# EXHIBIT 9 ## EXPERT REPORT OF BRIDGETTE CARR June 16, 2023 ### TABLE OF CONTENTS | I. | PROFESSIONAL BACKGROUND AND QUALIFICATIONS ..... | 1 | | ------ | ------------------------------------------------------------------------------------------------------------------------------- | ---- | | II. | FACTS OR DATA CONSIDERED ..... | 2 | | III. | METHODOLOGY USED ..... | 3 | | IV. | OPINIONS ..... | 3 | | | A. Human Trafficking Presents In Different Ways But Has The Same Core Elements ..... | 3 | | | B. One Common Theme In Human Trafficking Is The Targeting Of Vulnerable People To Victimize ..... | 6 | | | C. Human Trafficking Typologies And Red Flags Can Be Helpful When Assessing Potential Human Trafficking ..... | 8 | | | D. Jeffrey Epstein Directed A Sex Trafficking Venture..... | 13 | | | 1. Jeffrey Epstein Engaged In Commercial Sex With Girls Under The Age of 18..... | 14 | | | 2. Jeffrey Epstein Used Fraud, Force, And/Or Coercion To Induce Girls And Young Women To Perform Commercial Sex Acts ..... | 17 | | E. | JPMorgan's Due Diligence Indicates Epstein Was Involved In Sex Trafficking. 27 | 27 | | F. | Jes Staley's Communications With Epstein Show Red Flags For Human Trafficking ..... | 47 | | G. | Jeffrey Epstein's JPMorgan Accounts Show Signs Of Human Trafficking..... | 51 | | | 1. Large Cash Withdrawals..... | 53 | | | 2. Round-Dollar Wire Payments to Women ..... | 54 | | | 3. Payments To Individuals Supporting Epstein's Sex Trafficking Venture 55 | 55 | | | 4. Private Air Travel ..... | 56 | | | 5. MC2 Model Management ..... | 57 | | H. | Jeffrey Epstein's Sex Trafficking Venture Relied On Many Individuals And Entities—Including JPMorgan—To Operate ..... | 59 | | I. | JPMorgan Had A Unique Opportunity To Intervene And Help Epstein's Victims Who Banked With JPMorgan—Including [REDACTED]..... | 64 | | J. | Compensation For The Harms Victims Suffered Should Reflect The Severity, Scope, And Duration Of The Abuse They Suffered ..... | 72 | | K. | JPMorgan Should Implement Meaningful Injunctive Relief To Prevent Future Participation In Sex Trafficking Ventures ..... | 75 | | V. | CONCLUSION ..... | 77 | ### L PROFESSIONAL BACKGROUND AND QUALIFICATIONS - 1. My name is Bridgette Can. The Government of the United States Virgin Islands ("USVI") in this matter has retained me as an expert in human trafficking and specifically sex trafficking in the United States. My resume is attached as Exhibit A. I am being compensated for my work in this matter, and a list with my compensation rates is attached as Exhibit B. - 2. I reserve the right to supplement or amend my opinion in light of any further allegations, documents, depositions, or expert reports that may be prepared, provided, or may occur subsequent to this report. - 3. I am a member in good standing of the Michigan Bar. I am a Clinical Professor of Law and Co-Director of the Human Trafficking Clinic + Lab ("Clinic") at the University of Michigan Law School. I founded the Clinic at the University of Michigan Law School in 2009. It was the first law school clinic in the United States dedicated to representing victims' of human trafficking. The Clinic provides a variety of free legal services to victims of human trafficking. We serve victims of labor and/or sex trafficking regardless of age, gender, or national origin. - 4. Prior to joining Michigan Law School full-time in 2009, I spent fall 2008 as a visiting professor in Michigan Law School's clinical program and winter 2009 teaching Immigration Law and International Human Rights Law at the University of Toledo College of Law. - 5. For the 2007-2008 academic year, I worked at the University of Notre Dame Law School. At Notre Dame, I developed and established the Immigrant Rights Project in Notre Dame's clinical program. I taught Immigration Law and, in the Immigrant Rights Project, I represented foreign national clients in need of humanitarian immigration relief, including foreign national trafficking victims. - 6. Prior to joining the University of Notre Dame Law School, I was an Assistant Clinical Professor at Ave Maria School of Law ("Ave Maria") when it was based in Ann Arbor, Michigan. At Ave Maria, I founded the Asylum and Immigrant Rights Law Clinic. During my three years at Ave Maria, I represented foreign nationals in need of humanitarian immigration relief. It was during this time that I first provided legal representation to human trafficking victims. This representation focused on immigration relief and victim-witness rights advocacy for the victims in what would become United States v. Maksimenko, No. 05-80187 (E.D. Mich.) (forced labor of Ukrainian J-1 students in Detroit area strip clubs). The Maksimenko case was one of the first—if not the first federally prosecuted cases in the state of Michigan after the passage of the Trafficking Victims Protection Act in 2000. I use the word "victims" here and throughout my report because it is a term of art. My use of the term is not meant to disempower people who have survived human trafficking. - 7. In addition to the hundreds of trafficking victims I have represented through my work in clinics, I also provide paid and pro bono guidance on human trafficking cases for lawyers in the United States. This has included paid consultations for both labor trafficking and sex trafficking cases predominantly in the civil context. I have not previously testified as an expert at trial or deposition. - 8. I have published on the issue of human trafficking in academic journals and a legal casebook. I was the lead author for the first legal casebook in the United States on human trafficking law.2 I have been published in both legal and non-legal academic publications on the topic of human trafficking. A list of all publications I have authored in the previous 10 years is attached as Exhibit C. - 9. I have given hundreds of speeches, presentations, and trainings on human trafficking during my career. I am unable to meet the number of requests I receive to provide presentations or trainings on human trafficking. As a result of these requests and the need for high quality evidence-based training on human trafficking, my colleague from the University of Michigan School of Nursing and I created the Human Trafficking Collaborative ("Collaborative") at the University of Michigan. The Collaborative is a partnership between the Clinic and the University of Michigan School of Nursing to educate the public, including healthcare providers and advocates, about human trafficking. Dr. Munro-Kramer and I created an online training module for healthcare providers to help them address human trafficking in healthcare settings.3 The module has been available since February 2021. Thousands of individuals have taken the training. - 10. I have provided training and technical assistance to law professors in both the United States and abroad to assist in the creation of legal clinics serving human trafficking victims. I have helped multiple programs develop their training materials to educate law students about human trafficking and represent human trafficking victims. - 11. Over the past fifteen years, I have been interviewed and quoted by a variety of media outlets about human trafficking. ### IL FACTS OR DATA CONSIDERED - 12. I considered facts and data from this case, including documents the parties produced, one victim interview, expert reports, and depositions, in addition to the documents I cite in my report. I also relied on the expert reports in this case, including the forensic accounting conducted by Jorge Amador. A comprehensive list of the materials I relied upon is attached as Exhibit D. {sup}`2` Bridgette Carr, Anne Milgram, Kathleen., and Stephen Warnath, Human Trafficking Law and Policy, LexisNexis (1st ed. 2014). {sup}`3` Bridgette Carr, Dr. Munro-Kramer, Human Trafficking Training Module for Healthcare Providers and Advocates, https://humantrafficking.umich.edu/education/continuing-educationmodule/. ### III. METHODOLOGY USED - 13. In this matter I am offering my expert testimony regarding human trafficking, specifically sex trafficking and how it presents in cases in the United States, the typical signs of human trafficking, the power dynamics at work in human trafficking, and how victim vulnerabilities are identified and exploited. I apply my knowledge of human trafficking to the documents, depositions, victim statements, and other information to assess whether Jeffrey Epstein's behavior and victims' experiences are consistent with human trafficking of minors or adults through force, fraud, or coercion, and whether the information identified by or available to JPMorgan Chase Bank, N.A. ("JPMorgan") reflects red flags of trafficking. - 14. First, I review authoritative literature in the field of human trafficking to identify generally accepted and reliable typologies and indicators of human trafficking. I then apply these typologies and indicators to the documents and testimony that I reviewed, including documents and financial information available to, reviewed by, or created by JPMorgan. These included due diligence documents; information about Epstein's activities, such as the 2006 Probable Cause Affidavit, that were publicly and contemporaneously available; testimony, statements, and other documents related to individuals who participated in the Epstein Victim Compensation Program or otherwise identified as victims of Jeffrey Epstein, including Jane Doe; and an interview I conducted with an Epstein victim known to and banked by JPMorgan. I then assess, based on my professional experience and expertise, whether this information is consistent with typologies and indicators of human trafficking, including the use of force, fraud, or coercion. - 15. I offer such expert testimony to assist the Court in its determination of whether JPMorgan is civilly liable based on my knowledge, skill, education, experience, and training. I have arrived at this testimony by applying the principles and methods commonly used in the field of human trafficking in the United States, as well as through the knowledge and expertise I have gained as an academic and lawyer who has been providing legal representation to human trafficking victims and practicing, teaching, and writing in this field since 2006. ### IV. OPINIONS ### A. Human Trafficking Presents In Different Ways But Has The Same Core Elements - 16. Human trafficking presents in different ways, but, at its core, human trafficking involves a trafficker targeting vulnerable individuals and compelling them into service. Trafficking is a crime of exploitation, not movement, and as such victims may be United States citizens, undocumented migrants, legal permanent residents or any other foreign nationals with either immigrant or nonimmigrant status in the United States. The age of victims varies from the very young to the elderly. - 17. The Trafficking Victims Protection Act ("TVPA"), which was enacted in the United States in 2000, was the first comprehensive federal legislation specifically addressing human trafficking. Prior to the passage of the TVPA, prosecutors relied on the laws against involuntary servitude, debt peonage, and slavery to protect individuals compelled into service. - 18. The passage of the TVPA coincided with similar efforts at the international level to protect victims of what many were calling "modem day slavery." In the same year Congress passed the TVPA, the United Nations adopted the Protocol to Prevent, Suppress, and Punish Trafficking in Persons, Especially Women and Children ("Palermo Protocol") .