Speaker 1: What's up, everyone, and welcome to another episode of the
Epstein Chronicles. In this episode, we're going to pick up
where he left off with the survivor's lawsuit filed against
JP Morgan. Epstein uses JP morgan accounts for the sex
trafficking venture. Over the course of the relationship, Epstein and
his representatives used JP Morgan accounts to send dozens of
wires directly and indirectly to co conspirators in the sex
trafficking venture. JP Morgan was aware that the recipients of
some of these wire transfers described in the previous paragraph
were to Epstein's co conspirators, and that the wire transfers
were in furtherance of the Epstein sex trafficking venture. Epstein
used JP Morgan accounts to pay for course commercial sex
by Jane do One. Given JP Morgan's knowledge about Epstein's
past sex trafficking, its continuation of its financial relationship with
Epstein was at a minimum in reckless disregard of the
fact that Epstein was using means of force, threats of
force for all coercion, and a combination of such means
to cause Epstein's victims to engage in commercial sex acts.
In addition to actual knowledge that it was facilitating the
Epstein sex trafficking venture. JP Morgan benefited financially by participating
in the venture that it should have known had engaged
in coercive sex trafficking in violation of US Code eighteen,
Section fifteen ninety one A. If a financial institution decides
to do business with a high risk client, that institution
is required to conduct due diligence, commeasure it with the risk,
and to tailor its transaction monitoring to detect suspicious or
unlawful activity based on what the risk is. JP Morgan knowingly, intentionally, deliberately,
and maliciously failed to do so. With regard to its
relationship with Epstein, the bank was well aware not only
that Epstein had pled guilty and serve prison time for
engaging in sex with a minor, but also that there
were public allegations that his conduct was facilitated by sex
several named co conspirators. Despite this knowledge of the bank
did little or nothing to inquire into or block numerous
payments to name co conspirators and two or on behalf
of numerous young women, or to inquire how Epstein was
using hundreds of thousands of dollars in cash per year.
Hush money, financial compensation or recruiters, and compensation of victims
was integral Dapstein's scheme, without which his sex trafficking operation
could not exist. The ability to obtain exorbitant amounts of
money and wires to young females and obtain unlimited cash
was critical of de Epstein's operation. Suspicious wire transfers and
withdrawals of millions of dollars in cash are basic hallmarks
of any major criminal enterprise. A bank that would allow
Epstein to operate in this blatant criminal fashion was necessary
for the growth of his trafficking operation and for the
continued abuse of hundreds of young women. Before JP Morgan
facilitated Epstein's operation with aout question, Epstein was able to
abuse young women sporadically and in fear of being caught.
JP Morgan eliminated that fear, making sure that the suspicious
money trail that would unveil Epstein's operation as the criminal
sexual abuse machine that it was, would be covered up
and would lead to his downfall. The negligence of JP
Morgan is clear. The complicity, though far extended, negligence as
JP Morgan acted with a high degree of moral turpitude
and demonstrated such wanton dishonesty as to imply a criminal
indifference to civil obligations, and JP Morgan also acted outrageously
and intentionally. JP Morgan knew Epstein had no college degree,
no ongoing legitimate business, and was engaging in sexual abuse
of females on a daily basis. JP Morgan recognized its
importance to Ebstein as the exclusive financial institution that was
willing to allow Epstein to engage in obvious criminal financial
activities to fund his sex trafficking venture. JP Morgan, acting
through Staley, was a criminal co conspirator of the operation.
There came a time when JP Morgan absolutely knew Epstein
was running a sex trafficking venture, and JP Morgan chose
to remain Epstein's banking partner to receive financial benefits in
exchange for ensuring the ventures continued operation. In order to
make hundreds of millions of dollars off of Epstein and
his contacts, JP Morgan facilitated Epstein's sex trafficking network, which
caused billions of dollars in damages from the pain and
suffering of hundreds of Epstein's sexual abuse and sex trafficking victims.
JP Morgan's desire to maintain its profitable relationship with Epstein
let it avoid taking steps that would have documented its
involvement in Epstein's sex trafficking venture the statute of limitations.
The statute of limitations under the TVPA is ten years
after the cause of action arose, or ten years after
the victim reaches eighteen years of age if the victim
was a minor at the time of the alleged defense.
