Mega Edition: Judge Rakoff Makes A Ruling In The Survivors Suit Against USVI (Part 5-7) (9/12/26)

0:00What's up everyone and welcome back to the Epstein Chronicles. In this episode we're picking up where we left off with Judge Raycoff's opinion and order. D. TVPA Perpetrator Liability Plaintiff's allegations that defendants themselves perpetrated sex trafficking are another matter. A direct perpetrator of sex trafficking is someone who knowingly recruits and tices, harbors, transports, provides, obtains, advertises, maintains, patronises, or solicits, an underage person to engage in a commercial sex act, or does the same to an adult by means of force, fraud, or coercion. US Code 18, Section 1591, A&1 Plaintiff's allegations do not adequately allege that either JP Morgan or Deutsche Bank did so. DB Jando claims that Deutsche Bank's cash was part of the recruitment of Jando and other victims, P1's memorandum and opposition to defendants' motion to dismiss at 21. The alleged facts that Epstein used cash obtained from DB to recruit his victims and that DB

1:02recklessly disregarded that he was doing so might jointly rendered DB liable for participating in Epstein's venture, see above, but they do not make DB the recruiter. JPM Jando's allegations are a little more on point, but still not sufficient. JPM Jando alleges that JP Morgan directly perpetrated sex trafficking in two ways. However, she alleges that a powerful financial executive at JP Morgan later identified as Jess Staley sexually assaulted JPM Jando. Second, JPM Jando alleges that JP Morgan's subsidiary, hybrid, transported some of the victims of Jeffrey Epstein's sex trafficking venture. But even if Mr. Staley's actions are attributable to JP Morgan, those actions do not support a perpetrator claim because the TVPA does not impose liability for sexual assault per se. A classic state crime, but also requires the additional elements described above. See US Code 18, Section 1591 A and 1. And JPM Jando's complaint does not alleged that JP Morgan knew that the women and girls

2:07allegedly transported by high bridge would be caused to engage in a commercial sex act, which is likewise an essential element of a TVPA perpetrator claim. See US Code 18, Section 1591 A. JPM Jando and DB Jando also alleged that JP Morgan and Deutsche Bank, even if they were not themselves perpetrators, aided and abetted Jeffrey Epstein's violation of US Code 18, Section 1591 A. They support this claim with the following train of logic. First, Jeffrey Epstein violated US Code 18, Section 1591 A, through his direct acts of sex trafficking. Second, US Code 18, Section 2, makes anyone criminally punishable as a principal if they aid or abet the commission of an offense against the United States.

3:09Finally, 18 US Code, Section 1595 A, provides a civil remedy to victims of the TVPA. It states an individual, who is a victim of a violation of this chapter, may bring a civil action against the perpetrator or whoever knowingly benefits financially or by receiving anything of value from participation in a venture which the person knew or should have known has engaged in an act in violation of this chapter in an appropriate district court of the United States. In other words, plaintiffs contend that US Code 18, Section 2, a criminal statute, is incorporated within the civil remedy provision of the TVPA. Plaintiffs' principles are subject to civil liability when they violate US Code 18, Section 1591 A, and US Code 18, Section 2, puts aiders and abetters in an equivalent criminal position to principles plaintiffs contend that aiders and abetters are subject to civil liability under US Code 18, Section 1595 A. Plaintiffs claims thus hinge on a question of law, whether the civil remedy provided by

4:13US Code 18, Section 1595 A, enables sex trafficking victims to pursue claims for aiding and abetting. The parties take opposing positions. Defendants argue that Section 1595 A civil remedy does not apply because aiding and abetting liability is provided by US Code 18, Section 2, which is not within this chapter. i.e. the TVPA US Code 18, Section 1581, C. Noble, 335f.supp.3d at 525 and 526, rejecting aiding and abetting liability under the TVPA. Plaintiffs meanwhile contend that US Code 18, Section 2, is incorporated within the TVPA. The defendants are correct. The TVPA does not provide civil liability for aiding and abetting. In general, aiding and abetting liability should not be inferred when a statute does not expressly provide for it. See Central Bank of Denver, NA, Versed First Interstate Bank of Denver, NA.