° - 19. The TVPA defines several terms that I will reference throughout my report. I define them here for clarity. - 20. The TVPA created two categories for what is collectively known as "human trafficking" or, in the language of the statute, "severe forms of trafficking in persons." They are defined as: - a. The recruitment, harboring, transportation, provision, obtaining, patronizing, or soliciting of a person in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such an act has not attained 18 years of age; or - b. The recruitment, harboring, transportation, provision or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage or slavery? These two definitions are commonly known as sex trafficking (part "a" above) and labor trafficking (part "b" above). Used together, sex trafficking and labor trafficking are commonly known as "human trafficking."6 Throughout this report, I will use those terms in accordance with these definitions unless otherwise specified. {sup}`4` United Nations General Assembly, Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, Supplementing the United Nations Convention against Transnational Organized Crime (Nov. 15, 2000), https://www.refworld.org/docid/4720706c0.html. {sup}`3` 22 U.S.C. § 7102(11). {sup}`6` See Hilary Axam and Jennifer Torrito Leonardo, Human Trafficking: The Fundamentals, at 3. (U.S. Department of Justice Nov. 2017). Chapter 77, which is titled "Peonage, Slavery, and Trafficking in Persons," proscribes over a dozen distinct criminal violations, and none of them is captioned "human trafficking." None, in fact, even includes the term "human trafficking." Thus, the term does not reference a specific statutory violation, but rather denotes more broadly the category of conduct criminalized throughout Chapter 77, the essence of which is compelling or coercing another person to perform labor, services, or commercial sex acts." - 21. The definition of sex trafficking differs depending on the age of the victim. While both definitions require a victim to be accessed' by a trafficker, according to the TVPA, if an individual is under 18 years old, the inducement of a commercial sex act is the only other element needed to satisfy the definition of sex trafficking. For individuals 18 and over, sex trafficking exists when there is access plus a commercial sex act and force, fraud, or coercion were used to bring about the commercial sex act. - 22. Sex trafficking requires a "commercial" sex act. Sexual abuse without a commercial aspect does not meet the definition. A commercial sex act is a sex act "on account of which anything of value is given to or received by any person."8 It does not require money or cash to be exchanged. - 23. Many popular culture depictions of human trafficking include extreme physical violence or kidnapping. Prior to the passage of the TVPA, a criminal charge of involuntary servitude required use or threatened use of physical force or legal coercion? However, many cases of human trafficking do not contain force or even fraud. Victims are frequently coerced into trafficking; however, sometimes the coercion is solely psychological. The TVPA defines coercion as: - a. Threats of serious harm to or physical restraint against any person; - b. Any scheme, plan, or pattern intended to cause a person to believe that failure to perform an act would result in serious harm to or physical restraint against any person; or - c. The abuse or threatened abuse of the legal process.{sup}`10` Serious harm includes: physical, nonphysical, psychological, financial or reputational harms." - 24. "Serious harm" is defined as any of the harms listed above that are "sufficiently serious, under all the surrounding circumstances, to compel a reasonable person of the same background and in the same circumstances to perform or to continue performing [labor or commercial sexual activity] in order to avoid incurring that harm."12 {sup}`7` By "access" I am referring to the list of actions in the statute by which a trafficker can interact with the victim to satisfy the definition: recruitment, harboring, transportation, provision, obtaining, patronizing, or soliciting. See 22 U.S.C. § 7102(11). {sup}`8` 18 U.S.C. § 1592(eX3). {sup}`9` See U.S. v. Kozminski, 487 U.S. 931, 952 (1988). {sup}`1°` 22 U.S.C. § 7102(3). {sup}`11` 18 U.S.C. § 1591(e)(5). {sup}`12` 18 U.S.C. § 1589(c)(2) (labor trafficking); 18 U.S.C. § 1591(e)(5) (sex trafficking). ### B. One Common Theme In Human Trafficking Is The Targeting Of Vulnerable People To Victimize - 25. Based on my experience and literature in the field, traffickers target vulnerable people for victimization. This is the case for two reasons: 1) to exploit individuals for the labor or commercial sexual services they seek; and 2) to protect themselves from prosecution. - 26. Vulnerability is expressed in myriad ways and must be assessed in the context of the real or perceived power of the trafficker. Polaris Project, a nonprofit organization focused on preventing human trafficking, published the first National Survivor Study in January 2023.13 The National Survivor Study, which is relied upon by people who work in the field of human trafficking, found that: The vast majority of trafficking survivors faced trauma, abuse, poverty, mental health challenges, and other struggles in childhood. To assess the linkages between these vulnerabilities and survivors, the [National Survivor Survey] adapted the widely used CDC-Kaiser Permanente Adverse Childhood Experiences (ACEs) questionnaire to fit the context of human trafficking.14 For the National Survivor Study, these experiences were organized into the six categories listed below. Respondents reported experiencing each at an alarming rate: - I. Experienced poverty: 83 percent - 2. Ran away from home: 69 percent - 3. Experienced abuse (physical, sexual, emotional): 96 percent - 4. Experienced substance abuse and mental health challenges: 93 percent - 5. Lived with someone who experienced substance abuse and mental health challenges: 93 percent - 6. Other family or household instability: 96 percent's - 27. The experiences of my clients are consistent with the findings of Polaris's National Survivor Study. Most of my clients experienced abuse or poverty before they were trafficked. - 28. These vulnerabilities, as well as strategies used by traffickers to exploit them, mean that trafficking can occur without physical restraint. Based on my experience, myths and misconceptions about human trafficking abound. One myth, which, in my opinion, often prevents identification of victims, is that trafficking victims will have no physical {sup}`13` In Harm's Way: How Systems Fail Human Trafficking Survivors, Survey Results from the First National Survivor Study, Polaris Project (Jan. 2023), https://polarisproject.org/wpcontent/uploads/2023/06/In-Harms-Way-How-Systems-Fail-Human-Trafficking-Survivors-by-Polaris.pdf. {sup}`14` 1d. at 10. {sup}`13` Id. freedom of movement.16 Based on my experience, victims may have freedom of movement and access to money. - 29. Another misconception is that victims will be deprived of financial resources or appear to be financially deprived. While financial deprivation does occur in trafficking cases, in other cases traffickers may expect their victims to maintain a certain look, shop, obtain beauty services, and receive money for shopping or gifts for their birthday. For example, I saw evidence that Epstein paid for clothes, haircuts and spa services.17 This is likely because Epstein wanted the women to look a certain way and was consistent with the trafficking venture. - 30. Further, many victims may stay—even if they are physically able to leave—because of the trafficker's emotional manipulation.I8 In my work, I have found victims may feel they are in a loving or reciprocally affectionate relationship with their traffickers while being exploited. For example, in United States v. Maksimenko, Aleksander Maksimenko used sexual coercion and other tactics to exploit the victims while describing his relationship as consensual and romantic: Defendant maintains that he and Y.S. were involved in a consensual, romantic relationship. After the first encounter, they had sex several times per week until Y.S. left. Defendant says he considered Y.S. to be his girlfriend and considered leaving his wife for her. Y.S. acknowledges that she did not continue to fight Defendant, but she says that she acquiesced because she felt that "it would happen anyway" and she thought that it would not hurt if she did not fight. Purportedly because he viewed Y.S. as a girlfriend, Defendant says he bought her jewelry and other gifts on numerous occasions, paid for breast implants, moved her to a newer apartment when she complained about her existing one, purchased new furniture, and gave her money and took her out for her birthday. Y.S. denies that Defendant was "romantic" with her. {sup}`16`Emily Brady et al., Photographing Modern Slavery: Recommendations for Responsible Practice., Univ. of Nottingham Rights Lab (Dec. 2019), haps://www.nottingham.ac.uk/research/beacons-of-excellence/rights-lab/resources/reportsand-briefings/2019/november/photographing-modern-slavery.pdf. {sup}`17` JPM-SDNYLIT-00152748. I8 The Typology of Modern Slavery Defining Sex and Labor Trafficking in the United States, Polaris Project, at 11 (Mar. 2017) https://polarisproject.org/wpcontent/uploads/2019/09/Polaris-Typology-of-Modern-Slavery-l.pdf ("Typology") ("Traffickers often condition victims to believe they are the only ones who care for them, manipulating an attachment bond that makes the decision to leave the trafficker extremely difficult."). But, she acknowledges that he gave her jewelry for her birthday after she had been working for him for two years.19 This "consensual romantic relationship" took place within these methods of control according to Maksimenko: [He] explained that he controlled the women through the following: lectures and explanations, holding immigration over their heads, fear of the police and holding debts over the women's heads. [He] also said that we, meaning he and [co-conspirator], held their identity documents. [He] also admitted to using intimidation and threatening to "kick their ass". [sic] [He] also said that if he had to he would put a hand on one of the women to tug them out the door. Because of all of these things, according to [him], the girls were not able to say no to him." - 31. The techniques of control Maksimenko used are consistent with my experience. In many cases, I have seen victims fear the police or fear they will be ignored.2I Additionally, in my experience, the perceived or real power of their trafficker makes the victims afraid they will be harmed. ### C. Human Trafficking Typologies And Red Flags Can Be Helpful When Assessing Potential Human Trafficking - 32. Human trafficking exists in many forms in the United States, but there is no reliable evidence-based estimate of the prevalence of human trafficking in the United States. One source for verifiable data on human trafficking is the National Human Trafficking Hotline operated by Polaris, which is a highly regarded nonprofit, non-governmental organization that works to combat and prevent sex and labor trafficking in North America. While the Hotline data is limited to situations in which individuals reach out to the Hotline, which means it almost certainly underreports the incidence of human trafficking, the data gathered by the Hotline nonetheless provides useful information about human trafficking in the United States. - 33. Polaris analyzed cases of human trafficking documented through the Hotline and their BeFree Textline. The analysis included more than 32,000 cases of human trafficking recorded between December 2007 and December 2016. From this analysis, they created a typology of trafficking in the United States which includes 25 types of human {sup}`19` U.S. v. Maksimenko, 2007 