The TVPA causes of action for Jane do One and
other class members all arose within ten years of the
filing of this complaint. The New York Adult Survivors Act
has opened up a one year revival window for the
statute of limitations class action allegations. Plaintiff Chang do One
brings this action pursuant to Federal Rule of Civil Procedure
twenty three B three twenty three C four on behalf
of themselves and the following class all women who are
sexually trafficked by Jeffrey Epstein during the time when JP
Morgan maintained bank accounts for Epstein and or Epstein related entities,
which was in or about two thousand through in or
about August of twenty thirteen, both dates inclusive the class period.
Plaintiff reserves the right to seek leave to modify the definition,
including the addition of one or more sub classes, after
having the opportunity to conduct discovery. The class consists of
dozens of women, making joinder impracticable in satisfaction of Federar civp.
Twenty three one. The exact size of the class and
the identities of the individual class members are ascertainable through
records maintained by the Epstein Estate and the defendant, including
but not limited to J. P. Morgan's records for Epstein's
related accounts account ledgers reflecting payments from Epstein to class members.
Typicality Plaintiff's claims are typical of the claims of the
other class members she seeks to represent. The claims of
plaintiff and the other class members are based on the
same legal theories and arise from the same unlawful pattern
and practice of Defendant's participation in and funding of the
Epstein's sexual abuse and Epstein's sex trafficking venture. Commonality, there
are many questions of law and fact common to the
claims of plaintiff and the other class members, and those
questions predominate over any questions that may affect only individual
class members within the meaning of FEDERCIVP. Class Treatment of
common issues under fediarcivp. Twenty three. Common questions of fact
and law affecting class members include, but are not limited to,
the following. Whether the Epstein sex trafficking venture caused its
victim to engage in commercial sex acts in violation of
the Trafficking Victims Protection Act. Whether the Epstein sex trafficking
venture recruited, entice, solicited, harbored, provided, obtained, and transported victims
in ways that were in or affecting interstate or foreign commerce.
Whether Epstein and his co conspirators use means of force, fraud, coercion,
and abuse of legal process, or a combination of such
means to sexually abuse the victims and to cause victims
to engage in commercial sex acts. Whether JP Morgan knowingly
and intentionally assisted, facilitated, and supported the Epstein sex trafficking
venture pattern and practice of coercively forcing victims to engage
in commercial sex acts. Whether JP Morgan benefited by financially
or by receiving things of value, from its participation in
a venture which has engaged in sex trafficking in violation
of TVPA, Whether JP Morgan knew or should have known
that Epstein's sex trafficking venture had engaged in violations of
the TVPA, Whether JP Morgan committed negligent acts or omissions
that facilitated sexual abuse which would constitute a sexual offense
as defined in Article one hundred and thirty of the
Penal Law committed against such persons who were eighteen years
of age or older. Apsent a class action, Most of
the class members would find the cost of litigating their
claims to be cost prohibitive and will have no effective remedy.
The class treatment of common questions of law and fact
is also superior to multiple individual actions or piecemeal litigation
in that it conserves the resources of the courts and
the litigants, and promotes consistency and efficiency of adjudication adequacy.
Jane I will fairly and adequately represent and protect the
interests of the other class members she seeks to represent. Change.
No one has retained counsel with substantial experience in prosecuting
complex litigation and class actions. Plaintiff and our counselor are
committed to vigorously prosecuting this action on behalf of the
other class members, and have the financial resources to do so.
Neither plaintiff nor a council have any interests adverse to
those of the other class members. This action has been
brought and may properly be maintained as a class action
against the defendant pursuant to Rule twenty three of the
Federal Rules of Civil Procedure. Because there is a well
defined community of interest in the litigation and the proposed
class is easily ascertainable from defendant records, a class action
is superior to all other available methods for the fair
adjudication of this controversy. Because a joinder of the class
members is impracticable. The prosecution of individuals remedies by members
of the class will tend to establish inconsistent standards of
conduct for defendant and result in the impairment of class
members' rights and the disposition of their interests through actions
to which they are not parties. Class action treatment will
permit a large number of similarly situated persons to prosecute
their common claim in a single forum, simultaneously, efficiently, and
without the unnecessary duplication of effort and expense that numerous
individual actions would engender. Absent a class action, class members
will continue to suffer losses and be aggrieved, and defendant
will continue to violate New York in federal law without remedy.