5:14511 US 164 185 1994 It is not plausible to interpret the statutory silence as tantamount to an implicit congressional intent to impose Section 10b aiding and abetting liability. Moreover, neither the text nor the legislative history of the TVPA indicates that Congress intended to provide civil liability for aiding and abetting a violation of it. In fact, some aspects of the TVPA's legislative history suggests that Congress had the opposite intention. Congress specifically rejected defining participation and adventure, which would entail civil liability, so as to include aiding and abetting. Compare, allow states and victims to fight online sex trafficking act of 2017, publication L. No. 115 through 164, Section 5, statute 132, 1253, 1255, 2018. Rejecting definition of participation and adventure that included aiding or abets, with

6:15HR 1865, 115th Congress, as introduced in House of April 3, 2017. Civil drafting, proposing aiding or abets, in definition of participation and adventure. A comparison to Rothstein vs UBS AG is instructive, C. Rothstein vs UBS AG 708 F.3D 82 Second Circuit 2013. In Rothstein, the second circuit considered this issue as presented by a similar statute, the Anti-Terrorism Act. The Anti-Terrorism Act, like the Trafficking Victims Protection Act, is a largely criminal statute that also provides a civil remedy for violations of it. C. U.S. Code 18, Section 2333A, providing a private right of action. Also like the Trafficking Victims Protection Act, the Civil Remedy Provision of the Anti-Terrorism Act does not expressly provide liability for aiding or abetting, but the act is codified in Title 18 of the United States Code, Section 2, of which makes any aider or a better

7:17punishable as a principle. In Rothstein, the second circuit held at U.S. Code 18, Section 2333, does not provide a right of action to assert claims for aiding and abetting. Rothstein 708 F.3D at 97 and 98. Rothstein's holding was supported by two premises. The court noted Central Banks General Presumption that aiding and abetting liability should not be inferred from statutory silence. ID at 97. The court also noted that other provisions of the ATA sections that surround its civil remedy provision do provide for aiding and abetting liability, ID at 98. That context, the court found, suggested that Congress affirmatively rejected aiding civil liability for aiding and abetting a violation of the ATA. So two, for the TVPA. There is a presumption that aiding and abetting liability should not be read into Section 1595 silence, a presumption that is confirmed by its legislative history.

8:17Since therefore, the TVPA does not provide civil liability for aiding and abetting under Section 2, plaintiffs aiding and abetting claims are dismissed. F. Attempting to benefit from a TVPA violation. Plaintiffs also alleged that J.P. Morgan and D.B. attempted to benefit from a TVPA violation. A defendant is liable for attempting to violate the law only if they have the specific intent to commit the underlying violation of the law. United States vs. Farhan, 634 F.3D 127 145 Second Circuit 2011. But the complaints here do not plead facts that support the inference that either J.P. Morgan or D.B. had this specific intention. If taken is true, plaintiffs allegations do support the inference that D.B. and J.P. Morgan intended to profit from their relationship with Jeffrey Epstein, and that accomplishing that objective required J.P. Morgan and D.B. to provide banking services that allegedly they knew or recklessly disregarded, supported Jeffrey Epstein's extravagant venture.

9:22But the complaints do not support the allegation that either J.P. Morgan or D.B. acted with specific intent of benefiting from a sex trafficking venture. Thus plaintiffs claims for attempting to violate the TVPA are dismissed. G. Conspiracy to violate the TVPA. Finally, plaintiffs alleged that J.P. Morgan and D.B. conspired with Epstein and others to violate the TVPA. The gist of conspiracy is, of course, agreement. United States vs. Beach Nut Nutrition Corporation, 871 F.2D 1181 1191 Second Circuit 1989. To be liable each defendant must have entered into a joint enterprise with consciousness of its general nature and extent. United States vs. Lessie 638 F.2D 466 473 Second Circuit 1980. Plaintiffs' factual allegations do not support the inference that either defendant made such an agreement. If the allegations in the complaints are taken as true, the defendants did indeed agree