U.S. Dist. Lexis 45615, at \*11-12 (ED. Mich. June 25, 2007) (internal citations omitted). {sup}`20` Id. {sup}`2)` Amy Farrell, Meredith Dank, leke de Vries, Matthew Kafafian, Andrea Hughes, & Sarah Lockwood, Failing Victims? Challenges of the Police Response to Human Trafficking, Criminology & Public Policy (July 31, 2019), hups://doi.org/10.1111/1745-9133.12456. trafficking.22 Each human trafficking typology has its "own business model, trafficker profiles, recruitment strategies, victim profiles, and methods of control that facilitate human trafficking."23 The report acknowledges that situations of human trafficking may involve both sex and labor trafficking and a trafficker may engage in more than one typology. - 34. While, in my experience, the typologies are not perfect and do not fully capture individual situations, they provide a guide for the types of cases most often identified in the United States. I have represented clients who fit into many of these typologies. In my experience, multiple typologies may be present in a single trafficking venture. - 35. Applying these typologies, Epstein's behavior fits into multiple human trafficking typologies, including: - a. Residential: Residential sex trafficking recognizes a form of trafficking which occurs "within private households used...for commercial sex." In this typology, economic hardship is often used as a basis for the exploitation and "sex trafficking within residences informally used as brothels typically involves child victims."24 - b. Escort Services: This typology includes commercial sex acts "...that primarily occur at a temporary indoor location."25 The trafficker profile ranges from individuals, often intimate partners, to coordinated networks. In this typology, victims are often recruited through fraud whether it's "...fraudulent job offers, such as fake modeling contracts" or by the trafficker pretending to have affection for the victim 26 The majority of victims are United States citizen women and girls. Traffickers use a variety of methods of control in this typology including conditioning "...victims to believe they are the only ones who care for them, manipulating an attachment bond that makes the decision to leave the trafficker extremely difficult."22 - c. Illicit Massage, Health, & Beauty:28 In this typology, a façade of legitimacy for massage, health, and beauty services conceals that "...their primary business is the sex and labor trafficking of women trapped in these businesses."29 The trafficker profile for these cases includes on-site managers which "...tend to be women of the same ethnicity and may have been trafficked themselves in these {sup}`22`Typology at 5. {sup}`23` Id. {sup}`24` Id. at 18. {sup}`23` Id. at 10. {sup}`26`1d. at 1 I. {sup}`27` 1d. at 11. {sup}`28` The "Illicit Massage, Health, & Beauty" typology includes both sex trafficking and labor trafficking. I have focused my analysis in this case on sex trafficking, however them are also labor trafficking elements present in the materials I reviewed. {sup}`29` Typology at 12. businesses before becoming part of the larger trafficking network.."30 To control the victims in these cases, they may be forced to live on-site and have their movement monitored. - d. Arts and Entertainment: This typology includes a number of industries; however, for this case, I focused on modeling. "In the modeling industry, foreign and U.S. citizen women can be fraudulently recruited...with exaggerated job offers and fake immigration benefits."31 Traffickers may be "recruiters and executives in model management companies"32 and they may control victims through sexual abuse and harassment. - e. Personal Sexual Servitude:33 In this typology, payment is not always cash and the "line between ongoing sexual abuse and personal sexual servitude is complex."34 Trafficker profiles and recruitment vary, although victims "may be 'sold' by a family member to a trafficker."33 Traffickers use multiple forms of control including ongoing sexual assaults, threats, and isolation.36 - 36. Since the passage of the TVPA, a number of organizations, both governmental and nongovernmental, have created indicator or red flag lists to increase identification of human trafficking victims37. The majority of these lists are based on characteristics of previously identified cases of human trafficking, and the lists often share similar indicators. - 37. Indicators usually include caveats about the limitations of their use such as: presence or absence of indicators is not definitive proof of human trafficking; not all indicators are present in every human trafficking situation; the list is not exhaustive; and no single indicator is, by itself, conclusive of human trafficking but signals the need for follow up. The Department of State indicators note that sometimes individuals will first recognize something is wrong but not have a label for it: "Knowing indicators of human trafficking and some follow up questions will help you act on your gut feeling that something is {sup}`&`quot;Id. at 13. {sup}`31` Id. at 51. {sup}`32`Id. at 52. {sup}`33` I have included the "Personal Sexual Servitude" typology because, based on my review of the materials, I believe this typology applies to one of the victims described below. However, I did not find that this typology was a widespread pattern in this case. {sup}`34` Typology at 36. {sup}`35` Id. at 37. {sup}`36` Id. {sup}`37` See, e.g., Recognizing the Signs, National Human Trafficking Hotline https://humantraffickinghotline.org/en/human-trafficking/recognizing-signs; Spot the Signs, Stop the Traffik, https://wvAystopthetraffik.org/what-is-human-trafficicing/spot-the-signs/; What Are the Signs of Human Trafficking?, Freedom Network USA, https://freedomnetworkusa.org/the-issue/. wrong and report it."38 While all of these caveats are appropriate, there is one indicator which, if present, unequivocally meets the federal definition of sex trafficking: if a minor is involved in a commercial sex act. Two of the three sets of indicators below list this as an indicator. - 38. In the table below I have included the human trafficking indicators39 from: I) the Department of Homeland Security;4° 2) the Department of State;01 and 3) the Department of Health and Human Services, Administration for Children and Families Office.42 These indicators are representative of the types of indicators relied upon by experts within the field of human trafficking. | | AGENCY | INDICATORS | | --------------------------------- | -------- | ---------------------------------------------------------------------------------------------------------- | | Department of Homeland Security | | Does the person appear disconnected from family, friends, community organizations, or houses of worship? | | | | Has a child stopped attending school? | | | | Has the person had a sudden or dramatic change in behavior? | | | | **Is a juvenile engaged in commercial sex acts?** | | | | Is the person disoriented or confused, or showing signs of mental or physical abuse? | | | | Does the person have bruises in various stages of healing? | {sup}`38` !dents:ft and Assist a Trafficking Victim, U.S. Dep't of State, https://www.state.gov/identify-and-assist-a-trafficking-victim/. {sup}`&`quot;I have provided a sampling of typical indicator lists under United States law. The most widely accepted indicator list under international law is the Operational Indicators of Trafficking in Human Beings, International Labor Office (Sept. 2009), https://www.ilo.org/wcmsp5/groups/public/---ed\_nonn/--declaration/documents/publication /wcms\_105023.pdf. Based on a Delphi survey implemented by the International Labour Organization and the European Commission and published in 2009, it is a set of indicators based on consensus from a wide group of experts. The indicators are based on the international definition of human trafficking as defined in the United Nations' Palermo Protocol. There are many similarities between the definitions of human trafficking in the Palermo Protocol and the TVPA. {sup}`4°`Indicators of Human Trafficking, U.S. Dep't of Homeland Security, https://www.dhs.gov/blue-campaign/indicators-human-trafficking. {sup}`41` Identify and Assist a Trafficking Victim, U.S. Dep't of State, hups://www.state.gov/identifyand-assist-a-trafficking-victim/. {sup}`42`Adult Human Trafficking Screening Tool and Guide, Dep't of Health & Human Servs. Admin. for Children & Families, (Jan. 2018), hups://www.acf.hhs.gov/sites/default/files/documents /otip/adult\_human\_trafficking\_screening\_tool\_and\_guide.pdf. | | Is the person fearful, timid, or submissive? | | ------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | | Does the person show signs of having been denied food, water, sleep, or medical care? | | | Is the person often in the company of someone to whom he or she defers? Or someone who seems to be in control of the situation, *e.g.* , where they go or who they talk to? | | | Does the person appear to be coached on what to say? | | | Is the person living in unsuitable conditions? | | | Does the person lack personal possessions and appear not to have a stable living situation? | | | Does the person have freedom of movement? Can the person freely leave where they live? Are there unreasonable security measures? | | **Department of State** | Living with employer | | | Poor living conditions | | | Multiple people in cramped space | | | Inability to speak to individual alone | | | Answers appear to be scripted and rehearsed | | | Employer is holding identity documents | | | Signs of physical abuse | | | Submissive or fearful | | | Unpaid or paid very little | | | **Under 18 and in prostitution** | | **Department of Health and Human Services, Administration for Children and Families Office** | *Generally* | | | Is with a person who speaks for them | | | Is unsure of day, date, month, year | | | Moves frequently | | | Not in control of personal identification | | | Doesn't know where they live | | | Story doesn't make sense; seems scripted | | | Not allowed to come and go at will | | | Wears the same clothes over and over | | | Seems afraid to answer questions | | | Works long hours; exhausted; hungry | | | Someone else controls their money | | | Odd living/work space (may include tinted windows, security cameras, barbed wire, people sleeping/living at worksite) | | | Can't move freely; attached to someone | | --------------- | -------------------------------------------------------------------------------------- | | | Owes a debt to employer | | | Sex Trafficking | | | Works in the commercial sex industry: escort, exotic dancer, "prostitute," "massage" | | | Signs of having sex with multiple people | | | Has pimp: male, female, boyfriend, husband | | | Tattoos or branding of ownership | | | Uses language of the sex industry | | | Inappropriate clothing for venue or weather | | | Physical abuse, drugs/alcohol, malnourished | ### D. Jeffrey Epstein Directed A Sex Trafficking Venture - 39. My opinion is that Jeffrey Epstein directed a sex trafficking venture, which JPMorgan seemingly does not contest.43 - 40. I believe Epstein's trafficking is textbook human trafficking; however, the stage and scope of his sex trafficking venture is unique. In my experience, the majority of traffickers do not have access to the wealth and capital available to Epstein. Nonetheless, the trafficking Epstein engaged in and the power and control he exerted over his victims is consistent with both academic literature on sex trafficking and other sex trafficking ventures I have analyzed in my casework. - 41. My opinion that Epstein directed a sex trafficking venture is supported by the information I outline below that was known by or knowable to