Class treatment of this action will cause an orderly and
expeditious administration of class claims. Economies of time, effort, and
expense will be fostered, and uniformity of decision will be ensured.
Plaintiffener council, or unaware of any class action brought against
any defendant for the violations alleged in the action. The
forum is desirable because defendant conducted the subject business with
Jeffrey Epstein in this district and class members were consequently
trafficked in this district. And this action presents no difficulty
that would impede its management by the court as a
class action. All right, We're going to wrap up right here,
and in the next episode dealing with the topic, We're
going to pick up where we left off. All of
the information that goes with this episode can be found
in the description box. What's up, everyone, and welcome to
another episode of the Epstein Chronicles. In this episode, We're
going to pick up where we left off with the
lawsuit filed by the survivors against JP Morgan Causes of
action Count one Intentional and negligent Acts and omissions under
the New York Adult Survivors Act, New York CPLR. Section
two fourteen J. Plaintiff Jane do One realleges and in
corporates by paragraphs one through two thirty six, as if
fully set forth in this count. Plaintiff Jang do One
brings this count individual and on behalf of the other
class members they respectfully seek to represent pursu into New
York Civil Practice Law and Rules Section two fourteen J.
This count for intentional and negligent Acts and omissions has
been timely filed as every civil claim or cause of
action brought against any party alleging intentional and negligent acts
or omissions by a person for physical, psychological, or other
injury or condition suffered as a result of conduct which
would constitute a sexual offense as defined an Article one
hundred and thirty of the Penal Law committed against such
person who was eighteen years of age or older. Was
revived effective November twenty fourth, twenty twenty two. Intentional and
negligent actions and omissions committed by JP Morgan within this
district and elsewhere directly and approximately resulted in sexual offenses
by Epstein and his co conspirators. Under the laws of
the State of New York. As a financial institution operating
within this district and within the State of New York,
JP Morgan owed legal duties to plaintiff Channg do one
and the class members to exercise reasonable care to monitor
JP Morgan's customers, including Jeffrey Epstein, for the purpose of
preventing them from facilitating and engaging in foreseeable criminal activity
using banks facilities that could harm the plaintiff and the
class members. The legal duties of JP Morgan described in
the two preceding paragraphs also extended to the other class
members whom Plaintiff Jang do one seeks to represent. The
legal duties of JP Morgan include, but are not limited to,
following the Know Your Customer laws and related regulations described above.
Under KYC laws, banks have special duties to inquire about
possible crimes being committed by their customers, duties above and
beyond any duties that the general public may have. The
inquiries that banks must make include duties to inquire about
specific individuals who are being harmed. The regulations established a
duty of care that must be followed by banks, including
JP Morgan. But for JP Morgan, Epstein could not have
successfully run and expanded his sexual abuse organization. While would
have wanted to sexually abuse women, he could not have
abused hundreds of victims that he did without JP Morgan.
JP Morgan breached its legal duties to plaintiff Chane do
One and the class members by failing to discharge its
legal duty to prevent Jeffrey Epstein and others from using
the bank's facilities to facilitate and commit criminal activity harming
Jane do One and the class members. The criminal activity
that harm plaintiff and class members included for seeable federal
crimes committed by the Epstein sex trafficking enterprise described above,
as well as the state sex offense crimes. As a
direct and proximate result of the breach of legal duties
by JP Morgan, Plaintiff Jane do One and the class
members repeatedly suffered for seeable injuries from Epstein and his
co conspirators, including federal and state sexual offenses and resulting
emotional distress, mental pain and suffering, and other physical, psychological,
and other injuries. The breaches of legal duty were the
direct ie the but for cause of these injuries. Without
JP Morgan's breaches of its legal duties, those injuries would
not have occurred. The breaches of legal duty were the
direct ie but for cause of these injuries. Without defendant's
breaches of legal duties, those injuries would not have occurred.
The injuries that occurred were readily foreseeable by JP Morgan.
The injuries at plaintiff Channg do one and the class
members suffered included injuries directly and proximately suffered while there
were adults who were present in this district. These injuries
are permanent in nature, and Jane do One and other
class members will continue to suffer these losses in the future.
