The USVI And Their Motion In Opposition To JP Morgan's Request For Dismissal (Part 3) (9/11/26)

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1:22What's up everyone and welcome back to the Epstein Chronicles. In this episode, we're going to pick up where we left off with the USVI's motion to deny the request by JP Morgan to have the lawsuit dismissed. GG salesforce.com incorporated 603 F dot supp 3d 626 Northern District of Illinois 2022. Also does not support JP Morgan's argument that the government does not sufficiently alleged participation. In salesforce.com the court held that the plaintiff fell to alleged participation by a software supplier, whose software was used by an online marketplace, the post advertisements for commercial sex. 603 F dot supp 3d at 646 and 47. The court found no plausible allegations that salesforce did anything but just sell back page off the shelf software.

2:27ID at 648 finding no personalized services tailored to back page customization of its software to meet back pages needs. In other words, salesforce merely supplied its regular product to back page. Unlike salesforce.com JP Morgan did much more than provide Epstein with its regular banking services. It handled payments Epstein was making to young women who were his victims and recruiters, totaling millions of dollars, which had no conceivable relationship to Epstein's stated business interests. It further handled payments from accounts of Epstein's charitable organizations to young women, which again had no conceivable relationship to the charity's stated purpose. It ignored obvious red flags relating to Epstein's accounts that in the normal course would have prompted action by JP Morgan and instead reported nothing unusual in Epstein's account transactions. It felt to demonstrate even basic due diligence on Epstein's accounts, particularly irregular given Epstein was a high risk customer.

3:27It continued to maintain Epstein's assets for over a decade, despite the fact that he played guilty to criminal felony charges, constituting child trafficking, and its internal security, risk management, and compliance teams, repeatedly identified evidence of child and human sex trafficking. JP Morgan gave Epstein the most personalized and customized and illegal services. Moreover, unlike salesforce.com, JP Morgan had redacted. Further, salesforce.com differentiated cases where there was a showing of a continuous business relationship between the trafficker and the defendant, such that it would appear that the trafficker and the defendant have established a pattern of conduct or could be said to have a tacit agreement as to the venture. 603-F.SUPP3D at 644 In MA versus Wyndham Hotels and Resorts Incorporated, 425-SUPP3D-959-962-97071 For example, the court found a sufficiently continuous relationship to constitute participation where the defendant, Hotel Operator, repeatedly rented rooms to a trafficker over 17 months.

4:37Here, while doing business with Epstein, and in beyond his accounts, JP Morgan handled and redacted Epstein's payments to victims and recruiters for over 10 years. JP Morgan, separately, contends that it's redacted and redacted, does not constitute participation because redacted. Putting aside that JP Morgan ignores the government's allegations that it facilitated the sex trafficking by handling payments to victims and recruiters, the government's claim is that JP Morgan did detect Epstein's sex trafficking, but redacted. In turn, allowing Epstein's ongoing and future sex trafficking. 2. JP Morgan knew or acted with reckless disregard that minors would be caused to engage in commercial sex. JP Morgan acted with knowledge or reckless disregard that Epstein was sex trafficking minors based on law enforcement indictments, Epstein's own criminal guilty plea, and numerous additional law enforcement investigations. In 2006, JP Morgan knew that Epstein had been indicted for and later pled guilty to federal criminal charges of solicitation and procurement of a minor for prostitution.

5:44Solicitation and procurement of a minor for prostitution are acts covered by section 1591, A&2. Recruits and Tices, Harbors, Transport, Provides, Obtains, Maintains, or Solicits by any means a person and the person has not attained the age of 18 years and will be caused to engage in a Commercial Sex Act. The government further alleges that in 2009, the non-prossecution agreement between Epstein and the United States became public and revealed information, federal law enforcement allegations that Epstein may have used interstate commerce to induce minors, to engage in prostitution. Engaged illicit sexual act conduct with minors and traffic minors. The complaint details other law enforcement investigations of child sex trafficking by Epstein, of which JP Morgan was aware based on investigations and reports by its own security, risk management, and compliance teams. In a 2010 internal email, JP Morgan's Risk Management Division wrote of new allegations of an investigation related to child sex trafficking. Are you still comfortable with this client who is now a registered sex offender?

