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December 2, 2025 11 mins
In the United States District Court for the Southern District of New York, a class action lawsuit titled Jane Doe 1, individually and on behalf of all others similarly situated v. JP Morgan Chase & Co. was filed. The complaint represented not only Jane Doe 1, but a broader group of alleged victims who claimed they suffered harm tied to the actions—and alleged inaction—of JP Morgan Chase & Co. The filing formally demanded a jury trial, signaling the plaintiffs’ intention to take the allegations into open court rather than resolve them quietly behind closed doors.


The case was framed as both an individual and a class action complaint, raising the stakes considerably for the financial giant. By categorizing it this way, the plaintiffs positioned their claims as part of a larger systemic issue involving an entire group of alleged victims. The filing marked the beginning of what later became one of the most scrutinized legal battles connected to the Jeffrey Epstein network, setting the stage for intense public inquiry into the bank’s role and potential liability.


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Episode Transcript

Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:00):
What's up everyone, and welcome to another episode of the
Epstein Chronicles. In this episode, we're going to die of
right back in to the survivor's lawsuit filed against JP Morgan.
JP Morgan's knowledge about the Epstein venture, JP Morgan felt
in various respects to meet it's know your customer and
other obligations fully with respect to his relationship with Jeffrey

(00:22):
Epstein and entities related to Jeffrey Epstein. JP Morgan was
aware that Epstein was a wealthy man with hundreds of
millions of dollars in assets and an extensive network of
friends and connections that included prominent financial institutions, politicians, royalty,
and billionaires. JP Morgan was aware that Epstein also had
a well publicized reputation for sexually trafficking and abusing young women.

(00:47):
Allegations against them began appearing in the press as early
as March of two thousand and five with the accusation
that he paid a fourteen year old girl for a massage.
That year, the Palm Beach, Florida Police Department began an
investortigation and allegations against Epstein related to his sexual abuse
in Palm Beach. The investigation quickly uncovered dozens of other

(01:08):
Epstein sex abuse victims. The investigation also identified the Epstein
sex trafficking venture, which included a number of individuals who
were responsible for recruiting young women to come to Epstein's
Palm Beach mansion to give massages or otherwise furthering his abuse.
In two thousand and six, the state attorney handling the case,
after meeting privately with an attorney representing Epstein, referred the

(01:31):
case to a state grand jury instead of charging Epstein
and as co conspirators for crimes for which local police
believed there was an abundance of evidence. As a result,
the Palm Beach Police chief publicly denounced the state attorney
and referred the case to the Federal Bureau, which subsequently
opened its own investigation and interviewed potential witnesses and victims.

(01:54):
In September two thousand and seven, Epstein agreed to plead
guilty to two prostitution charges in state court, including the
solicitation of a minor to engage in prostitution, in exchange
for a federal non prosecution agreement providing him and co conspirators,
including Leslie Groff, Sarah Kellen, Adriana Ross, and Nadia Maarsenkova

(02:14):
with immunity from federal prosecution for extensive federal sex trafficking
charges in Florida. The deal included an eighteen month sentence
in Epstein was also required to register as a sex
offender upon his release. Epstein ultimately served only thirteen months
of his eighteen month sentence in the Palm Beach County
Jail and was allowed work release privileges that enabled him

(02:36):
to leave jail six days a week for twelve hours
a day. In the summer of two thousand and eight,
Epstein's non prosecution agreement with the US Department of Justice
was made public when it was unsealed in connection with
a challenge to the NPA by two of his victims.
Among other things, the agreement outlined the possible federal sex
offense charges that could have resulted from the investigation, including

(02:59):
charges that Epstein conspired to use a means of interstate
commerce to induce miners to engage in prostitution, to engage
in illicit sexual conduct with miners, conspiring with others to
do the same, and trafficking miners. That agreement also noted
that the United States had compiled the list of the
individuals whom it identified as victims, and that Epstein would

(03:21):
pay for legal representation for these alleged victims. Core proceedings
involving the challenge to Ebstein's NPA continued between two thousand
and eight and twenty thirteen and beyond and attracted significant
media attention. Indeed, between two thousand and five and twenty thirteen,
press reports outlined the allegations underlining the NPA, and to

(03:42):
varying degrees, detailed the involvement of Epstein's alleged co conspirators,
including Leslie Groff, Sarah Kellen, and Nadia Marsenkova. Some articles
reported that Leslie Groff and Sarah Kellen had invoked their
Fifth Amendment right against self incrimination, and others reported that
Nadia Marsenkova had allegedly recruited underage girls to give Epstein massages. Additionally,

(04:05):
pressed reports during the time noted allegations that Epstein was
involved with Eastern European women in particular, and that a
modeling agency he helped fund, brought young girls, often from
Eastern Europe, to the US on Epstein's private jets at
all times. Material here too. JP Morgan was aware of
the foregoing information and more about Epstein's sex trafficking activities.

