitating and covering up Epstein's 386 00:24:31,599 --> 00:24:35,400 sexual misconduct was a means of obtaining economic success and 387 00:24:35,440 --> 00:24:41,400 promotion within the JP Morgan hierarchy. JP Morgan knowing an 388 00:24:41,440 --> 00:24:44,880 intentional conduct has caused Jane do One and the other 389 00:24:44,920 --> 00:24:50,759 members of the class serious harm, including without limitation, physical, psychological, emotional, financial, 390 00:24:50,960 --> 00:24:55,400 and reputational harm. JP Morgan's knowing and intentional conduct has 391 00:24:55,440 --> 00:24:57,799 caused Jane do One and the other members of the 392 00:24:57,839 --> 00:25:01,559 class harm that is sufficiently serious under all the surrounding 393 00:25:01,599 --> 00:25:05,359 circumstances to compel a reasonable person of the same background 394 00:25:05,559 --> 00:25:08,400 and in the same circumstance to perform or to continue 395 00:25:08,440 --> 00:25:13,039 performing commercial sexual activity in order to avoid incurring that harm. 396 00:25:13,640 --> 00:25:16,880 This case does not involve mere fraud. Instead, JP Morgan 397 00:25:17,119 --> 00:25:21,079 tortious conduct and violating the TVPA was outrageous and intentional 398 00:25:21,359 --> 00:25:24,480 because it was a deliberate furtherance of a widespread and 399 00:25:24,599 --> 00:25:29,880 dangerous criminal sex trafficking organization. JP Morgan's tortious conduct also 400 00:25:29,920 --> 00:25:33,440 evinced a high degree of moral tertitude and demonstrated such 401 00:25:33,480 --> 00:25:38,599 wanton dishonesty as to imply a criminal indifference to civil obligations. 402 00:25:38,799 --> 00:25:42,519 JP Morgan's tortious conduct was directed specifically at Jane do 403 00:25:42,640 --> 00:25:45,079 One and other members of the class who are the 404 00:25:45,160 --> 00:25:49,319 victims of Epstein's sexual abuse and sex trafficking organization. By 405 00:25:49,440 --> 00:25:53,480 virtue of these violations, knowing an intentional violation of US 406 00:25:53,559 --> 00:25:57,359 Code eighteen, section fifteen ninety one fifteen ninety five, JP 407 00:25:57,480 --> 00:26:00,000 Morgan is liable to Jane do One and other members 408 00:26:00,400 --> 00:26:03,599 of the class for the damages they sustained and reasonable 409 00:26:03,599 --> 00:26:08,240 attorney fees by virtue of these intentional and outrageous violations. 410 00:26:08,640 --> 00:26:12,119 US Code eighteen, section fifteen ninety one A two fifteen 411 00:26:12,200 --> 00:26:15,319 ninety five, JP Morgan is liable to Jane do One 412 00:26:15,559 --> 00:26:19,000 and other members of the class for punitive damages. Count 413 00:26:19,079 --> 00:26:23,240 number three conspiracy to commit violations of the Sex Trafficking 414 00:26:23,319 --> 00:26:27,599 Victim Protection Act. US Code eighteen, section fifteen ninety four 415 00:26:27,680 --> 00:26:32,480 C and fifteen ninety five. Plaintiff Chang Do one realleges 416 00:26:32,680 --> 00:26:36,079 and incorporates by reference paragraphs one through two thirty six 417 00:26:36,440 --> 00:26:39,759 as a fully set forth in this count. Plaintiff Jang 418 00:26:39,799 --> 00:26:42,880 Do one brings this count individually and on behalf of 419 00:26:42,920 --> 00:26:47,039 the other class members she respectively seeks to represent. JP 420 00:26:47,160 --> 00:26:51,279 Morgan intentionally conspired with others by agreement and understanding to 421 00:26:51,359 --> 00:26:55,960 violate US Code eighteen, section fifteen ninety one A and 422 00:26:56,000 --> 00:26:59,359 to further Epstein sex trafficking venture to course commercial sex 423 00:26:59,359 --> 00:27:02,880 acts from Jane H One and other class members, all 424 00:27:02,920 --> 00:27:06,480 in violation of US Code eighteen, section fifteen ninety four C. 425 00:27:07,640 --> 00:27:11,599 JP Morgan employees conspired with Epstein himself to further the 426 00:27:11,599 --> 00:27:15,880 sex trafficking venture. JP Morgan conspired with Epstein and his 427 00:27:16,000 --> 00:27:19,799 co conspirators to further the Epstein sex trafficking venture with 428 00:27:19,880 --> 00:27:25,119 the purpose of facilitating Epstein's illegal sex trafficking. JP Morgan 429 00:27:25,240 --> 00:27:29,480 intentionally committed overt acts in furtherance of the conspiracy agreement 430 