The injuries that plaintiff Chang Do one and the class
members suffered included injuries directly and proximately suffered as a
result of sex offense committed by Epstein and other co
conspirators and criminalized under Article one thirty. The offenses included
sexual intercourse without consent and oral sexual conduct without consent
forbidden by New York Penal Law Section one thirty dot twenty.
The offenses included forcible touching of sexual or other intimate
parts without consent, forbidden by New York Penal Law Section
one thirty dot twenty. The breaches of legal duties by
JP Morgan proximately caused plaintiff Chang Do I and the
class members to repeatedly suffer injuries from Epstein and his
co conspirators, including sexual assaults and resulting emotional distress, mental
pain and suffering, and other physical and psychological trauma. These
injuries were easily foreseeable because JP Morgan knew and acted
in reckless disregard of the fact that their actions and
omissions supporting and facilitating Epstein would lead to, among other crime,
sex offenses by Epstein and his co conspirators forbidden by
Article one thirty of the New York Penal Law against
the victims, including Jane do One and the class members.
In the exercise of reasonable care, JP Morgan and its
employees knew or should have known of the dangerous propensities
of Jeffrey Epstein and the harm that would be caused
by his likely sexual crimes and various violations of Article
one thirty of the New York Penal Law. JP Morgan
could reasonably foresee that its actions and omissions in facilitating
Epstein's sex trafficking enterprise would lead to sex offenses against
Jane do One and the class members, among other things.
The defendant was specifically aware that Epstein had previously been
prosecuted for similar sex crimes and previously paid numerous civil
settlements associated with similar sex crimes. Indeed, the defendant was
aware and should have been aware, that Epstein was a
high risk to commit sex offenses against young women and girls.
Plaintiff Chang do One and the class members were easily
within the zone of foreseeable harm from JP Morgan's intentional
and negligent acts and omissions. JP Morgan's intentional and negligent
acts and omissions for seeably created substantial risk of Jeffrey
Epstein and his co conspirators committing sex crimes against young
women with whom he was in contact. Tragically, Jane do
One and the Master class members fell within that zone.
The sex offenses Jeffrey Epstein committed against Jane do One
and the class members were easily within the zone of
foreseeable risks that JP Morgan created with its intentionally and
negligent actions and omissions. Those actions and omissions foreseeably risked
further sex crimes by Jeffrey Epstein and his co conspirators,
which is exactly and tragically the harm that he inflicted
on Jane do One and the class members. While the
foregoing allegations easily made out a clearer case of negligence,
the case does not involve mere negligence. Instead, defendant's tortious
conduct in this case evinced a high degree of moral
tertitude and demonstrated such wanton dishonesty as to imply a
criminal indifference to civil obligation. It also involved outrageous and
intentional acts and omissions because it was a deliberate attempt
to further the crimes of a widespread and dangerous criminal
sex trafficking organization. Defendant's tortious conduct was directed specifically at
Jane do One and the class members, who were the
victims of Epstein's sexual abuse and sex trafficking organization. As
a result of the intentional and negligent actions and omissions
described in this count, Plaintiff Jang do One and the
class members have sustained both general and specified damages in
substantial amounts by virtue of acting intentionally, outrageously and with
a high degree of moral tertitude, and demonstrating such wanton
dishonesty as to imply a criminal indifference to civil obligation.
Defendant is liable to Jane do One and other members
of the class for punitive damages. Count two participating in
a sex trafficking venture violation of the Trafficking Victims Protection
Act US Code eighteen, section fifteen ninety one A and
two fifteen ninety five. Plaintiff Chang do one realleges and
incorporates by reference paragraphs one through two thirty six as
a fully set fourth in this count. Plaintiff Chang do
One brings this count individually and on behalf of the
other class members she seeks to represent. JP Morgan knowingly
and intentionally participated in, assisted, supported, and facilitated a sex
trafficking venture that was in and affecting interstate and foreign commerce,
together with others, in violation of US Code eighteen, section
fifteen ninety one A two. JP Morgan knowingly and intentionally
benefited financially from and received value four its participation in
the sex trafficking venture in which Epstein, with JP Morgan's
knowledge or reckless disregard of the fact that Epstein would
use means of force, threats of force, fraud, coercion, and
a combination of such means to sexually abuse Jang do
One as well as other class members and cause Gai
as well as other class members to engage in commercial
sex acts. Some of Epstein's victims were under the age
of eighteen. Among the financial benefits that JP Morgan received
for participating in the and facilitating Epstein's sex trafficking venture
were the deposit of funds that Epstein and Epstein controlled
entities made the JP Morgan. JP Morgan profited from the
use of these deposits. Epstein and Epstein controlled entities deposited
these funds in exchange for JP Morgan's facilitation and participation
in the sex trafficking venture. Among the financial benefits that
the defendant received for participating in Epstein's sex trafficking venture
was a referral of business opportunities from Epstein and his
co conspirators. JP Morgan profited from these referred business opportunities.