10:23to provide banking services for Epstein and as affiliated entities and that they knew or recklessly disregarded would assist in a sex trafficking venture. So that agreement is different from an actual agreement to participate in a sex trafficking venture. Plaintiffs also alleged that the defendants covered up Epstein's sex trafficking by willfully failing the file's suspicious activity reports. But plaintiffs do not plead any facts which support the inference that the defendants did so pursuant to an agreement with Epstein or others to further his sex trafficking operation. Thus plaintiffs conspiracy claims are dismissed. Alright, that's going to do it for this episode. In the next episode we're going to pick up with H. Rico. All of the information that goes with this episode can be found in the description box. What's up everyone and welcome back to the Epstein Chronicles. In this episode we're getting right back to Judge Raykov's opinion and order. H. Rico Having discussed plaintiffs, TVPA claims the court now turns to DB Jane Doe's claim that

11:25DB violated section 1962 C of the racketeering influenced and corrupt organizations act Rico, US code 18 section 1961 and conspired the violate Rico and violation of section 1962D. There can be no liability under section 1962C if the defendant did not participate in the conduct of an enterprise. DeFalkis vs. Bernis 244f.3d286 306 Second Circuit 2001 To state a civil claim under US code 18 1962C, plaintiff Musa-Legge that the defendant participated in one conduct two of an enterprise three through a pattern four of racketeering activity. Quoting Sadima SPL-RL for his Immerex Company 473 US 479 496 1985 To participate in a racketeering enterprise under the relevant provisions of Rico, a defendant must direct the enterprises affairs. Reeves vs. Ernst & Young 507 US 170 177 180 1983

12:32While a defendant need not play a predominant part in the operation of the enterprise, it must exert some control over it. Dubai Islamic Bank vs. City Bank NA 256 F.S UPP 2D 158 164 SDNY 2003 While DB Jane Doe does not precisely define the enterprise that Deutsche Bank and Jeffrey Epstein allegedly formed and this itself would warrant dismissal of a Rico claims, her allegation appears to be that DB participated in Jeffrey Epstein's ex-trafficking venture. If that is Jane Doe's allegation, her substantive civil Rico claim fails. For, she is not alleged that DB controlled or directed that venture in any way. DB Jane Doe's Rico conspiracy claim likewise fails. For, she is not alleged any factual basis for a finding of a conscious agreement among the defendants. Hecht vs. Commerce Clearing House Incorporated 897F.2D2126N.4 Second Circuit 1990.

13:32DB Jane Doe has not pledged sufficient facts to supporter allegation that DB consciously agreed to undertake racketeering activity in violation of Section 1962 with Jeffrey Epstein. Instead, at most, she alleges that Deutsche Bank acted unlawfully as part of an implicit quid pro quo. Deutsche Bank would conceal Epstein's ex-trafficking venture in exchange for Epstein's lucrative fees. Because DB Jane Doe fails to plausibly allege that DB participated in a violation of Section 1962 C, or that DB consciously agreed to participate in one, DB's motion to dismiss, DB Jane Doe's civil Rico claim is granted. 1. Seaco The USVI makes similar allegations against JP Morgan, which fails for similar reasons. The USVI claims that JP Morgan violated the Virgin Islands criminally influenced and corrupt organizations act, Seaco, the Virgin Islands territorial law, analog to Rico, but the USVI fails to plausibly allege two of the initial elements of such a claim.

14:36That a criminal enterprise existed and that JP Morgan participated in it. The USVI alleges that JP Morgan's association with Jeffrey Epstein was a de facto enterprise, and the enterprise formed in this way, and association in fact enterprise must have three features, a common purpose, relationships among those associated with the enterprise, and longevity to pursue the enterprise's purpose. People, vs. McKenzie 66, VI3, 12 Supreme Court, 2017. The USVI, however, is failed to support its allegation that JP Morgan shared a common purpose with Jeffrey Epstein. The USVI does not allege that JP Morgan shared the purpose of trafficking or abusing Epstein's victims, rather the USVI alleges that the purpose of JP Morgan's association with Epstein was simply to make money. If the USVI's allegations are taken as true, achieving that purpose did require JP Morgan to support Epstein's ex-trafficking venture, but neither human trafficking nor its consequences were part of JP Morgan's purpose. JP Morgan would have been just as happy for Epstein's