6:52In March 2011, JP Morgan's Global Corporate Security Division reported that it was aware of numerous articles detailing various law enforcement agencies investigating Jeffrey Epstein for allegedly participating directly or indirectly in child sex trafficking and molesting underage girls. Jeffrey Epstein is settled a dozen civil lawsuits out of court from his victims regarding solicitation for an undisclosed amount. The same internal JP Morgan reports pointed to derogatory information that Jean-Luc Brunel, owner of the MC2 Model Management and Jeffrey Epstein, engaged in unracquitering that involved, learning in minor children for sexual play for money. The government also alleges that Epstein, through JP Morgan, paid more than $600,000 to Jane Doe 1, a woman with an Eastern European surname, who JP Morgan's own due diligence reports, stated Epstein purchased at the age of 14. 3. JP Morgan's Knowledge or a Reckless Disregard of the Use of Force, Threats, Fraud, or Corrigian.

7:58With respective victims 18 and over, Section 1591A2 requires that a beneficiary of sex trafficking like JP Morgan has acted with knowledge or a reckless disregard of the fact that means of force, fraud, and or coercion will be used to cause the victim to engage in commercial sex acts. The government alleges that JP Morgan knew it was processing Epstein's payments to specific young women around the world. That these young women were trafficked by or recruiters of victims for Epstein, and that JP Morgan knew these payments had no conceivable relationship to Epstein's stated business interests, and that JP Morgan knew that Epstein was being connected repeatedly to human trafficking activity. After Epstein's arrest and death in 2019, JP Morgan acknowledged that recipients of the payments may be victims of human trafficking. In addition to consistent references to human trafficking, JP Morgan, the government, alleges that JP Morgan's internal reports showed accounts of MC2, modeling agency, and Epstein, learning victims.

9:02It is inferrable that the young women would have been lured by a modeling agency with a fraudulent promise of modeling opportunities and careers. Moreover, JP Morgan handled payments for numerous women with Eastern European surnames, who were publicly and internally identified as Epstein recruiters and or victims, including Jane Dull 1, who JP Morgan's own internal reports stated Epstein purchased when she was a child. It is inferrable that these young women from Eastern Europe were subject to fraud, force, or coercion. JP Morgan argues that the government fails to allege knowledge of trafficking for a specific victim, motion at 10. This argument's incorrect for two reasons. First, JP Morgan omits Section 1591A's coverage of a defendant having reckless disregard. Second, JP Morgan ignores that the government identifies 20 specific young women who are trafficked by Epstein and the Virgin Islands and Delswar, for whom JP Morgan handled Epstein's payments knowing there was no conceivable relationship to Epstein's own.

10:03The former state of the world was repeatedly being connected to trafficking and recognizing that these women may be victims of human trafficking. JP Morgan's own internal reports stated that Epstein purchased Jane Dull 1 at 14. Yet it processed $600,000 in payments by Epstein tour. The government also alleges that JP Morgan had up close view of Epstein's conduct. These allegations support a plausible inference that JP Morgan knew or at a minimum acted with reckless disregard for the probability that these women were being subjected to forced threats of fraud and or coercion.

11:12CEG stood over his freshman 164F.3D820A27 second circuit 1999. Epstein's reckless disregard shown by recognition of substantial probability of harm and action with disregard for its occurrence. JP Morgan separately argues that the government cannot establish knowledge based solely on JP Morgan's awareness of allegations of Epstein's trafficking. Again, JP Morgan omits reckless disregard Epstein's guilty plea to conduct that constitutes child sex trafficking under Section 1591, which is knowledge, not an allegation, and its own observation of red flags and adoption of the trafficking allegations. Moreover, the allegations, or lack thereof, in Grubella are a far cry from this case. Grubella found that there was no evidence of knowledge of wrongdoing, not even allegations. 318F.SUPP3D at 701 Argument that the government knew of the fraudulent conduct at issue is pure speculation.

12:14In Escobar, the allegations that were held insufficient to give rise to knowledge were some complaints by private individuals to state regulators about a health care provider. The allegations were numerous, widely reported, in many cases involved law enforcement investigations and extended over a number of years. Given Epstein was a registered sex offender, felon, and high-risk client, JP Morgan's failure to follow up on these allegations other than to assign Staley, whose JP Morgan email strongly suggests he was involved in Epstein's ex-traveling, and whose relationship with Epstein catapulted his career to talk to Epstein at a minimum shows reckless disregard. JP Morgan cites SJ versus Choisotelle's International 473 SUPP3D 147154 EDNY 2020. See a motion at 12 and 13 for the proposition that knowledge or willful blindness of a general sex trafficking problem does not satisfy the men's rear requirements of the TVPA.

13:15This is an opposite because the government alleges that JP Morgan had general knowledge of trafficking, but that it had knowledge of the specific sex trafficking venture. Epstein was operating through the foregoing evidence that was uniquely in its sights. Alright, we're going to wrap this episode up right here, and in the next episode dealing with the topic we're going to pick up where we left off, and that's with part 4. JP Morgan knowingly benefited. All of the information that goes with this episode can be found in the description box.