Epstein referred business entities and business opportunities to JP Morgan
in exchange for its facilitation and participation in his sex
trafficking venture. JP Morgan knew and rectly disregarded the fact
that it was Epstein's pattern and practice to use the
channels and instrumentalities of interstate and foreign commerce to entice, recruit, solicit, harbor, provide, obtain,
and transport young women and underage girls for the purpose
of causing commercial sex acts and violation of US Code eighteen,
section fifteen ninety one. JP Morgan and its employees had
actual knowledge that they were facilitating Epstein's sexual abuse and
sex trafficking conspiracy to recruit, solicit, entice, coerce, harbor, transport, obtain,
and provide Jane do One as well as other members
of the class into commercial sex acts through the means
of force, threats of force, fraud, abuse of process, and coercion.
Despite such knowledge, JP Morgan intentionally paid for, facilitated, and
participated in Epstein's violation of US Code eighteen, section fifteen
ninety one, a one which defendant knew and was in
reckless disregard of the fact that Epstein would coerce the
fraud and force Jaine One as well as other members
of the class to engage in commercial sex acts. All right,
we're going to wrap up right here, and in the
next episode, we're going to pick up where we left off.
All of the information that goes with this episode can
be found in the description box. What's up, everyone, and
welcome to another episode of the Epstein Chronicles. In this episode,
we're going to get right back to the survivor's lawsuit
filed against JP Morgan. JP Morgan, through its employees and agents,
actively participated in the sex trafficking conspiracy and led Jane
Doe One as well as other members of the class
to believe that they would be rewarded if they cooperated
and acquiesced to Epstein's demands. JP Morgan's affirmative conduct was
committed knowing or in reckless disregard of the facts that
Epstein would use cash and financial support provided by JP
Morgan as a means of defrauding, forcing, and coercing sex
acts from Jane Doe One as well as other members
of the class. Defendant's conduct was outrageous and intentional. In
addition to actual knowledge that they were participating in and
facilitating the Epstein's sex trafficking venture. JP Morgan also should
have known that it was participating in and facilitating a
venture that had engaged in course of sex trafficking in
violation of US Code eighteen, section fifteen ninety one. In
exchange for facilitating and covering up Epstein's commercial sex act,
JP Morgan's employees advanced their careers at JP Morgan and
receive financial benefits from there. Facilitating and covering up Epstein's
sexual misconduct was a means of obtaining economic success and
promotion within the JP Morgan hierarchy. JP Morgan knowing an
intentional conduct has caused Jane do One and the other
members of the class serious harm, including without limitation, physical, psychological, emotional, financial,
and reputational harm. JP Morgan's knowing and intentional conduct has
caused Jane do One and the other members of the
class harm that is sufficiently serious under all the surrounding
circumstances to compel a reasonable person of the same background
and in the same circumstance to perform or to continue
performing commercial sexual activity in order to avoid incurring that harm.
This case does not involve mere fraud. Instead, JP Morgan
tortious conduct and violating the TVPA was outrageous and intentional
because it was a deliberate furtherance of a widespread and
dangerous criminal sex trafficking organization. JP Morgan's tortious conduct also
evinced a high degree of moral tertitude and demonstrated such
wanton dishonesty as to imply a criminal indifference to civil obligations.
JP Morgan's tortious conduct was directed specifically at Jane do
One and other members of the class who are the
victims of Epstein's sexual abuse and sex trafficking organization. By
virtue of these violations, knowing an intentional violation of US
Code eighteen, section fifteen ninety one fifteen ninety five, JP
Morgan is liable to Jane do One and other members
of the class for the damages they sustained and reasonable
attorney fees by virtue of these intentional and outrageous violations.