15:42victims to escape, so long as Epstein's fees continued to roll in. And even if JP Morgan did form an enterprise with Jeffrey Epstein, the facts in the complaint do not support the USVI's allegation that JP Morgan participated in it. Like DBJ & Do, the USVI does not allege that JP Morgan conducted Epstein's ex-trafficking venture in any way. For that reason, and because the USVI fails to plausibly allege and enterprise as well, JP Morgan's motion to dismiss the USVI's sequel claim is granted. J. C. F. D. B. P. A. The last statutory claim brought against the defendants is the USVI's claim that JP Morgan violated the Virgin Consumer Fraud and Deceptive Business Practices Act. The USVI alleges that JP Morgan gained an unfair advantage over other law-abiding banks by supporting Epstein's ex-trafficking venture. USVI FAC 130-36. In exchange for JP Morgan's support, the USVI alleges Epstein provided JP Morgan with referrals of high-value

16:44business opportunities, ID at 135. The USVI's pleadings are threadbare. The USVI does not say which banks in particular were denied the high-value business opportunities that JP Morgan allegedly obtained. It does not describe any connection between those banks and the Virgin Islands. And it does not say that these banks actually did comply with their legal obligations with respect to similarly situated customers, which is an essential aspect of the USVI's unfairness claim. Thus, the USVI's allegations fall well short of making its CFP B. D. P. A. claim plausible, and JP Morgan's motion to dismiss this claim is granted. Okay, negligence. JPM Jando and D. B. Jando and also assert several New York State law-tort claims against JP Morgan and D. B. Their first set of such claims alleged that JP Morgan and D. B. were negligent. They alleged that the banks failed to exercise reasonable care to prevent physical harm and that

17:44the banks failed to exercise reasonable care as banking institutions providing non-routine banking services. Under New York law, and as under the law of virtually every state, there are three elements of negligence. One, duty owed by the defendant to the plaintiff, two, a breach thereof, and three injury proxamentally resulting therefrom. Solomon Example, Solomon vs. City of New York, 489, NE2D 1294, and Y 1985. The parties can test the first and third elements, duty and proxament causation, JP Morgan and Deutsche Bank, say that they owed no duty to Jando. According to the banks, they had no duty to prevent Jeffrey Epstein from harming either Jando, nor did they acquire any duty to care from their banking relationship with Epstein. CRE terrorist attacks on September 11, 2011, 714 F.3D 116, 2nd Circuit 2013. Banks and other financial institutions do not owe non-customers a duty to protect them

18:47from the intentional torts of their customers. But JP Morgan and D. B. like everyone else owed both Jando's the ordinary duty of reasonable care, this duty can extend to actions undertaken by third parties. Restatement, third of torts, physical and emotional harm, section 19. The conduct of a defendant can lack reasonable care in so far as it forcibly combined with or permits the improper conduct of the plaintiff or third party, Ford vs. Grand Union Company, 197, NE266268 and 269, and Y 1935. Defendant owes a duty to avoid injuries to others by forces set in motion by the defendant. Banks are not exempt from this duty. See, L. Malliick vs. Bank of China LTD 110AD3D192 206 New York Appeals Division 2013. We do not find case law to support the argument that a bank can never be held liable to non-customers, ID at 206.

19:47A toward fissures compliance with relevant laws and regulations will not insulate it from liability if it fails to act objectively reasonably. And this duty applies when banks provide non-routine services, CID at 207. Although New York does not generally recognize a duty on the part of banks to non-customers, that does not mean that New York policy would prohibit recovery under the alleged facts of proven. Since JPM Jando and DB Jando do indeed alleged that JPMorgan and DB helped set in motion Jeffrey Epstein's ex-trafficking venture by providing the cash that fueled it, they plausibly assert that JPMorgan and DB owed a duty to them. JPMorgan and DB also contend that their first conduct is not a proximate cause of Jando's injury. When an alleged injury is caused by an intervening criminal act such as sexual abuse, the defendant's conduct is a proximate cause only when that intervening act is a natural and foreseeable consequence of a circumstance created by the defendant. Hane versus Jemisin, 68,

20:49NE3D, 1233, 1236, and 37, and Y 2016. Proximate cause will be found lacking where the original negligent act merely furnished the occasion for an unrelated act to cause injuries not ordinarily anticipated. ID at 1238. And the banks assert, rehearsing arguments considered above that they neither knew nor should have known that their services contributed to the abuse of the Jando's. For the reasons already discussed above, however, JPM Jando and DB Jando alleged that JPMorgan and DB should have known that their banking services sustained Jeffrey Epstein's ex-trafficking venture. Indeed, they go further and adequately alleged that the defendant's actually knew this or at least recklessly disregarded what was plainly to be seen. Such constructive knowledge plausibly makes harm to plaintiffs and other victims of Epstein's ex-trafficking a natural and foreseeable consequence of the actions of JPMorgan and DB. Thus the court finds that JPM, Jando and DB Jando