(04:28):
It is well known that JP Morgan did know that
a large number of cash transactions by a customer can
be an indicator of criminal activity generally and sex trafficking
in particular. Payments to victims of sex trafficking are often
made in cash to avoid leaving a paper trail for
law enforcement or other investigators to follow. For sexual exploitation

(04:49):
of victims has been estimated to generate approximately one hundred
billion dollars in yearly illicit profits, according to a recent
study by the Financial Action Task Force and iitled Financial
Flows from Human Trafficking. Given the illegal nature of sex trafficking,
individuals perpetrating the crime as well as laundering the proceeds

(05:09):
of that crime, may be identifiable by observing financial transactions
and information obtained by financial institutions in the course of
conducting their customer due diligence and the behavior of offenders,
sex trafficking organizations have the need for large amounts of
cash because many illegal transactions are often necessary to keep

(05:29):
the organization functioning. The technique that financial institutions use to
detect other criminal enterprises using their services can also be
employed to detect sex trafficking. For example, sex trafficking organizations
often use assets for money laundering, such as cash, real estate, cars, etc.
That other sex trafficking organizations use. Sex trafficking organizations may

(05:53):
also make cash deposits and withdrawals below customer identification thresholds
to avoid triggering additionals, scrutiny, or bank reporting requirements. Sex
trafficking organizations may also use multiple accounts to disguise the
nature of their illegal transactions, thereby laundering the funds involved.
One indicator of sex trafficking can be media coverage of

(06:15):
an account holder activities relating to sex trafficking. Another indicator
of sex trafficking can be recurring payments for transportation of
logistics service in the late night or early morning. A
similar indicator can be significant payments for transportation or logistics,
car rental, taxi and ride sharing service transactions. JP Morgan

(06:38):
participated in Epstein's violation of the TVPA by knowingly and
intentionally assisting, supporting, facilitating, and enabling Epstein's legal conduct and
sex trafficking venture, including in particular, is coercive sex trafficking
and violation of US Code eighteen, Section fifteen ninety one
A one. JP Morgan's conduct violated the TVPA, which forbids

(06:59):
benefit financially from participating in a venture that in or
affecting interstate or foreign commerce, has recruited, solicited, enticed, transported, harbored, provided,
or obtained a person knowing or in reckless disregard of
the fact that the person has been caused to engage
in a commercial sex act by the means of force,

(07:19):
threats of force, fraud, coercion, abuse of process, or a
combination of such means. JP Morgan's actions knowingly and intentionally
furthered the Epstein sex trafficking venture, including specifically Epstein's sex trafficking.
For example, JP Morgan provided cash to Ebstein, knowing that
he would use the cash to pay for commercial sex acts,

(07:40):
including sexualized massages during which Epstein penetrated Jane do Ie,
forcing her to engage in sexual activity. JP Morgan also
aided and abetted Epstein's sex trafficking venture by, among other things,
providing the financial underpinnings for the venture. JP Morgan enabled
Epstein to have ready and reliable access to ray resources,

(08:00):
including cash and a variety of bank accounts and other
financial tools to recruit, entice, solicit, harbor, provide, obtain, and
transport young women and girls to cause them to engage
in commercial sex acts. JP Morgan knowingly and intentionally benefited
financially and in other ways from its participation in Epstein's

(08:21):
sex trafficking venture with knowledge or with reckless disregard to
the fact that Epstein used means of force, threats of force, fraud,
and coercion, and combinations thereof to force young women and
girls into engaging into commercial sex acts. As recounted throughout
this complaint, JP Morgan financially benefited by earning millions of
dollars from its participation in the Epstein sex trafficking venture.

(08:45):
The benefits that JP Morgan received came directly from its
participation in the sex trafficking venture and because of its
participation in that venture. In other words, there was a
casual relationship between JP Morgan's conduct furthering epstein sex trafficking
venture and its receipt of the financial benefits. With actual
and constructive knowledge of that casual relationship, JP Morgan knowingly

(09:10):
and intentionally financed Epstein's legal sex trafficking venture. JP Morgan
knew that if it did not finance Epstein's a legal
sex trafficking venture, then it would lose valuable Epstein related accounts.
Face with the choice between profiting from Epstein's sex trafficking
venture or following the law, JP Morgan chose to profit
in violation of various banking laws and regulations, including various

(09:33):
know your customer laws. JP Morgan regularly authorized cash withdrawals
and deposits for the Epstein sex trafficking venture, which allowed Epstein,
his co conspirators, and those they directed to conduct the
business of the sex trafficking venture. JP Morgan's knowing and
intentional banking law violations allowed Epstein in his various corporations

(09:53):
to stay under the radar and continue the sex trafficking
operation without close scrutiny or interference. JP Morgan knowingly and
intentionally benefited financially from Epstein's sex trafficking venture by facilitating
and financing Epstein's commercial sex acts in interstate and foreign commerce,
JP Morgan earned interest, commissions, service fees, and other financial

(10:16):
benefits directly from its connection with Epstein, Epstein related entities,
and others acting in concert with Epstein, and Epstein provided
those financial benefits to JP Morgan precisely because it was
facilitating his sex trafficking venture, and JP Morgan knew that
was the reason that Epstein was providing them with those

(10:36):
financial benefits. JP Morgan benefited by receiving things of value
from its participation in the Epstein sex trafficking venture. Among
the various things of value it received were I connections
with Jeffrey Epstein, his co conspirators, and his wealthy friends
and associates. Two additional deposits from Epstein, his co conspirators,

(10:56):
and his wealthy friends and associates. Three the upper ortunity
to earn financial benefits from the funds that he had
been deposited with JP Morgan. JP Morgan knowingly and intentionally
received these things of value as a direct result of
its participation in the Epstein sex trafficking venture and because
it was furthering Epstein's sex trafficking venture. Among the women

(11:19):
and girls who's sex trafficking and sex abuses, JP Morgan
furthered was Jane do one. All right, folks, we're gonna
wrap up right here and in the next episode dealing
with the topic, we're gonna pick up where we left off.
All of the information that goes with this episode can
be found in the description box.
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