JPMorgan at the time, and is underscored by the 2019 indictment of Epstein on charges of sex trafficking conspiracy and sex trafficking44 and Ghislaine Maxwell's 2022 federal conviction for her decadelong role in assisting, facilitating, and participating in Epstein's "abuse of minor girls by, {sup}`43` Jane Doe 1 v. JPMorgan Chase Bank, N.A., No. 22-cv-10019, May 26, 2023 Hr'g Tr. at 19:3 (Counsel for JPMorgan: "I think the way the Court could use those grand jury findings would be to ascertain something not contested, which is Mr. Epstein was engaged in horrendous criminal activity, including sex trafficking. That's not something being contested at all by JPMorgan."); Kevin Breuninger et al., JPMorgan prepared to pay \$290 million in settlement with Jeffrey Epstein victims, CNBC (June 12, 2023), https://www.cnbc.com/2023/06/12/jpmorgan-reachessettlement-with-epstein-victim-in-lawsuit.html ("'We all now understand that Epstein's behavior was monstrous, and we believe this settlement is in the best interest of all parties, especially the survivors, who suffered unimaginable abuse at the hands of this man,' JPMorgan said in a separate statement Monday morning.") {sup}`44` U.S. V. Jeffrey Epstein, 19 Cr. 490, Sealed Indictment, https://www.justice.gov/usaosdny/press-release/file/1180481/download. among other things, helping Epstein recruit, groom, and ultimately abuse victims known to Maxwell and Epstein to be under the age of 18."4\$ ### 1. Jeffrey Epstein Engaged In Commercial Sex With Girls Under The Age of 18 - 42. In my opinion, Jeffrey Epstein engaged in commercial sex with girls under the age of 18. - 43. I reviewed a police incident report dated July 19, 2006, which detailed the Palm Beach Police Department's investigation into Epstein.46 The incident report provides evidence of a pattern consistent with a sex trafficking venture. It shows that girls under the age of 18 and young women were recruited under the false pretense that they would provide a massage (or even a naked massage with limited touching) to Epstein for cash. Epstein then engaged in sexual acts with these girls for which he paid them cash. For example: - a. {sup}`M` {sup}`47` had just turned 17 when a friend asked her if she wanted to provide a massage and make \$200.48 During the massage, Epstein tried to touch Ms buttocks, but told Epstein that made her uncomfortable. massaged Epstein while naked, and Epstein gave. \$200. Epstein explained to : "I know you're not comfortable but I'll pay you if you bring some girls." He told her "the younger the better." told the police that she once brought a 23-yearold female to Epstein, and Epstein said she was "too old."49 - b. A woman reported that her 14-year-old stepdaughter ("Jane Doe") may have been molested in Palm Beach by a wealthy man. When police spoke with Jane Doe, she said brought her to Epstein's house. Jane Doe was told to give Epstein a massage. Epstein instructed her to remove her clothes. Epstein then masturbated while Jane Doe gave him a massage. Epstein paid Jane Doe \$300 and \$200 for bringing her.S° {sup}`45` U.S. v. Ghislaine Maxwell, 20 Cr. 330, Sealed Indictment, https://www.justice.gov/usaosdny/press-relesse/file/1291491/download. {sup}`46` JDoe\_DBAG\_005374 ("2006 PBPD Incident Report"). {sup}`47` In order to maintain their privacy, I will not use victims' full names in my report unless and when it is necessary. I will refer to victims either by their first and last initials or by the designation given to them in court documents or law enforcement records (e.g., "Jane Doe No. 1"). For anyone named as a potential co-conspirator by the federal government I have used their name for clarity purposes only unless I have interviewed them determined they are a victim. {sup}`48` 2006 PBPD Incident Report at 28. {sup}`49` Id. S0 Id. at 29. - c. Alfredo Rodriguez, who worked as a property manager for Epstein in Palm Beach from at least 2004-2005,51 was interviewed by police and "stated that it was his responsibility to keep the identity of the masseuses private. Mr. Epstein had a massage in the morning and one in the aftemoon."52 Rodriguez did not know the age of the girls showing up to provide massages but told the police he felt they "were very youngs53 and high school age.54 He felt there was more than massage going on. He cleaned up after the massages and "would discover massager/vibrators and sex toys scattered on the floor. He also said he would wipe down the vibrators and sex toys and put them away in an armoire."55 Rodriguez referred to himself as a "human ATM machine."36 Epstein ordered Rodriguez to "maintain a minimum balance of \$2,000 dollars on him at all times" so he could give cash to the girls and women who "massaged" Epstein." - d. Juan (sometimes also referred to as "John") Alessi. Epstein's employeetold police that Epstein "had up to three massages a day." "Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger."S9 Alessi told police he sometimes set up massage tables in Epstein's bedroom or bathroom and at times "would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage."6° - e. Maria Alessi, who worked for Epstein from 1994 through 2002,61 told police "that two or three girls would come during the day and provide the massages." She said the girls who arrived looked "young in age."62 - f. During the police search of Epstein's residence, they found: - i. "several photographs of young naked teenage girls;"63 {sup}`51`Jane Musgrave, Epstein Journal's Findings Could Resurrect Case, Palm Beach Post (Sept. 17, 2019), https://www.palmbeachpost.com/story/news/2019/09/17/epstein-journals-findingscould-resurrect-case/2645154007/. {sup}`52` 2006 PBPD Incident Report at 51. {sup}`&`quot;Id. at 71. {sup}`54` JDoeDBAG\_005816. {sup}`55` 2006 PBPD Incident Report at 71. {sup}`56`1d. {sup}`57` Id. at 71. {sup}`58` VI-JPM-000089979. {sup}`&`quot; 2006 PBPD Incident Report at 57. {sup}`69` Id. {sup}`61` 1d {sup}`62` Id. {sup}`63` Id. at 44. - ii. a "massage table...located in the bedroom' and - iii. telephone message books with messages for Epstein, including messages with the first names of girls, dates, and telephone numbers. This included names the police recognized from victim interviews. "The body of the messages was time of the day that they called for confirmation of 'work.'" Other names and numbers included these messages: "'I have irls for him' or 'I have 2 girls for him.' These messages were taken by ] for Jeffrey Epstein."" - 44. The witness accounts in the police incident report appear highly credible, because they are consistent, confirm each other, and were corroborated by, among other things, Epstein's staff and, reportedly, cell phone records and phone messages retrieved from Epstein's trash, and credit card records. - 45. On July 19, 2006, following the Palm Beach Police Department's investigation, Epstein was indicted for Felony Solicitation of Prostitution in the Fifteenth Judicial Circuit in Florida." - 46. On September 24, 2007, Epstein entered into a Non-Prosecution Agreement ("NPA") with the United States Attorney's Office in the Southern District of Florida 67 The agreement acknowledged the federal investigation into offenses that may have been committed by Epstein from 2001 through approximately September 2007. These included multiple offenses involving illicit sexual conduct involving minors and an investigation into sex trafficking. Specifically, "knowingly, in and affecting interstate and foreign commerce, recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act .... 68 - 47. The NPA identified tential co-conspirators of E "including but not limited to Lesley Groff, or [ ]."" The NPA stated: "[I]f Epstein successfully fulfills all of the terms and conditions of this agreement, the United States also agrees it will not institute any criminal charges against any potential co-conspirators of Epstein.s70 - 48. The NPA deferred all federal investigations, including the sex trafficking investigation, "in favor of prosecution by the State of Florida."7I {sup}`60` Id at 44. {sup}`65` Id. at 59. {sup}`66` JDoe\_JPMC\_004535 at 42. {sup}`67` JDoe\_DBAG\_005165 ("Non-Prosecution Agreement" or "NPA"). {sup}`&`quot; NPA at 2. {sup}`&`quot; Id. at 5. {sup}`70`1d. {sup}`71`1d. at 2. - 49. On June 30, 2008, Epstein pled guilty in the 15th Judicial Circuit in Palm Beach County to one count of "Felony Solicitation of Prostitution" and one count of "Procuring Person under 18 for Prostitution." As part of the plea Epstein was to have "no unsupervised contact with minors" and was "designated as a Sexual Offender" under Florida law.72 - 50. At the time of Epstein's charge, "Procuring a Person under 18 for Prostitution" was defined as: "A person who procures for prostitution, or causes to be prostituted, any person who is under the age of 18 years commits a felony of the second degree."73 This law was repealed in 2014 by Fla. HB 989, which was "an act relating to human trafficking." - 51. In my experience, it is not uncommon for states to initially pass human trafficking legislation and then later integrate their human trafficking legislation with preexisting laws on prostitution like Florida did in 2014. If Epstein's crimes had been charged after 2014, the procuring count would not have been available. If the same type of charge were used, Epstein likely would have been charged under one of Florida's human trafficking laws. - 52. In my opinion, the charge Epstein pled guilty to in Florida in 2008, "Procuring a Person under 18 for Prostitution," satisfies the definition of sex trafficking under the TVPA (i.e., solicits commercial sex with a person under the age of 18) and is consistent with the investigation into sex trafficking crimes under the TVPA mentioned in the NPA. Stephen Cutler, who was JPMorgan's General Counsel from January 2007 until roughly the end of 2015. acknowledged that solicitation of someone under the age of 18 for commercial sex {sup}`71` - 53. On November 17, 2011, a New York court found "clear and convincing evidence," including the probable cause affidavit prepared by Florida law enforcement authorities, sufficient for a level three sex offender adjudication for Epstein for his "sex offenses in Florida."75 The Court held: "The evidence before the SORA hearing court established that defendant committed multiple offenses against a series of underage girls. The girls were brought to defendant's home to provide "massages" that led to very serious sex crimes."76 ### 2. Jeffrey Epstein Used Fraud, Force, And/Or Coercion To Induce Girls And Young Women To Perform Commercial Sex Acts - 54. In my opinion, Jeffrey Epstein used fraud, force, and/or coercion to induce girls and young women to perform commercial sex acts. {sup}`72` JDoe\_DBAG\_006690 at 20. {sup}`73` Ha. Stat. § 796.03. {sup}`74` Stephen Cutler Dep. (May 24, 2023) at 21:12-20; 90:7-93:4. {sup}`75`People v. Epstein, 933 N.Y.S. 2d 239, 240 (N.Y. App. Div. 2011). {sup}`76` Id. - 55. Although I believe Epstein routinely used fraud, force, and/or coercion—regardless of the victim's age, for any individuals under the age of 18, these elements are not required to find sex trafficking occurred under the TWA. - 56. To support this opinion and my analysis below, I have included representative examples, including statements of girls and young women which describe their experiences. It is common in the field of human trafficking to rely on the reports of victims to analyze potential human trafficking ventures. Many of the statements I reviewed were strikingly similar in their pattern of recruitment and exploitation, reinforcing their credibility. - 57. Based on my review of the victim statements, it appears that Epstein or others acting under his direction recruited economically vulnerable girls and young women for commercial sex under the false pretense of receiving payment for providing a massage. Based on my experience, recruiting economically vulnerable girls and young women is common in sex trafficking situations. Below is a sampling of instances I reviewed which demonstrate this vulnerability:77 {sup}`77` Many of the documents I reviewed were redacted so I am unable to say how many victims met this criterion; however, I am unaware of any victim who described herself as economically stable. {sup}`78` JDoe\_JPMC\_000723 at 000794. {sup}`&`quot; Id. at -000756. {sup}`80` In the hearing, this Jane Doe was not given a Jane Doe number by the court. Based on my accounting in the transcript, she would be Jane Doe No. 10. {sup}`81` JDoe\_JPMC\_000753 at 000829. {sup}`87` In the hearing, this Jane Doe was not given a Jane Doe number by the court. Based on my accounting in the transcript, she would be Jane Doe No. 11. {sup}`83`Id. at 000831. e. [REDACTED] met Epstein in 2002 when she was 16 years old. According to the complaint she filed against Epstein and [REDACTED] was an “economically poor and vulnerable child” who was recruited by another minor and told “she could make \$300 cash by giving an old man a massage on Palm Beach.”