21:52plausibly allege both that JPMorgan and DB owed a duty to them and that the banks proximately caused harm to them by breaching that duty. Thus the court denies defendant's motions to dismiss plaintiffs negligence claims. Alright, we're going to wrap up this episode right here, and in the next episode we're going to wrap up the whole document. And that's going to start with section L, intentional inflection of emotional distress. All of the information that goes with this episode can be found in the description box. What's up everyone and welcome back to the Epstein Chronicles. In this episode we're getting right back to Judge Raykov's opinion and order, and we're going to finish that bad boy up. L, intentional inflection of emotional distress. JPM Jando and DB Jando also allege that JPMorgan and DB intentionally inflicted emotional distress upon them. The elements of such a claim under here applicable New York law are one extreme and outrageous conduct, two the intent to cause or the disregard of a substantial likelihood of

22:54causing severe emotional distress, three causation and four severe emotional distress. Ascredge versus diocese of Brooklyn 210 AD 3D 1056 1057 New York Appeals Division 2022. At the outset the court notes that this cause of action is highly disfavored and almost never successful. Sesto versus Slein 171 F dot S UPP 3D 194 20102 SDNY 2016. That is especially so when as here the plaintiff asserts a negligence claim. Since almost all conduct that amounts to the intentional inflection of emotional distress also constitutes negligence i.i.e. declaims are routinely dismissed for their redundancy with negligence claims. C E G Wolkstein versus Morgan Stern 275 AD 2D 635 637 New York Appeals Division First Department 2000.

23:55Generally a cause of action for inflection of emotional distress is not allowed if essentially duplicative of tort or contract cause of action. Samuel at all versus Rockefeller University 2022 WL 2916 784 at 2 NY Supreme Court July 25th 2022. Dismissing i.i.e. declaims as duplicative of negligence claim. So it is with the Jane Doe's i.i.e. declaims if the conduct of JP Morgan and DB was extreme and outrageous and was intended to cause or was made with reckless disregard for severe emotional distress and in fact cause severe emotional distress JP Morgan and DB were thereby also liable for negligence. This alone is likely sufficient grounds for dismissal. Additionally the plaintiffs fell to a ledge that JP Morgan and DB intentionally directed their conduct at them. Martin vs City Bank NA 762 F.2D 212 220 second circuit

24:581985. The conduct must also be intentionally directed at the plaintiffs. None of the plaintiffs allegations support the inference that either JP Morgan or DB directed their conduct at JPM, J&O or DB J&O specifically. Instead they all alleged to have finance Jeffrey Epstein who then harmed JPM, J&O, DB, J&O and others. While the plaintiffs' harm might have been a foreseeable consequence of defendant's actions, the allegations in the complaints do not support the inference that it was specifically directed towards them. For both of these reasons plaintiffs i.i.e. declaims are dismissed. M. Aiding and a betting battery. Last JPM, J&O and DB J&O alleged that JP Morgan and DB aided and abetted the battery of them. They claim that Jeffrey Epstein and his associates sexually abused them. Acts that amounted to battery and that the defendant supported those wrongs. Under the New York Law there are three elements of Aiding and a betting battery. One, a wrong

26:00philac producing an injury. Two, the defendant's awareness of a role as part of an overall illegal or torteous activity at the time he provided the assistance. And three, the defendant's knowing and substantial assistance in the principal violation. Scolo versus Nunes, 847 and YS2D 899 Supreme Court 2007. Affidavid at 60AD 3D 840 New York Appeals Court 2009. The defendant's focus on this last element, whether they provided knowing and substantial assistance to those who battered the Jane Does. Knowledge for these purposes is actual knowledge. Learner vs. Fleet Bank, NA 459 F.3D 273 292 Second Circuit 2006. JP Morgan Chase Bank vs. Winick 406 F.SUPP 2D 247 253 4. SDNY 2005 The weight of the case law cited above defines knowledge in the context of an Aiding