US Code eighteen, section fifteen ninety one A two fifteen
ninety five, JP Morgan is liable to Jane do One
and other members of the class for punitive damages. Count
number three conspiracy to commit violations of the Sex Trafficking
Victim Protection Act. US Code eighteen, section fifteen ninety four
C and fifteen ninety five. Plaintiff Chang Do one realleges
and incorporates by reference paragraphs one through two thirty six
as a fully set forth in this count. Plaintiff Jang
Do one brings this count individually and on behalf of
the other class members she respectively seeks to represent. JP
Morgan intentionally conspired with others by agreement and understanding to
violate US Code eighteen, section fifteen ninety one A and
to further Epstein sex trafficking venture to course commercial sex
acts from Jane H One and other class members, all
in violation of US Code eighteen, section fifteen ninety four C.
JP Morgan employees conspired with Epstein himself to further the
sex trafficking venture. JP Morgan conspired with Epstein and his
co conspirators to further the Epstein sex trafficking venture with
the purpose of facilitating Epstein's illegal sex trafficking. JP Morgan
intentionally committed overt acts in furtherance of the conspiracy agreement
and understanding to violate US Code eighteen, section fifteen ninety
one by knowingly playing an active role in assisting, supporting,
and facilitating the recruiting, enticing, coursing, harboring, transporting, and inducing
Jane do One and other class members to engage in
commercial sex acts through providing financial support for the Epstein
sex trafficking venture. Among the many overt acts intentionally committed
by JP Morgan in furtherance of the sex trafficking venture
were creating and maintaining a financial relationship between JP Morgan
and Epstein within the district. It was part of the
conspiracy that JP Morgan would financially benefit from providing financial
support for Epstein's sex trafficking venture. JP Morgan did financially
benefit from its participation in the venture, including receiving valuable
deposits from Epstein and Epstein related entities into JP Morgan.
JP Morgan's participation in furthering Epstein's sex trafficking venture was
intentional and wilful, and therefore JP Morgan intentionally and wilfully
caused Epstein's commission of the commercial sex acts with Jane
do One and other class members. Through its affirmative and
overt acts supporting Epstein, JP Morgan knew or acted in
reckless disregard of the fact that its acts and conduct
supporting and facilitating Epstein would lead to unlawful coercive commercial
sex acts by Epstein with young women and girls, including
Jane do One and other class members. JP Morgan conspired
with Epstein through their affirmative acts and provided substantial support
to Epstein committing commercial sex acts upon Jane do One
and other class members. In addition to acting with knowledge
that they were supporting the Epstein sex trafficking venture, JP
Morgan benefited financially from participating in the Epstein sex trafficking venture,
which JP Morgan should have known that had engaged in
course of sex trafficking and violation of US Code eighteen,
Section fifteen ninety one A one. Defendant's conduct has caused
Jane do One and other class members serious harm, including
without limitation, physical, psychological, financial, and reputational harm. Defendants conduct
has caused Jane do One harm that is sufficiently serious
under all the surrounding circumstances to compel a reasonable person
of the same background and in the same circumstance to
perform or continue to performing commercial sex acts in order
to avoid incurring that harm. This case does not involve
mere fraud. Instead, defendants towardious conduct and conspiring to violate
the TVPA was outrageous and intentional because it was in
deliberate furtherance of a widespread and dangerous criminal sex trafficking organization.
Defendants tortious conspiracy also evinced a high degree of moral
turpitude and demonstrated such wanton dishonesty as to imply criminal
indifference to civil obligations. Defendants tortious conspiracy was directed specifically
at Jane do One and other members of the class
who are the victims of Epstein's sex trafficking organization. By
virtue of these violations of US Code eighteen, section fifteen
ninety four C. Fifteen ninety five, Defendant is liable to
Jane do One and the other members of the class
for the damages they sustained and reasonable attorney fees. By
virtue of its intentional and outrageous conspiracy to violate US
Code eighteen, section fifteen ninety four C and fifteen ninety five,
Defendant is liable to Jane doll One and other members
of the class for punitive damages. Count number four attempt
to commit violations of the Trafficking Victim Protection Act. US
Code eighteen, section fifteen ninety four A and fifteen ninety five.