00:27:29,599 --> 00:27:33,279 and understanding to violate US Code eighteen, section fifteen ninety 431 00:27:33,319 --> 00:27:37,319 one by knowingly playing an active role in assisting, supporting, 432 00:27:37,319 --> 00:27:42,000 and facilitating the recruiting, enticing, coursing, harboring, transporting, and inducing 433 00:27:42,079 --> 00:27:45,400 Jane do One and other class members to engage in 434 00:27:45,400 --> 00:27:49,279 commercial sex acts through providing financial support for the Epstein 435 00:27:49,359 --> 00:27:53,119 sex trafficking venture. Among the many overt acts intentionally committed 436 00:27:53,160 --> 00:27:56,519 by JP Morgan in furtherance of the sex trafficking venture 437 00:27:56,880 --> 00:28:01,119 were creating and maintaining a financial relationship between JP Morgan 438 00:28:01,720 --> 00:28:04,839 and Epstein within the district. It was part of the 439 00:28:04,880 --> 00:28:08,960 conspiracy that JP Morgan would financially benefit from providing financial 440 00:28:09,000 --> 00:28:13,799 support for Epstein's sex trafficking venture. JP Morgan did financially 441 00:28:13,839 --> 00:28:17,799 benefit from its participation in the venture, including receiving valuable 442 00:28:17,799 --> 00:28:22,160 deposits from Epstein and Epstein related entities into JP Morgan. 443 00:28:22,960 --> 00:28:27,160 JP Morgan's participation in furthering Epstein's sex trafficking venture was 444 00:28:27,200 --> 00:28:31,319 intentional and wilful, and therefore JP Morgan intentionally and wilfully 445 00:28:31,359 --> 00:28:35,039 caused Epstein's commission of the commercial sex acts with Jane 446 00:28:35,039 --> 00:28:38,279 do One and other class members. Through its affirmative and 447 00:28:38,440 --> 00:28:42,799 overt acts supporting Epstein, JP Morgan knew or acted in 448 00:28:42,839 --> 00:28:45,839 reckless disregard of the fact that its acts and conduct 449 00:28:45,920 --> 00:28:50,119 supporting and facilitating Epstein would lead to unlawful coercive commercial 450 00:28:50,119 --> 00:28:53,680 sex acts by Epstein with young women and girls, including 451 00:28:53,759 --> 00:28:58,200 Jane do One and other class members. JP Morgan conspired 452 00:28:58,240 --> 00:29:01,720 with Epstein through their affirmative acts and provided substantial support 453 00:29:01,960 --> 00:29:05,279 to Epstein committing commercial sex acts upon Jane do One 454 00:29:05,680 --> 00:29:10,519 and other class members. In addition to acting with knowledge 455 00:29:10,559 --> 00:29:13,640 that they were supporting the Epstein sex trafficking venture, JP 456 00:29:13,799 --> 00:29:18,480 Morgan benefited financially from participating in the Epstein sex trafficking venture, 457 00:29:18,839 --> 00:29:22,000 which JP Morgan should have known that had engaged in 458 00:29:22,039 --> 00:29:25,000 course of sex trafficking and violation of US Code eighteen, 459 00:29:25,119 --> 00:29:29,920 Section fifteen ninety one A one. Defendant's conduct has caused 460 00:29:30,000 --> 00:29:33,799 Jane do One and other class members serious harm, including 461 00:29:33,839 --> 00:29:39,720 without limitation, physical, psychological, financial, and reputational harm. Defendants conduct 462 00:29:39,759 --> 00:29:42,680 has caused Jane do One harm that is sufficiently serious 463 00:29:42,960 --> 00:29:46,480 under all the surrounding circumstances to compel a reasonable person 464 00:29:46,519 --> 00:29:49,319 of the same background and in the same circumstance to 465 00:29:49,400 --> 00:29:53,640 perform or continue to performing commercial sex acts in order 466 00:29:53,680 --> 00:29:56,680 to avoid incurring that harm. This case does not involve 467 00:29:56,720 --> 00:30:00,519 mere fraud. Instead, defendants towardious conduct and conspiring to violate 468 00:30:00,559 --> 00:30:04,519 the TVPA was outrageous and intentional because it was in 469 00:30:04,599 --> 00:30:09,079 deliberate furtherance of a widespread and dangerous criminal sex trafficking organization. 