{sup}`86` f. g. h. i. --- {sup}`84` *Id.* {sup}`85` *Id.* at 000832. {sup}`86` JPM-SDNYLIT-00099549; [REDACTED] v. *Jeffrey Epstein and [REDACTED]*, No. 9:10-cv-81111, DE\_1\_Complaint-1902 at 7 (S.D. Fla. Sept.17, 2010) (“[REDACTED] Compl.”). {sup}`87` JDoe\_JPMC\_000753 at -000774. {sup}`88` *Id.* at -000790. {sup}`89` [REDACTED] 00000378. {sup}`90` [REDACTED] Dep. (Mar. 3, 2023) at 131. {sup}`91` *Id.* at 214. {sup}`92` *Id.* at 135. {sup}`93` [REDACTED] 00000120 at -00000122. - 58. In addition, in my experience, immigration status can be another source of vulnerabilit . Many of the women to whom Epstein made payments have Eastern European surnames, suggesting they may also be immigrants. It is well known including by JPMorgan—that Eastern Europe is a source country for human trafficking victims.95 - 59. According to the materials I reviewed, young girls and women were fraudulently recruited to perform paid "massages," "modeling," or other forms of work; however, in most instances, Epstein required sexual acts as part of the work. This fraud was perpetuated by the language used to recruit young girls and women to his home and even in the physical set-up he created in his home. At Epstein's residence, the young girls and women were taken to an interior, private space with a massage table. Excerpts from these victims' accounts are as follows: - a. . was told by another minor that if she gave "an old man a massage,"96 she could make \$3 minor who recruited . called Epstein and scheduled El's trip to E her. When house. Durin the call Epstein spoke with III and invited , showed her to the masse e room.. was not trained in massage and told Epstein. Epstein instructed on how he liked his massage and then sexually assaulted her. {sup}`94` .000456 at -000474. {sup}`95` Trafficking in Persons Report U.S. Dep't of State (2009), htt./2009-2017.state.gov/j/ti p/rl sit i prpt/2009/index.htm; JPM-SDNYLIT-00174047. {sup}`96` Comp!. at 7-10. {sup}`97` VI-JPM-000001756 at 31 I Dep. (May 3, 2016) at 113:18-117:12). {sup}`98` 1d. 60. Based on the materials I reviewed, many of the young girls and women experienced violence, threats of violence, or otherwise feared serious harm would occur if they did not do what Epstein wanted, including engaging in commercial sex. For example: {sup}`&`quot; This information came from interview with described in Section IV.I. II" 000456 at -000473. {sup}`101` 378 at 00379. {sup}`&`quot; 2 1d. {sup}`1°3` Id. I" Id. {sup}`105` 3 °°°°°°I. - d. Against Ms wishes, Epstein forced a sexual act upon her during the massage. "...Epstein while masturbating with his right hand reached out his left hand and grabbed [M's] vagina and butt over her clothes. [MI pushed [Epstein's] hand away and told him repeatedly not to touch her like that. Epstein was persistent in his attempt to grab [her] vagina and continued to grab her vagina and butt on multiple occasions after she told him not to."1I2 Epstein paid \$300 in cash after this assault. - 61. Based on the materials I reviewed, in some cases, Epstein would coerce young girls and women into commercial sex by making them believe he cared about them. In my experience, this is a common tool of traffickers, which is especially effective when victims have been abused or harmed within their own families before they meet the trafficker. {sup}`&`quot; 6 . Dep. (Mar. 3, 2023) at 132. {sup}`107`Id. at 133. JDoe\_JPMC\_000753 at 000796. {sup}`109` In the hearing, this Jane Doe was not given a Jane Doe number by the court. Based on my accounting in the transcript, she would be Jane Doe No. 11. l to JDoe\_JPMC\_000753 at 000832. {sup}`&`quot; I Id. at 000833. {sup}`112` Comol. at 8. {sup}`113` at -00000075. l la Id. at -00000065. - b. - c. - d. 62. Epstein also coerced his victims into commercial sex by establishing control over their lives and emotionally manipulating them. For example: 113 378 at 00398. at 00063. 378 at 00379. mu JDoe\_IPMC\_000753 at 000796. 12° JDoe\_IPMC\_000753 at 000826. De . (May 5, 2023) at 78. 122 III 11378 at 00398. Imola at -00000077. Id. at -00000066. \_00000378 at 00398. - 63. When in the Virgin Islands, Epstein had another layer of control over his victims due to the remoteness of his island. My understanding, based on my conversation with one of his victims mentioned in Section IV.I. is that once on the island, the women had no means to leave the island without E rmission. {sup}`126` . Dep. (Mar. 3, 2023) at 134. {sup}`127` Id. at 108, 129. {sup}`129` 000001 at -000003. {sup}`129` Dep. (May 5, 2023) at 77. {sup}`130`000456 at -000471. {sup}`131` Moe\_JPMC-007449 at 07460. - 64. It is my expert opinion that the victim stories I reviewed exhibited a pattern of force, fraud, and/or coercion; however, for any individuals under the age of 18 these elements are not required to find sex trafficking occurred. - 65. Based on my review of the materials, Epstein paid girls and young women in both cash and other types of financial support for sexual acts, which is consistent with the definition of inducing a commercial sex act under the TVPA. For example: - a. During the Florida police investigation in 2005, a victim recounted that a teen recruiter who worked for Epstein said the more "you do the more you are paid."I32 - b. Many of the young girls and women who Epstein victimized mentioned being paid between \$200-\$300 dollars for a single session with Epstein with the pay increasing based on the sexual acts induced."3 - c. - d. - e. - 66. The fact that some of the victims did not resist the commercial sex is not inconsistent with human trafficking. In my experience, victims of human trafficking frequently do not fight back, say no, run away, try to escape, or even tell someone they need help. The {sup}`132` 2006 PBPD Incident Report at 34. {sup}`133` See v. Jeffrey Epstein, No. 2008 CA 028058, Compl. (H. Cir. Ct. 15th Cir. Palm Beach Cnty, Fla.); Jane Doe 11 v. Jeffrey Epstein et at, No. 09-cv-80469-KAM, ECF No. 1 (S.D. Fla.), Jane Doe v. Jeffrey Epstein, 08-cv-80893-KAM, ECF No. Lap. Ha.), Jane Doe No. 102 v. Jeffrey Epstein, 09-cv-80656-KAM, ECF No. 1 (S.D. Fla.); v. Jeffrey Epstein, No. 09-cv-81092-KAM, ECF No. 1 (S.D. Ha.); , ■ **v. Jeffrey Epstein, 10-cv-81111, ECF No. 1 (S.D. Ha.); Jane Doe 43 v. Jeffrey Epstein et at, No. 17-cv-00616-JGK-SN (S.D.N.Y.).** **{sup}`134` Estate\_JPM018245.** **{sup}`135`** **{sup}`136` 1 Dep. (May 5, 2023) at 89.** **In Dep. (Mar. 3, 2023) at 115-120.** power dynamics inherent in human trafficking situations mean that victims may not believe that they are able to leave or worthy or capable of freedom or may believe that they or their families will be punished if they try to leave. That does not make their participation voluntary.138 - 67. Based on my experience working with human trafficking victims, many victims of trafficking are afraid to seek help or talk to law enforcement. They may fear the real or perceived power or connections of their trafficker or worry they may not be believed. The statements made by some of the young girls and women in this case are in line with my previous experiences and it is reasonable in my opinion for individuals in their situation to perceive Epstein as powerful and worry about retaliation or not being believed. For example: 138 In international law even explicit consent to trafficking does not negate the illegal behavior of the trafficker. It was the "...general agreement among participating States that consent of the victim should not be an issue in determining whether or not the crime of trafficking had been established." See Issue Paper: The Role of `Consent' In The Trafficking In Persons Protocol, United Nations Office on Drugs & Crime (2014), https://www.unodc.org/documents/human traffickin 014/UNODC\_2014\_Issue\_Paper Consent.pdf. 139 at 00065. 140 at 00020. 1 141 at -00000066. 142 Dep. (May 5, 2023) at 90-91. {sup}`113` Id. at 66. - e. According to Epstein's pilot, David Rodgers, was transported via Epstein's private plane with Prince Andrew.'45 ### E. JPMorgan's Due Diligence Indicates Epstein Was Involved In Sex Trafficking - 68. JPMorgan's own due diligence files regarding Epstein contain many red flags for sex trafficking. For each year below, I list a few representative examples of the type of information JPMorgan had and explain how it was indicative of sex trafficking. 2003 - 69. On May 21, 2003, Mary Rieth (=), Managing Director, sent an email to Paul LaRiff, Managing Director, referencing a Due Diligence Report (DDR) about Financial Trust (one of Epstein's companies) and a Vanity Fair Article.146 I believe was referencing an article Vanity Fair published in March of 2003 about Epstein. The article contains red flags for human trafficking. For example: Epstein is known about town as a man who loves women—lots of them, mostly young. Model types have been heard saying they are full of gratitude to Epstein for flying them around, and he is a familiar face to many of the Victoria's Secret girls. One young woman recalls being summoned by Ghislaine Maxwell to a concert at Epstein's town house, where the women seemed to outnumber the men by far. "These were not women you'd see at Upper East Side dinners," the woman recalls. "Many seemed foreign and dressed a little bizarrely.99147 - 70. The reference to young women—particularly the one woman who was "summoned" to Epstein's town house—and models is a red flag for human trafficking. It is particularly indicative of both the escort services and the arts and entertainment (modeling) typologies of human trafficking, both of which involve commercial sex. In my opinion, the arts and entertainment typology is the closest fit because this article suggests that Epstein has a sexual relationship with and is transporting foreign women who are in the United States under the pretense of modeling. {sup}`44` 1d. at 87. {sup}`145` V. Maxwell, No. 18- 2868 ad Cir.), ECF No. 283, ("Unsealed Maxwell Documents") at 292 (David Rodger Dep. (June 3, 2016) 138:22-25). {sup}`146`Mary Dep. (Apr. 7, 2023) Ex. 3. " {sup}`7` 1d. - 71. Another indicator of commercial sex and human trafficking is that Epstein engaged in extensive cash transactions. In 2003 alone, JPMorgan noted over \$175,000 in cash transactions in Epstein's personal JPMorgan account.148 In addition, Epstein made nearly \$177,000 in payments to women in 2003.109 2004 - 72. On February 8, 20a. M IPMorgan opened accounts in its Private Bank for two young women and ) as a "favor" to Epstein.15°The circumstances surrounding these account openings contain many red flags for sex trafficking, including that the DDRs for both women contain similar information provided by someone other than the women themselves.I51 For example: - a. The DDRs for both women state the information contained in the reports were provided by "Epstein advisor, Eric Ganey," not the women themselves. - b. JPMorgan's DDRs fail to include a date of birth for and IR which is particularly suspicious given their young age. - c. Both DDRs claim the women have a net worth of \$100,000 through modeling assignments. They also note that Epstein often supports emerging models and has agreed to guarantee their credit card applications. - d. - e. 