27:02and a betting claim as actual knowledge. Colbeck vs. Lydam Incorporated 939 F.SUPP 240 246 SDNY 1996 152 F.3D 918 Second Circuit 1998 New York Common Law which controls the analysis here has not adopted a constructive knowledge standard for imposing Aiding and a betting liability. Rather, New York courts and federal courts in this district have required actual knowledge. Steinberg vs. Goldstein 279 NYS 242 42 Appeals Division 1967 Substantial assistance, meanwhile, requires committing some overt act either by words or conduct in further ends of the battery of plaintiff. McCurran in vs. Vicaro 91 NYS 3D 478 481 Appeals Division 2019 Lindsay vs. Lockwood 625 NYS.2D 393 397 Supreme Court 1994

28:03That in turn requires intentional or deliberate acts directed at causing harm which would rise to the level of actionable conduct in relation to the subject assault. Shave vs. Cornell University 192 AD2D 857 858 596 NYS 2D 502 503 1993 As explained above, the complaints are the void of facts which support the allegation that the acts of JP Morgan and DB were specifically and intentionally directed at causing harm to the Jane Does. Thus, the defendant's motions to dismiss plaintiff's claims for Aiding and a betting battery are granted. 3. The conclusion for the four-going reasons the court hereby reconfirms its rulings in its bottom line order of March 20, 2023. Defendants' motions to dismiss are therefore granted in part and denied in part as specified below. With respect to Jane Doe vs. DB At all 22-cv-10018, the court's grant defendants motion to dismiss with respects to counts

29:102, 3, 4, 5, 7, 8, 9, and 10 of the first amended complaint. The court denies defendants' motions with respect to counts 1, 6, 11, and 12 of the first amended complaint. Thus for clarity, the following claims asserted by plaintiff Jane Doe against defendant DB, DB AG New York Branch, and DB Trust Company Americas remain as part of the case. 1. The claim that defendants knowingly benefited from participating in a sex trafficking venture in violation of US Code 18, Section 1591, A and 2. 2. The claim that defendants obstructed enforcement of the Trafficking Victims Protection Act in violation of US Code 18, Section 1591, D. 3. The claim that defendants negligently failed to exercise reasonable care to prevent physical harm and for the claim that defendants negligently failed to exercise reasonable care as a banking institution providing non-routine

30:13banking. All other claims are dismissed. With respect to Jane Doe vs. JP Morgan, Chase Bank, NA 22-10019, the court grants defendants' motion to dismiss with respect to counts 1, 2, 6, 7, 8, and 9 of the first amended complaint. The court denies defendants' motions with respect to counts 3, 4, 5, and 10 of the first amended complaint. Thus for clarity, the following claims asserted by plaintiff Jane Doe against defendant JP Morgan, Chase Bank, NA remain as part of the case. 1. The claim that defendants negligently failed to exercise reasonable care to prevent physical harm. 2. The claim that defendants negligently failed to exercise reasonable care as a banking institution providing non-routine banking. 3. The claim that the defendant knowingly benefited from participating in a sex trafficking venture. In violation of US Code 18, Section 1591, A and 2,

31:13and 4, the claim that defendants obstructed enforcement of the Trafficking Victims Protection Act and violation of US Code 18, Section 1591, D. All other claims are dismissed. With respect to the government of the United States Virgin Islands vs. JP Morgan, Chase, NA 22-CV, 10904, the court grants the defendants' motion to dismiss with respect to counts 2, 3, and 4 of the first amended complaint. The court denies the defendant's motion with respect to count one of the first amended complaint. Thus for clarity, the claim of plaintiff, the government of the United States Virgin Islands, that defendants JP Morgan, Chase Bank, NA knowingly benefited from participating in a sex trafficking venture. In violation of US Code 18, Section 1591, A and 2 remains as part of the case. All other claims are dismissed. So ordered by Judge Jed Raykov, and this was signed and dated

