December 3, 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.
to contact me:
bobbycapucci@protonmail.com
source:
Microsoft Word - 00513854.DOCX
Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
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.
to contact me:
bobbycapucci@protonmail.com
source:
Microsoft Word - 00513854.DOCX
Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.
Mark as Played
Transcript
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 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
(00:21):
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 corese commercial sex
(00:44):
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.
(01:06):
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
(01:29):
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
(01:50):
that Epstein had pled guilty and serve prison time for
engaging in sex with a minor, but also that there
were public allegations that its 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
(02:11):
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
(02:34):
was critical of to 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
(02:58):
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
(03:19):
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,
(03:41):
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
(04:01):
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
(04:24):
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
(04:44):
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
(05:07):
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 a civil Procedure
twenty three B three twenty three C four on behalf
(05:28):
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,
(05:53):
including the addition of one or more sub classes, after
having the opportunity to conduct discovery. The class consists of
dozens of women, making joind or 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,
(06:17):
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
(06:38):
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
(07:02):
of common issues under federarcivp. 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, entyight, solicited, harbored, provided, obtained, and
(07:27):
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
(07:50):
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
(08:13):
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
(08:33):
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
(08:54):
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
(09:17):
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.
(09:38):
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
(09:59):
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,
(10:22):
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,
(10:46):
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 desire 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
(11:10):
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 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
(00:21):
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 corese commercial sex
(00:44):
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.
(01:06):
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
(01:29):
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
(01:50):
that Epstein had pled guilty and serve prison time for
engaging in sex with a minor, but also that there
were public allegations that its 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
(02:11):
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
(02:34):
was critical of to 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
(02:58):
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
(03:19):
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,
(03:41):
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
(04:01):
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
(04:24):
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
(04:44):
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
(05:07):
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 a civil Procedure
twenty three B three twenty three C four on behalf
(05:28):
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,
(05:53):
including the addition of one or more sub classes, after
having the opportunity to conduct discovery. The class consists of
dozens of women, making joind or 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,
(06:17):
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
(06:38):
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
(07:02):
of common issues under federarcivp. 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, entyight, solicited, harbored, provided, obtained, and
(07:27):
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
(07:50):
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
(08:13):
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
(08:33):
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
(08:54):
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
(09:17):
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.
(09:38):
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
(09:59):
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,
(10:22):
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,
(10:46):
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 desire 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
(11:10):
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.
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