470 00:30:10,039 --> 00:30:13,680 Defendants tortious conspiracy also evinced a high degree of moral 471 00:30:13,720 --> 00:30:18,079 turpitude and demonstrated such wanton dishonesty as to imply criminal 472 00:30:18,079 --> 00:30:23,960 indifference to civil obligations. Defendants tortious conspiracy was directed specifically 473 00:30:24,000 --> 00:30:26,720 at Jane do One and other members of the class 474 00:30:27,000 --> 00:30:31,160 who are the victims of Epstein's sex trafficking organization. By 475 00:30:31,279 --> 00:30:34,680 virtue of these violations of US Code eighteen, section fifteen 476 00:30:34,759 --> 00:30:38,559 ninety four C. Fifteen ninety five, Defendant is liable to 477 00:30:38,640 --> 00:30:41,519 Jane do One and the other members of the class 478 00:30:41,640 --> 00:30:45,680 for the damages they sustained and reasonable attorney fees. By 479 00:30:45,839 --> 00:30:49,079 virtue of its intentional and outrageous conspiracy to violate US 480 00:30:49,119 --> 00:30:53,000 Code eighteen, section fifteen ninety four C and fifteen ninety five, 481 00:30:53,440 --> 00:30:56,440 Defendant is liable to Jane doll One and other members 482 00:30:56,440 --> 00:31:01,119 of the class for punitive damages. Count number four attempt 483 00:31:01,160 --> 00:31:04,720 to commit violations of the Trafficking Victim Protection Act. US 484 00:31:04,759 --> 00:31:08,880 Code eighteen, section fifteen ninety four A and fifteen ninety five. 485 00:31:10,279 --> 00:31:14,079 Plaintiff Chang do one realleges and incorporates by reference paragraphs 486 00:31:14,119 --> 00:31:17,480 one through two thirty six as a fully set fourth 487 00:31:17,640 --> 00:31:22,000 in this count. Plaintiff change One brings this count individually 488 00:31:22,039 --> 00:31:25,599 and on behalf of the other class members she respectfully 489 00:31:25,839 --> 00:31:30,160 seeks to represent. JP Morgan intentionally attempted to violate US 490 00:31:30,200 --> 00:31:34,000 Code eighteen section fifteen ninety one A one and to 491 00:31:34,160 --> 00:31:38,039 further epstein sex trafficking venture to coerce commercial sex acts 492 00:31:38,079 --> 00:31:41,000 from Jane do One and other class members, all in 493 00:31:41,079 --> 00:31:44,440 violation of US Code eighteen section fifteen ninety four A. 494 00:31:45,400 --> 00:31:49,359 JP Morgan employees deliberately took substantial steps to attempt to 495 00:31:49,400 --> 00:31:54,720 violate US Code eighteen, section fifteen ninety one within the district. 496 00:31:54,960 --> 00:31:58,920 JP Morgan deliberately took substantial steps toward attempting to violate 497 00:31:59,000 --> 00:32:03,599 US Code eighteen, section fifteen ninety one providing financial support 498 00:32:03,599 --> 00:32:07,640 for Epstein's sex trafficking venture. Among the many substantial steps 499 00:32:07,680 --> 00:32:10,960 taken by JP Morgan to deliberately attempt to violate US 500 00:32:11,000 --> 00:32:14,359 Code eighteen, section fifteen ninety one A were creating a 501 00:32:14,400 --> 00:32:18,799 financial relationship between JP Morgan and Epstein within the District. 502 00:32:19,759 --> 00:32:22,319 It was part of the attempt to violate US Code eighteen, 503 00:32:22,400 --> 00:32:26,440 Section fifteen ninety one that JP Morgan would financially benefit 504 00:32:26,480 --> 00:32:31,119 from providing financial support for Epstein's sex trafficking venture. JP 505 00:32:31,240 --> 00:32:35,480 Morgan did financially benefit from its participation in the venture, 506 00:32:35,799 --> 00:32:40,039 including receiving valuable deposits from Epstein and Epstein related entities 507 00:32:40,240 --> 00:32:45,279 into JP Morgan. Defendants attempt to violate the TVPA by 508 00:32:45,359 --> 00:32:49,799 furthering Epstein's sex trafficking venture was intentional and wilful, and therefore, 509 00:32:49,839 --> 00:32:53,759 Defendant intentionally and wilfully caused Epstein's commission of sexual abuse 510 00:32:53,960 --> 00:32:56,680 and commercial sex acts with Jane do One and other 511 00:32:56,720 --> 00:33:00,680 class members through its affirmative and overt act supporting Epstein, 512 00:33:01,720 --> 00:33:04,519 Defendant knew and acted in reckless disregard to the fact 513 00:33:04,559 --> 00:33:08,319 that its acts and conduct supporting and facilitating Epstein would 514 00:33:08,359 --> 00:33:12,000 lead to sexual abuse and unlawful coersive commercial sex acts 515 00:33:12,000 --> 00:33:15,279 by Epstein with young women and girls, including Jang do 516 00:33:15,400 --> 00:33:19,480 One and other class members. In addition to acting intentionally 517 00:33:19,680 --> 00:33:22,160 and with knowledge that they