's DDR states she is "a Slovakian citizen who came to the US for modeling work" and that Epstein "knows her personally." It further states that Ms social security number "could not be confirmed as belonging to 's DDR also states that: "Mary [Erdoes] will meet with her as soon as possible. She has met several times with Jeffrey Epstein." However, Mary Erdoes later testified she never met with - 73. As mentioned earlier in my report, government agencies that publish trafficking indicators agree that having someone provide information for the victim or not letting the victim speak for themselves is a classic sign of human trafficking. Further, based on my experience, opening a bank account for a foreign national female model without a date of birth or any government issued documentation, and having all her personal information supplied by a potential employer/sponsor is a red flag for human trafficking. In my opinion, the information in this DDR combined with the media report from the year prior about potentially transporting young foreign models increases the severity of this red flag. I" Expert Report of Jorge Amador ("Amador Report") at 25. {sup}`149` Id., Ex. F. {sup}`&#`x27;5° JPM-SDNYLIT-00036564; JPM-SDNYLIT-00149696. {sup}`151` Id. - 74. Also, JPMorgan noted \$840,000 in cash transactions from Epstein's JPMorgan accounts in 2004—a sign of commercial sex and red flag for human trafficking.152 Also in 2004, M in made over \$161,000 inaments to women, including more than \$36,000 to and more than \$17,000 to {sup}`153` 2005 - 75. In 2005, JPMorgan identified over \$900,000 in cash transactions from Epstein's personal JPMorgan account.154 During this same time, Epstein also made more than \$192,000 in payments to women.t55 2006 - 76. By at least July 26, 2006, JPMorgan's internal emails reflect discussion of E 2006 indictment for Felon Solicitation of Prostitution in Florida. - 77. On July 26, 2006, Mary sent an email to Jes Staley with a link to a July 26, 2006 PalmBeachPost.com article about Epstein's indictment that had several red flags for sex trafficking.157 The PalmBeachPost.com article opens with "Palm Beach billionaire Jeffrey Epstein paid to have underage girls and young women brought to his home, where he received massages and sometimes sex..." The article lays out in detail evidence from police documents, including: - a. A college student gave Epstein a naked massage and then "brought him six girls, ages 14 to 16, for massage and sex-tinged sessions" at Epstein's home. - b. A 27-year-old Epstein employee, would arrange the sessions and prepare the massage table. - c. Police obtained statements from five alleged victims and 17 witnesses. Police contend Epstein "had sex with the girls" on three occasions. - d. El met Epstein at age 17 and was recruited to massage him. Epstein told her he would "pay her to bring him more girls—the younger the better." She stated she once brought a 23-year-old woman to him and "Epstein said she was too old...." She brought six girls to Epstein and said the girls were paid \$200 for each session. {sup}`152` Amador Report at 25. {sup}`153` Id., Ex. F. {sup}`154` Id. at 25. {sup}`155` Id., Ex. F. {sup}`156` JPM-SDNYLIT-00000183. {sup}`157`mary Dep. (Apr. 7, 2023) Ex. 5. - e. One 14-year-old victim recounted the details of her encounter in February 2005 including being aid 300 for a massage in her bra and panties. For bringing this child to Epstein, received \$200. - f. Police scoured the trash from Epstein's house and found notes with names and phone numbers, sex toys and female hygiene products. Notes stated that one female could not "come over at 7 p.m. because of soccer. Another said a girl had to work Sunday—`Monday after school?' And still another note contained the work hours of a girl, saying she leaves school at 11:30 a.m. and would come over the next day at 10:30 a.m." - 78. On July 26, 2006, Mary Erdoes emailed Stale and said the PalmBeachPost.com article was "so ainful to read x•158 - 79. During Mary deposition, she acknowledged that in 2006, when she sent the PalmBeachPost.com article to Staley, Epstein was withdrawing upwards of \$30,000 per month in cash from his accounts.160 - 80. further acknowledged that in 2005—the year before she sent the PalmBeachPost.com article to Staley—Epstein made \$50,000 in payments to from Epstein's JPMorgan accounts.161 - 81. JPMorgan acknowledged over \$935,000 in cash transactions in Epstein's JPMorgan accounts in 2006.162 Epstein also made over \$184,000 in payments to women in 2006.163 - 82. In my opinion, the information in July 26, 2006 email combined with Epstein's JPMorgan banking activities are significant because they provide detailed information and corroboration of Epstein's role not just in sex trafficking, but a sex trafficking venture. The information described in the article about the police investigation is consistent with the types of trafficking signaled by the red flags in 2003 and 2004. - 83. On October 17, 2006, JPMorgan held a "Rapid Response Team meeting."164 JPMorgan noted that Epstein had accounts with balances totaling approximately \$32 million and {sup}`168` JPM-SDNYLIT-00099334. {sup}`169` James Staley Dep. (June 10, 2023) 17:3-21:12 (rough transcript); James Staley Dep. (June 11, 2023 • 2-404:11 (rough transcript). {sup}`160` Mary Dep. (Apr. 7, 2023) at 71. {sup}`161`Mary Dep. (Apr. 7, 2023) Ex. 6; Mary Erdoes Dep. (Mar. 15, 2023) Ex. 7. {sup}`162` Amador Report at 25. {sup}`163` Id., Ex. F. {sup}`164` JPM-SDNYLIT-00127953. "cash withdrawals are routinely made in amounts for \$40,000 to \$80,000 several times a month, which total over \$750,000 year to date."165 - 84. Following the Rapid Response Team meeting, JPMorgan decided to keep Epstein on as "solely" a banking client.IM - 85. I also saw references to high level JPMorgan employees joking about Epstein's association with young girls.167 For example, on August 27, 2006, Staley emailed Erdoes: "Last night went to the Huggy Bear concert. The age difference between husbands and wifes [sic] would have fit in well with Jeffrey. What a joke." Erdoes responded, `e, and what I meant to tell you about last night was they [sic] were a few people laughing about Jeffrey. One of the guys ran a unit of IAC. Apparently barry diller has 8 assistant, one is more beautiful than the other (even though he's gay). Anyway, lots of comparisons to JE." - 86. In my opinion, this is significant because JPMorgan employees at this meeting had consistent information starting in 2004 about Epstein's potential trafficking and use of cash in this venture. The new information in October 2006 was that Epstein was indicted for inducing minors into commercial sex acts. In my opinion, the indictment combined with the previous knowledge of accusations of Epstein's use of cash to pay for sex with minors plus the scope of his cash withdrawals are extremely strong, if not conclusive, indications of sex trafficking. 2007 - 87. In 2007, JPMorgan's internal emails continued to reflect discussions of Epstein's 2006 indictment, but it does not appear that JPMorgan acted on the information. On June 5, 2007, Marcus Sheridan, Managing Director,'" sent an email to Mary discussing what to do with Epstein's accounts. Sheridan said: "[E]veryone knows this is a hot potato with jes in the middle."'" 88. {sup}`165` Id. {sup}`166` JPM-SDNYLIT-00 127953 {sup}`167` JPM-SDNYL1T-0009937. {sup}`168` JPM-SDNYLIT-00001395 at 9. {sup}`169` JPM\_SDNYLIT-00001693. JPM-SDNYL1T-00099501. 89. On September 20, 2007, Mary Erdoes emailed Staley regarding the Page Six column. She said, "It's actually on page 14 in the "page six" column. Epstein Rumored 15 months jail with 15 months home confinement. Then a few details of one of the nights-yuck." 171 90. On October 25, 2007, Stephen Cutler, JPMorgan's General Counsel, emailed JPMorgan employee Brent Taylor, and asked, "Did we close the loop on Jeffrey Epstein?"172 Mr. Taylor responded, "Not yet. Sleazy allegations in NY Post articles notwithstanding, we are still waiting to get the facts which we expect will emerge when he pleads guilty as expected (which has not happened yet)." 91. In 2007, JPMorgan identified \$520,000 in cash transactions from Epstein's personal account.173 Also in 2007, Epstein made more than \$276,000 in payments to women from his JPMorgan accounts.174 92. In my opinion, the articles and discussions among JPMorgan employees—particularly when coupled with the cash transactions and payments to women—are highly indicative of Epstein engaging in a sex trafficking venture, particularly the commercial sex with minors. ### 2008 93. In 2008, JPMorgan's internal emails showed continued discussions of Epstein's 2006 indictment and eventual 2008 guilty plea. 94. On January 4, 2008, Lisa Waters and Mary emailed about Epstein's 2006 indictment and impending guilty plea.'" Lisa Waters said Epstein's court date was "pushed to march while he tries to 'hammer out' details of his 18 month prison sentence followed by house arrest." Ms. Waters also said, "We need to have the felony he pleads guilty to. So march. No one wants him." {sup}`171` JPM-SDNYLIT-00099500. {sup}`172` JPM-SDNYLIT-00274272. {sup}`173` Amador Report at 25. {sup}`174` Id., at Ex. F. {sup}`175` JPM-SDNYLIT-00002141. - 95. In a January 25, 2008 email to Mary Erdoes, Lisa Waters reported: "AP and reuters 50mm lawsuit filed in fed ct-miami against JE- sexual abuse of a minor etc. etc."'" - 96. JPMorgan had a Rapid Response Team meeting on July 15, 2008 after Epstein pled guilty in which they discussed JPMorgan's due diligence on Epstein.177 The July 2008 updated derogatory information on Epstein noted: "On July 3, 2008 Jeffrey Epstein was sentenced to 12 months in jail for solicitation of a prostitute and six months for procuring a person under age 18 for prostitution. His jail sentence will be followed by 12 months of house arrest."'" The memo from this meeting stated: "No change to relationship approach"179 or "[c]ontinue discussion with management"18° after this updated information was included depending on the version of the document.1S1 - 97. In my expert opinion, Epstein pled guilty to facts which meet the definition of sex trafficking under the TVPA. JPMorgan's internal emails and documents show extensive discussion of these facts. - 98. JPMorgan noted that Epstein engaged in \$460,000 in cash transactions in 2008 alone and over \$3.8 million in cash transactions from 2003-2008.182 Moreover, Epstein made over \$302,000 in payments to women in 2008 and nearly \$1.3 million in payments to women from 2003-2008.183 These transactions, coupled with the other information contained in JPMorgan's due diligence files, are significant red flags for sex trafficking. 99. {sup}`&`quot;6 JPM-SDNYLIT-00099550. JPM-SDNYLIT-00127944. {sup}`&`quot;8 Id. I" Id. {sup}`180`Mary Dep. (Mar. 15, 2023) Ex. 30. 18' It is not clear which outcome was the final or controlling one from the documents I reviewed, so I am including both of the outcomes I saw in my review.