Plaintiff Chang do one realleges and incorporates by reference paragraphs
one through two thirty six as a fully set fourth
in this count. Plaintiff change One brings this count individually
and on behalf of the other class members she respectfully
seeks to represent. JP Morgan intentionally attempted to violate US
Code eighteen section fifteen ninety one A one and to
further epstein sex trafficking venture to coerce commercial sex acts
from Jane do One and other class members, all in
violation of US Code eighteen section fifteen ninety four A.
JP Morgan employees deliberately took substantial steps to attempt to
violate US Code eighteen, section fifteen ninety one within the district.
JP Morgan deliberately took substantial steps toward attempting to violate
US Code eighteen, section fifteen ninety one providing financial support
for Epstein's sex trafficking venture. Among the many substantial steps
taken by JP Morgan to deliberately attempt to violate US
Code eighteen, section fifteen ninety one A were creating a
financial relationship between JP Morgan and Epstein within the District.
It was part of the attempt to violate US Code eighteen,
Section fifteen ninety one that JP Morgan would financially benefit
from providing financial support for Epstein's sex trafficking venture. JP
Morgan did financially benefit from its participation in the venture,
including receiving valuable deposits from Epstein and Epstein related entities
into JP Morgan. Defendants attempt to violate the TVPA by
furthering Epstein's sex trafficking venture was intentional and wilful, and therefore,
Defendant intentionally and wilfully caused Epstein's commission of sexual abuse
and commercial sex acts with Jane do One and other
class members through its affirmative and overt act supporting Epstein,
Defendant knew and acted in reckless disregard to the fact
that its acts and conduct supporting and facilitating Epstein would
lead to sexual abuse and unlawful coersive commercial sex acts
by Epstein with young women and girls, including Jang do
One and other class members. In addition to acting intentionally
and with knowledge that they were supporting the Epstein sex
trafficking venture, Defendant benefited financially from participating in epstein sex
trafficking venture with defendant should have known would engage in
coercive sex trafficking and violation of US Code eighteen, section
fifteen ninety one A one. This case does not involve
mere fraud. Instead, Defendant's tortious conduct in attempting to violate
the TVPA was outrageous and intentional because it was a
deliberate attempt to further the crimes of a widespread and
dangerous criminal sex trafficking organization. Defendants tortious attempts also evinced
a high degree of moral certitude and demonstrated such wanton
dishonesty as to imply a criminal indifference to civil obligation.
Defendants tortious attempt was directed specifically at Jane do One
and other members of the class who are the victims
of Epstein's sex trafficking organization. Defendant's conduct has caused Jane
do One and other class members serious harm, including without limitation, physical, psychological, financial,
and reputational harm, by virtue of these violations of US
Code eighteen, section fifteen ninety four A fifteen ninety five.
A defendant is liable to Jane do One and other
members of the class for the damages they sustained and
reasonable attorney fees. By virtue of this intentional and outrageous
attempt to violate US Code eighteen, Section fifteen ninety four
A fifteen ninety five. Defendant is liable to Jane do
One and other members of the class for punitive damages.
The request for relief Jane do One respectfully requests at
the Court at her judgment in her favor and against JP. Morgan,
as follows, the Court certify the class named Jame do
One as class representative and appoint our Lawyers as class council. B.
That the Court award plaintiff and other members of the
class compensatory, consequential, general, nominal, and punitive damages against defendant
in an amount to be determined at trial. That the
Court award punitive and exemplary damages against defendant in an
amount to be determined at trial. That the Court award
to a plaintiff the costs and disbursements of the action,
along with reasonable attorney fees, costs and expenses. That the
Court award pre and post judgment interest at the maximum
legal rate. And f That the Court grant all such
other and further relief as it deems just and proper
plaintiffs demand a trial by jury on all claims that
are triable. Dated November twenty fourth, twenty twenty two, and
it was signed by Bradley Edwards. All Right, folks. So
that's the end of the lawsuit that was filed by
the survivors against JP more. Now, the next set of
core documents we're gonna dive into are the core records
from the lawsuit filed by Virginia Roberts against the Joe
Exotic of the Windsor family. All of the information that
goes with this episode can be found in the description box.