were supporting the Epstein sex 518 00:33:22,200 --> 00:33:27,079 trafficking venture, Defendant benefited financially from participating in epstein sex 519 00:33:27,119 --> 00:33:31,720 trafficking venture with defendant should have known would engage in 520 00:33:31,799 --> 00:33:35,400 coercive sex trafficking and violation of US Code eighteen, section 521 00:33:35,759 --> 00:33:39,319 fifteen ninety one A one. This case does not involve 522 00:33:39,400 --> 00:33:43,400 mere fraud. Instead, Defendant's tortious conduct in attempting to violate 523 00:33:43,440 --> 00:33:47,039 the TVPA was outrageous and intentional because it was a 524 00:33:47,079 --> 00:33:50,079 deliberate attempt to further the crimes of a widespread and 525 00:33:50,160 --> 00:33:55,759 dangerous criminal sex trafficking organization. Defendants tortious attempts also evinced 526 00:33:55,799 --> 00:33:59,079 a high degree of moral certitude and demonstrated such wanton 527 00:33:59,119 --> 00:34:02,920 dishonesty as to imply a criminal indifference to civil obligation. 528 00:34:03,680 --> 00:34:07,240 Defendants tortious attempt was directed specifically at Jane do One 529 00:34:07,440 --> 00:34:10,199 and other members of the class who are the victims 530 00:34:10,199 --> 00:34:14,679 of Epstein's sex trafficking organization. Defendant's conduct has caused Jane 531 00:34:14,679 --> 00:34:21,519 do One and other class members serious harm, including without limitation, physical, psychological, financial, 532 00:34:21,760 --> 00:34:25,920 and reputational harm, by virtue of these violations of US 533 00:34:25,960 --> 00:34:29,360 Code eighteen, section fifteen ninety four A fifteen ninety five. 534 00:34:29,400 --> 00:34:32,760 A defendant is liable to Jane do One and other 535 00:34:32,840 --> 00:34:35,599 members of the class for the damages they sustained and 536 00:34:35,719 --> 00:34:40,280 reasonable attorney fees. By virtue of this intentional and outrageous 537 00:34:40,280 --> 00:34:43,719 attempt to violate US Code eighteen, Section fifteen ninety four 538 00:34:43,760 --> 00:34:47,119 A fifteen ninety five. Defendant is liable to Jane do 539 00:34:47,280 --> 00:34:50,519 One and other members of the class for punitive damages. 540 00:34:51,400 --> 00:34:55,079 The request for relief Jane do One respectfully requests at 541 00:34:55,079 --> 00:34:58,400 the Court at her judgment in her favor and against JP. Morgan, 542 00:34:58,440 --> 00:35:02,519 as follows, the Court certify the class named Jame do 543 00:35:02,719 --> 00:35:07,559 One as class representative and appoint our Lawyers as class council. B. 544 00:35:07,760 --> 00:35:09,960 That the Court award plaintiff and other members of the 545 00:35:10,000 --> 00:35:16,440 class compensatory, consequential, general, nominal, and punitive damages against defendant 546 00:35:16,559 --> 00:35:19,199 in an amount to be determined at trial. That the 547 00:35:19,199 --> 00:35:22,880 Court award punitive and exemplary damages against defendant in an 548 00:35:22,880 --> 00:35:26,280 amount to be determined at trial. That the Court award 549 00:35:26,440 --> 00:35:29,239 to a plaintiff the costs and disbursements of the action, 550 00:35:29,639 --> 00:35:33,159 along with reasonable attorney fees, costs and expenses. That the 551 00:35:33,199 --> 00:35:36,400 Court award pre and post judgment interest at the maximum 552 00:35:36,480 --> 00:35:39,440 legal rate. And f That the Court grant all such 553 00:35:39,480 --> 00:35:42,599 other and further relief as it deems just and proper 554 00:35:43,960 --> 00:35:47,000 plaintiffs demand a trial by jury on all claims that 555 00:35:47,039 --> 00:35:51,280 are triable. Dated November twenty fourth, twenty twenty two, and 556 00:35:51,360 --> 00:35:55,079 it was signed by Bradley Edwards. All Right, folks. So 557 00:35:55,199 --> 00:35:57,800 that's the end of the lawsuit that was filed by 558 00:35:57,840 --> 00:36:01,679 the survivors against JP more. Now, the next set of 559 00:36:01,719 --> 00:36:04,920 core documents we're gonna dive into are the core records 560 00:36:05,039 --> 00:36:08,880 from the lawsuit filed by Virginia Roberts against the Joe 561 00:36:08,880 --> 00:36:12,760 Exotic of the Windsor family. All of the information that 562 00:36:12,800 --> 00:36:16,360 goes with this episode can be found in the description box.