182 Amador Report at 25.

183 1d., Ex. F.

184 JPM-SDNYLIT-W-00026257 (Tab "HaloECI\_CaseJournal", Row 3).

l" William Langford Dep. (May 3, 2023) at 285:7-20.

2009

2010

In my opinion, this information is significant because it signals the potential scope of Epstein's sex trafficking venture when combined with the information JPMorgan had about cash withdrawals.

186Amador Report at 25.

In Id., Ex. F.

WM-SDNYLIT-00008237.

189 WM-SDNYLIT-00008238.

190 WM-SDNYLIT-00008239.

lot

191 JPM-SDNYLIT-00100251.

192 JPM-SDNYLIT-00036580 at 00036596.

193Amador Report at 25.

194 Id., Ex. F.

107. The information about [REDACTED] in this DDR is particularly troubling given that JPMorgan opened an account for her with little to no information—and none of the information JPMorgan did have was provided by [REDACTED]

108. [REDACTED]

109. [REDACTED]

110. [REDACTED]

a. [REDACTED]

b. [REDACTED]

c. [REDACTED]

111. In my opinion, JPMorgan had overwhelming evidence of Epstein's sex trafficking venture at this point from both from its own due diligence research and Epstein's

195 JPM-SDNYLIT-00010814.

196 Id.

197 Id. at 00010815.

198 Id.

activities in his JPMorgan accounts. JPMorgan employees used either the terms "child trafficking" or "human trafficking" or the definition of sex trafficking in their communications regarding Epstein.

2011

I" JPM-SDNYLIT-00002141.

200 JPM-SDNYLIT-00269848.

201 JPM-SDNYLIT-00269848.

2°2 JPM-SDNYLIT-00194062

2°3 William Langford Dep. (May 3, 2023) at 239:11-23.

2°4 Stephen Cutler Dep. (May 24, 2023) at 394:24-395:8.

2°3 William Langford Dep. (May 3, 2023) at 58-59.

2°6 1d. at 59-60.

207 JPM-SDNYLIT-00011965.

2°8 JPM-SDNYLIT-00194062.

2°9 JPM-SDNYLIT-00127930.

crimes, including child trafficking," Epstein's completion of home arrest, and a lawsuit being filed against Epstein by a woman alleging Epstein abused her as a teen. The meeting notes indicate the conclusion of the Rapid Response Team was "[n]o change to relationship approach."

210 Amador Report at 25.

211 Id., Ex. F.

212 JPM-SDNYL1T-W-00026257 (Tab "HalOECI\_CaseJournal", Row 3).

213 JPM-SDNYLIT-00194067.

120.

He is alleged to be involved in the human trafficking of young girls and law enforcement is also allegedly investigating his involvement in this activity.214

214 JPM-SDNYL1T-00152748\_R.

215 JPM-SDNYLIT-00152809.

Epstein sponsored in the private bank "the opening of DDA accounts and a cc for "two 18 year olds (turned 19 days later) that appear to be part of his inner entourage. One is mentioned in many of the recaps of the escapades as a willing participant and assistant when hosting visitors. She has received about \$450,000 since opening from Epstein...Me willing participant had some lovely debit charges and spends a good deal at spa establishments. He did pay other girls, many models, no huge amounts. Sugar Daddy!"

216 IPM-SDNYLIT- 00036580 at 00036596.

217 Meeghan Sheppard, Exposing the Exploitative Realities of Sugar Dating, Human Trafficking Search (2020), https://humantraffickingsearch.orgiresource/exposing-the-exploitative-realitiesof-sugar-dating/.

218 JPM-USVI-00000593.

216 JPM-USVI-00000594.

127.

22° Id.

221 JPM-USVI-00000595.

222

225 Id.

224 id.

225ESTATE 005175.

226 Stephen Cutler Dep. (May 24, 2023) at 354:12-357:8.

227 JPM-SDNYLIT-00036570.

“January 27, 2011 update: A few news stories during 2010 connects Jeffrey Epstein to human trafficking. The coverage team along with Catherine Keating and William Langford all met to discuss the situation and agreed to enhance monitoring and document a discussion with the client. Jes Staley discussed the topic with Jeffrey Epstein who replied there was no truth to the allegations, no evidence and was not expecting any problems. We will continue to monitor the accounts and cash usage closely going forward.”228

  1. 131. In my opinion, it is highly irregular to rely on denials from the alleged trafficker and his lawyers when investigating potential sex trafficking. In addition, it stands out that JPMorgan failed to reach out to its own customers, [REDACTED] or [REDACTED], for instance, or other women who received payments from Epstein, or the counsel of any of the women who sued Epstein in conducting a diligent investigation of Epstein’s activities.
  2. 132. In addition to speaking with Epstein and his lawyers, JPMorgan also reached out to law enforcement. On March 2011, Jonathan [REDACTED], General Counsel of JPMorgan’s Investment Bank, at the direction of JPMorgan’s General Counsel, Stephen Cutler, contacted the United States Attorney for the Southern District of Florida “in an effort to determine whether there was an active criminal investigation into Epstein for alleged sex crimes. . . [REDACTED] spoke to the U.S. Attorney, but the U.S. Attorney did not disclose the existence of any such investigation.”229 In my experience, law enforcement frequently refuses to disclose the existence of human trafficking investigations and/or will not comment on open cases—a fact that [REDACTED] acknowledged in his email.

2012

  1. 133. In 2012, JPMorgan had continued discussions about Epstein’s use of cash. On March 27, 2012, John Duffy forwarded an email chain to Mary Erdoes.230 The email chain discussed Epstein’s cash withdrawals. Mr. Duffy said to Ms. Erdoes, “I previously spoke with JE about this activity. We’ll need to discuss.”

134. [REDACTED]

228 Id. at 00036575.

229 JPMC First Supplemental Responses and Objections to Interrogatories in Lieu of Rule 30(b)(6) Deposition Testimony, Response to Topic 28.

230 JPM-SDNYLIT-00136519.

231 JPM-SDNYLIT-00230819.

Philip: I was just googling maryanne's pery ... what a slime

Jessica: ha -poor maryanne. Someone is going to hear us say that she have a pery

Jessica: and totally misunderstand the message

Jessica: what is his name? I want to google

Philip: jeffrey Epstein

Philip: He was a convicted sex offender and supposedly bought his way to a lesser sentencing. He paid a whole series of girls to stay quiet. The FBI is reportedly preparing to launch a new hairy into Epstein after one of his under-age erotic masseuses,

made a string of disturbing allegations about her role U.S detectives are said to be furious that Epstein, 58, escaped with only 13 months in jail for child sex offenses after he struck a plea bargain with prosecutors. The deal protected him from further prosecution for offences in Florida. But the significant of

[MI's claims that under-age girls were moved abroad for sex is

232 Amador Report at 25, 18-22.

233 Id., Ex. F.

that she paves the way for the FBI to prosecute him for offences committed outside Florida under the Trafficking Victims Protection Act. PB did not want to keep him but due to his relationship with the old head of the PB (Jes Staley) they were over ruled.

Jessica: is Stanley till [sic] here?

Philip: no and I have to remove that comment234

139. This discussion demonstrates that Epstein's sex trafficking was discussed at JPMorgan. It is also significant because Mr. DeLuca ties movement of underage girls abroad as a way he believes federal law enforcement could prosecute Epstein under the TVPA.

140.

[REDACTED]
234

[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]

234 JPM-SDNYLIT-00100935.

235 JPM-SDNYLIT-W-00026257 (Tab "HaloECI\_CaseJournal", Row 26-27).

[Redacted text block]

141. In 2013, Epstein engaged in more than \$197,000 in cash transactions from his Hyperion account at JPMorgan.236 He also paid more than \$473,000 to various women in 2013.237

142.

[Redacted text block]

143.