32:14on May 1st of 2023. All right folks, so that's going to do it not only for this episode, but for the whole entire order and opinion given by Judge Raykov. So that gives us a little more clarity as to where things might be going when it comes to the USVI and the lawsuit filed against the survivors, because the blueprint has already been put out now. So if the survivors just follow this blueprint, my guess is that eventually they're going to hit pay dirt, and guess what? They deserve every single dollar that they might get. All right, so that might be the end of this one, but as you can imagine, we have plenty more to get to. All of the information that goes with this episode can be found in the description box. What's up everyone and welcome back to the Epstein Chronicles. Just daily and Jeffrey Epstein were obviously a lot closer than just daily wants to let on. And as we learn more information from this lawsuit as far as some of the details,

33:16as far as those emails and the conversations that they were having, it fills in a lot of the blanks and it confirms a lot of the rumor out there about just daily and his relationship with Jeffrey Epstein. And now we're learning that not only were they having these weird-ass conversations using code word and all kinds of other goofy stuff, Epstein allegedly sent just daily a photo of a young woman in a sexually suggestive pose. And that's according to Judge Raykov himself. And he also released a 54 page filing explaining why he made the rulings that he made. And over the course of the next few days, we're going to dive a little deeper into those court rulings and into some of those filings and pick out some of the more interesting parts to talk about here on the podcast. But before we get there, Law and Crime has an article out and this article is talking about the photo that was allegedly sent to Jess daily by Jeffrey Epstein. So let's get this

34:22quick update and let's see where we're at. Headline, Jeffrey Epstein sent ex-senior JP Morgan exec photo of young woman in sexually suggestive pose. The judge says, this article was authored by Adam Klassfeld. Then top JP Morgan chase executive, Jess Staley allegedly abused some of Jeffrey Epstein's victims and received a sexually suggestive photograph of one young woman from the now deceased pedophile, a judge indicated in a ruling. And again, this isn't in you end though. This isn't some knucklehead sitting on Twitter just talking nonsense. This is what the judge who's overseeing this case had to say. And this is all part of why he's letting this ruling move forward. He finds merit in what these survivors, what these victims have to say. And considering everything we know about the relationship between Jess Staley and Jeffrey Epstein, I don't know how

35:22as a judge or anyone in a position of power, how you wouldn't be interested in learning more. And having this progress to a point where we're at discovery, where people are being deposed, and to where things are getting aired out in open court. Because we all know that transparency is the best medicine here. And we also know that that's the reason why nothing has ever really been transparent when we're talking about Epstein. If the false narrative surrounding Epstein ever broke down and the regular old Joe found out the real story forget it. Because people, for the most part, only know a part of the story as far as Epstein's concerns. They only know the little tidbits that have been on TV or that have been in documentaries like Filthy Rich. The average person doesn't understand the levels of the corruption surrounding this dude, or how deeply he was entrenched at basically every level of power from the local municipality level

36:22all the way up to the White House, where he was visiting 17 times. Released on Monday afternoon, senior US District Judge Jed Raycoff's 54-page opinion and order explains why he advanced claims alleging that JP Morgan and Deutsche Bank knowingly profited from Jeffrey Epstein's sex trafficking scheme. Raycoff revealed new details about the bank and its former executives in explaining his reasoning. And I have to tell you I was on the fence about Judge Raycoff and his decisions and if he was going to let this move forward, I'm honestly surprised that we're at the point we're at. Because it's very rare that an institution like JP Morgan or people like Jess Staley or Jamie Diamond are held accountable for anything. Usually people like this will get a fine and they'll keep it moving. And there's never any real accountability or anybody really facing serious consequences. And that's because these institutions have so much

37:25money that they're able to just pay their way out of any trouble they ever find themselves in. And this is how it's been historically for the banks forever. The financial sector is able to do basically whatever they want because who do you think is funding all of your favorite politicians? Do you think they got to Washington DC on your $20 donation? They absolutely did not. They got there by all of their handlers and by all of their backboys working in the financial sector who are giving them money hand over fist. And then when they give them that money, well, they expect something in return, right? This isn't charity. This isn't altruism. This is nothing more than pay to play politics. We'll give you the money to get elected than you as the lawmaker will make sure that we have favorable laws on the books so that we can maneuver and continue to get rich by pilfering the wealth of everybody else. The most prominent among these bankers is Staley who later moved on to become the CEO of Barclays Bank before

