December 4, 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.
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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 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
(00:23):
Chang do one realleges and incorporates, by paragraphs one through
two thirty six, as if fully set forth in this count.
Plaintiff Chang do One brings this count individually 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 JY. This count for intentional and Negligent Acts
(00:44):
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 which would constitute a sexual offense as defined
an Article one hundred and thirty of the Penal Law
(01:05):
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
(01:25):
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 jan
do I and the class members to exercise reasonable care
to monitor J P. Morgan's customers, including Jeffrey Epstein, for
the purpose of preventing them from facilitating and engaging in
(01:46):
foreseeable criminal activity using bank's 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 Jane do One seeks
to represent. The legal duties of JP Morgan include, but
are not limited to, following the Know Your Customer laws
(02:08):
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.
(02:29):
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
(02:51):
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
(03:13):
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,
(03:38):
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.
(04:02):
The injuries that occurred were readily foreseeable by JP Morgan.
The injuries at plaintiff Janng 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.
(04:24):
The injuries at plaintiff Channg Do one and the class
members suffered included injuries directly and proximately suffered as a
result of sex offenses 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.
(04:48):
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 cause plaintiff chan do One 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,
(05:13):
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,
(05:34):
including Jane do One and the class members. In the
exercise of reasonable care, JP Morgan and its employees new
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
(05:55):
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
(06:19):
should have been aware, that Epstein was a high risk
to commit sex offenses against young women and girls. Plaintiff
Jang 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 foreseeably created substantial risk of Jeffrey Epstein and
(06:41):
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
(07:03):
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
(07:27):
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.
(07:47):
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 non negligent actions and omissions described in
this count. Plaintiff Chang Do one and the class members
have sustained both general and specified damages in substantial amounts
(08:10):
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. Defend and
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
(08:32):
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
(08:54):
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
(09:16):
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 sextually abuse Jane do
One as well as other class members and caused Jane
do One as well as other class members to engage
in commercial sex acts. Some of Epstein's victims were under
(09:39):
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 depositive these funds in exchange for JP Morgan's facilitation
(10:03):
and participation in the sex trafficking venture. Among the financial
benefits that the defendant received form 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
(10:24):
JP Morgan in exchange for its facilitation and participation in
his sex trafficking venture. JP Morgan knew and recklessly 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
(10:47):
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
conscer spar seed or recruit, solicit, entice, coerce, harbor, transport, obtain,
and provide Jane Doe one, as well as other members
of the class, into commercial sex acts through the means
(11:10):
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
(11:31):
fraud and force Jane Doe 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 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
(00:23):
Chang do one realleges and incorporates, by paragraphs one through
two thirty six, as if fully set forth in this count.
Plaintiff Chang do One brings this count individually 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 JY. This count for intentional and Negligent Acts
(00:44):
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 which would constitute a sexual offense as defined
an Article one hundred and thirty of the Penal Law
(01:05):
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
(01:25):
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 jan
do I and the class members to exercise reasonable care
to monitor J P. Morgan's customers, including Jeffrey Epstein, for
the purpose of preventing them from facilitating and engaging in
(01:46):
foreseeable criminal activity using bank's 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 Jane do One seeks
to represent. The legal duties of JP Morgan include, but
are not limited to, following the Know Your Customer laws
(02:08):
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.
(02:29):
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
(02:51):
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
(03:13):
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,
(03:38):
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.
(04:02):
The injuries that occurred were readily foreseeable by JP Morgan.
The injuries at plaintiff Janng 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.
(04:24):
The injuries at plaintiff Channg Do one and the class
members suffered included injuries directly and proximately suffered as a
result of sex offenses 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.
(04:48):
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 cause plaintiff chan do One 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,
(05:13):
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,
(05:34):
including Jane do One and the class members. In the
exercise of reasonable care, JP Morgan and its employees new
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
(05:55):
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
(06:19):
should have been aware, that Epstein was a high risk
to commit sex offenses against young women and girls. Plaintiff
Jang 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 foreseeably created substantial risk of Jeffrey Epstein and
(06:41):
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
(07:03):
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
(07:27):
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.
(07:47):
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 non negligent actions and omissions described in
this count. Plaintiff Chang Do one and the class members
have sustained both general and specified damages in substantial amounts
(08:10):
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. Defend and
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
(08:32):
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
(08:54):
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
(09:16):
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 sextually abuse Jane do
One as well as other class members and caused Jane
do One as well as other class members to engage
in commercial sex acts. Some of Epstein's victims were under
(09:39):
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 depositive these funds in exchange for JP Morgan's facilitation
(10:03):
and participation in the sex trafficking venture. Among the financial
benefits that the defendant received form 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
(10:24):
JP Morgan in exchange for its facilitation and participation in
his sex trafficking venture. JP Morgan knew and recklessly 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
(10:47):
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
conscer spar seed or recruit, solicit, entice, coerce, harbor, transport, obtain,
and provide Jane Doe one, as well as other members
of the class, into commercial sex acts through the means
(11:10):
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
(11:31):
fraud and force Jane Doe 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.
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