38:28resigning amid scrutiny of his Epstein ties. JP Morgan has tried to shift the blame to Staley in a separate lawsuit claiming that their former executive disguised his Epstein ties for personal reasons. Jane Doe, the anonymous woman suing JP Morgan in a proposed class action claimed in a deposition that Staley sexually abused her. So look, we're not talking about just financial enabling here, right? Because we all know that there's levels to this. And while Staley has always been rumored to be really close with Epstein, we had never really seen any public accusations about Staley being involved in the actual abuse. Now behind the scenes, that's a whole different story. Rumors have been rampant for a very long time. That not only just Staley, but other people involved with Jeffrey Epstein financially took part in this abuse. And we have had several names, prominent names thrown out there by Virginia Roberts and others. But how many girls behind the scenes women who

39:31have never come forward were abused by Jeffrey Epstein and his gross ass pals and still to this day haven't come forward with those allegations. My guess is that's in the hundreds and that's not even hyperbole. We're talking about decades of abuse where this man continuously did what he was doing. You don't take a break from this. This behavior was Epstein's thing. It wasn't something he could turn on and off. This is how he rolled all the time. So how many hundreds thousands of women are out there that we have never even heard from women in war torn countries, women in places of great poverty. It's a wide known fact that Jeffrey Epstein loved to use places like Easter in Europe to find women to abuse. So how many are out there that we have never heard from? Raycoff's ruling suggests that she's not his only accuser. The judge noted that the women in the class alleged that Mr. Staley himself abused some of Epstein survivors, including JPM Jane Doe

40:33herself abbreviating JP Morgan. So that's what they're calling Jane Doe in the JP Morgan suit. JP Jane Doe. So that's what he's referring to her as in his ruling. And as we go through these stories, these articles, I'm sure that's what he's going to be referring to. Jane Doe as from here on out. And like I said in the last episode, there are certainly some hints as to who Jane Doe is. But until that name is announced, if it's ever announced, I'm not going to jump in here and really dive too deep and try and unfurl who that person is. They filed this lawsuit in an anonymous fashion for a reason, right? But I will say that they didn't do a great job in masking the person's identity. If you're following along with the story and you're looking at the allegations in the lawsuit and certain facts that they point out. JP Jane Doe claims that one of Epstein's friends, whom she later identified as Mr. Staley, used aggressive force in his sexual assault over

41:37and informed JP Jane Doe that he had Epstein's permission to do what he wanted to her, the ruling states in a separate lawsuit, the Virgin Islands government, unsealed eye opening details about Staley and Epstein's relationship. The attorney general's office there claims that Epstein exchanged approximately 1,200 emails with Staley's work email address between 2008 and 2012. They didn't even set up like burner accounts or anything. They were so brazen and not worried that they were ever going to face any kind of scrutiny that they were like, we'll just have these conversations out in the open on your work email account. And thankfully they did because if they didn't, we might not have ever seen any of the contents of those emails. These communications show a close personal relationship and profound friendship between the two men and even suggest that Staley may have been involved in the Epstein sex trafficking operation. The Virgin Islands

42:38lawsuit states, heavy words, right? And again, we're not talking about somebody making allegations from the peanut gallery. This is the attorney general's office of the US Virgin Islands. So these are serious accusations and the judge is certainly treating them as such. In December 2009, well after Epstein's conviction for soliciting prostitution from a minor, Epstein allegedly sent Staley to emails each showing a photograph of a young woman. Those images are redacted entirely in the Virgin Islands complaint, but Judge Reikov describes one of them in his ruling. One of them dated December 5, 2009, attached a picture of a young woman in a sexually suggestive pose. The judge said the ruling notes that another email from December 20, 2009 consisted entirely of a picture of a young woman. So who are these young women? And are they people that have been previously known as accusers? We probably will never know. I'm just asking

43:41in that as a rhetorical question at this point. Staley's attorney didn't immediately respond to an email requesting comment. I mean, what do you say to something like that as the attorney? No comments probably the right way to go. You have the judge coming out here and making what can only be called inflammatory remarks in his ruling and certainly not remarks that are friendly to Jeff Staley or to JP Morgan. So it's going to be very, very interesting to watch this all unfold and to see what happens come trial time in October. So until then we'll continue to add pieces to the puzzle until a full HD picture appears. All right, everybody, that's going to do it for this one. All of the information that goes with the episode can be found in the description box.