[Redacted text block]

I will note that JPMorgan's failure to tie the excessive cash withdrawals to Epstein's history of engaging in commercial sex with minors made it more difficult for JPMorgan to see this as a red flag for sex trafficking, which, when observed in the full context, it clearly is.

144.

[Redacted text block]

145. JPMorgan's documents also show that JPMorgan's top executives made the connection between Epstein's cash transactions and sex trafficking, which I believe is an appropriate connection to make. In fact, it appears JPMorgan communicated that connection as the main reason for exiting Epstein. In July 2013, Mary Erdoes and John Duffy discussed via email talking points for exiting Epstein from JPMorgan.240 Duffy suggested the following talking points:

236 Amador Report at 25.

237 Id., Ex. F.

238 JPM-SDNYLIT-W-00021995.

239 JPM-SDNYLIT-00609197 at 2013 tab.

240 JPM-SDNYLIT-00100966.

146.

147.

F. Jes Staley's Communications With Epstein Show Red Flags For Human Trafficking

241 JPM-SDNYLIT-00184442.

242 JPM-SDNYLIT-00901975.

243 Id.

244 Id.

245 JPM-SDNYLIT-00004240.

246 JPM-SDNY LIT-00004661.

247 JPM-SDNYLIT-00006171.

248 JPM-SDNYLIT-00006592.

249 JPM-SDNYL1T-00006713.

2" JPM-USVI-00043990; JPM-SDNYLIT-00006715; JPM-SDNYLIT-00006716.

251ESTATE\_JPM001832.

252 JPM-SDNYLIT-00008669.

253 JPM-SDNYLIT-00036258.

254 JPM-SDNYLIT-00006592.

255 JPM-SDNYLIT-00152756\_1'.

256 Francis Peam Dep. (Mar. 29, 2023) at 172:22-173:6.

257 JPM-SDNYLIT-00373376.

258Mary could not remember the names of the JPMorgan employees who accompanied her to the meetings with Epstein at his Manhattan townhouse. See JPMC Second Set of Interrogatory Responses on 30(b)(6) topics at 15.

Figure 1: JPMorgan Employee Visits to Epstein Properties

NameNumber of Visits
James (Jes) Staley8 visits
Justin Nelson12 visits
McGraw2 visits
David FrameI visit
PaulI visit
Chris6 visits
Carol n ReersI visit
Mary2-3 visits
Paul Morris3 visits
Jeffrey MatusowI visit
Mary Erdoes2 visits
John DuffyI visit
Jim CondrenI visit
Joanna JagodaI visit
James (Jes) Staley2 visits
Justin NelsonI I visit

G. Jeffrey Epstein's JPMorgan Accounts Show Signs Of Human Trafficking

259 JPM-SDNYL1T-00755203.

26° JPM-SDNYL1T-00173973.

from trafficking was to search huge volumes of data from thousands of customers to identify whether they could see signs of human trafficking in the data. In other words, the goal of JPMorgan's human trafficking initiative was trying to find a needle in a haystack.

261Id.

262id.

263 Amador Report at 13-18; See Raising the Standard In Private Banking Service, JPMorgan, https://privatebank.jpmorgan.com/glien/o/raising-the-standard-in-private-banking-service ("Banking here is personal, and we work to gain a deep understanding of you and what's really important to you. With your unique goals and preferences always in mind, your team will move mountains to meet what the moment calls for."); Personal Banking, located at https://privatebank.jpmorgan.com/glieniservices/banIcing/personal-banking ("Wealth can mean freedom and security, but managing it requires time and know-how. That's why J.P. Private Bank provides you with personalized services and a range of premium banking products for every aspect of your financial life. You'll have easy access to your money, when and where you need it, and an experienced Client Service team focused on you.").

264 JPM-SDNYLIT-00173973.

1. Large Cash Withdrawals

Figure 2: Epstein's Estimated Payments to Victims

Estimated Daily Payments Per Victim Estimated Monthly Payments to Victims for "Massages" Estimated Monthly Payments to Victims for "Massages"
2 Victims Per Day Estimate 3 Victims Per Day Estimate
Low Estimate (\$200) \$12,000 \$18,000
High Estimate (\$1,000) \$60,000 \$90,000

Figure 3: JPMorgan's Reports of Epstein's Cash Withdrawals

Year Epstein #0438 Epstein #0663 Hyperion #4332 NYSG #3130 116 East 65th St LLC#4235 Total
2003 \$175,310 \$175,310

265See 18 U.S.C. § 1591(e)(3).

266 2006 PBPD Incident Report

267 Francis Peam Dep. (Mar. 29, 2023) at 191:18-192:13.

768 This amount reflects an assumption of two victims at the lowest sexual act pay rate of \$200 per sex act and no payment for recruitment and then 3 victims at the highest rate I saw of \$1000 and again no payment for recruitment.

2004\$840,000\$840,000
2005\$901,337\$3,000\$904,337
2006\$935,265\$3,000\$938,265
2007\$520,000\$6,000\$526,000
2008\$460,000\$9,000\$469,000
2009\$100,011\$60,000\$5,000\$165,011
2010\$223,397\$30,000\$253,397
2011\$200,000\$60,000\$260,000
2012\$290,000\$290,000
2013\$197,152\$197,152
Total\$4,355,320\$90,000\$547,152\$21,000\$5,000\$5,018,472269

2. Round-Dollar Wire Payments to Women

171.

2" The \$21,707 difference between the Cash Transactions in Figure 7 (\$5,040,178) and Figure 8 (\$5,018,472) are due to: Account #0438 - a July 23, 2010 purchase of 10,000 EURO for \$13,397.00 not recorded as cash, a July 23, 2010 withdrawal of \$9,515.10 not reported on a CTR, and a February 3, 2009 CTR reflecting a January 13, 2009 transaction of \$20,011 rather than \$20,000 as reflected on check 1206; Account #4332 - a \$1,600 due to check 1370 for the same amount dated 9/24/2012 not reported on a CTR; and Account #9169 - \$27,000 of cash transactions not reported on CTRs.

27° JPM-SDNYLIT-00174075 at 174076.

271 Id. at 00174078.

272 Exhibit E is the Amador Report Exhibit F.

3. Payments To Individuals Supporting Epstein's Sex Trafficking Venture

273 In light of her conviction, I am confident Maxwell is a co-conspirator and based on my interview and explanation below, I believe is a victim. However, inclusion in this section of anyone else is not an evaluation one way or the other of what role they played.

274 NPA at 5. 275 Ghislaine Maxwell Sentenced To 20 Years In Prison For Conspiring With Jeffrey Epstein To Sexually Abuse Minors, United States Attorney's Office, Southern District of New York, (June 28, 2022), https://www.justice.gov/usao-sdny/prighislaine-maxwell-sentenced-20-years-prisonconspiring-jeffrey-epstein-sexually-abuse.

276 JPM-SDNYLIT-00036396 at 00036397 and-00036400.

277 JPM-SDNYLIT-00036564.

278 NPA at 5.

279 Exhibit F is Figure 15 from the Amador Report.

4. Private Air Travel

180.

28° Exhibit G is Figure 9.3 from the Amador Report.

281Exhibit H is Figure 9.2 from the Amador Report.

282 JPM-SDNYLIT- 00174185 at 00174188.

283 JPM-SDNYLIT-00100935.

284 Amador Report at 46.

283 Id.

2" Id.

287m.

Aviation Database, as of June 27, 2007, the helicopter with tail number N908GM was registered to Air Ghislaine, IFIC.288

183.

5. MC2 Model Management

288 Id

2" JPM-SDNYLIT-00194462.

29° JPM-SDNYLIT-00 127953

'-91 JPM-SDNYLIT-00020772.

292 JPM-SDNYLIT-00151917.

293 JPM-SDNYLIT-00173973; JPM-SDNYLIT-00174075.

294 Epstein also made a similar request for ; I discuss her in a separate section below.

card application.”295 Epstein used JPMorgan private banking services to pay [REDACTED] \$36,049.30 from 2003-2013.296

188. [REDACTED]

297

This appears to be a quote from a July 22, 2010 article from the Daily Beast titled, “Jeffrey Epstein Pedophile Billionaire and His Sex Den.”298 The article also noted that, “According to a former bookkeeper, young girls were brought to the U.S. by MC2—often from Eastern Europe—then traveled on Epstein’s private jets.”

189. [REDACTED]

190. JPMorgan’s April 2011 DDR for Epstein stated: “MC2 Model Management received \$1 million from Epstein in 2005. It is unknown if the money was given as a secret investment or payment for services as a procurer,”300 and “Jean Luc Brunel, owner of MC2 Model Management and Jeffrey Epstein engaged in racketeering that involved luring in minor children for sexual play for money. In addition, Brunel was a frequent passenger on Epstein’s private jet and often visited Epstein in jail.”301

295 JPM-SDNYLIT-00149696.

296 Amador Report, Ex. F.

297 JPM-SDNYLIT-00100422.

298 [REDACTED], Jeffrey Epstein Pedophile Billionaire and His Sex Den, Daily Beast (July 22, 2010), https://www.thedailybeast.com/jeffrey-epstein-pedophile-billionaire-and-his-sex-den.

299 JPM-SDNYLIT-00194067.

300 JPM-SDNYLIT-00036570.

301 Id, at 00036574.

191.

192.

193. Jean Luc Brunel committed suicide in February 2022 when he was incarcerated in France in connection with an investigation into the rape of minors and trafficking of minors for sexual exploitation 301

194. In my opinion, Epstein used MC2 Model Management as part of his sex trafficking venture. Based on the materials I reviewed, Epstein relied, at least in part, on the financial services of JPMorgan to support MC2 Model Management.

H. Jeffrey Epstein's Sex Trafficking Venture Relied On Many Individuals And Entities—Including JPMorgan—To Operate

195. Based on my experience and as the human trafficking typologies described above illustrate, sex trafficking operations are organized in different ways, ranging from one individual to multi-level organized crime rings. After reviewing the materials in this case, it is my opinion that Epstein did not act alone. Rather, he directed a number of individuals to run a sex trafficking venture which recruited young girls and women to perform commercial sex acts often through coercion, force, or fraud.

196. I have included excerpts below to demonstrate some of the roles of additional participants in his sex trafficking venture. This is not meant to be an exhaustive list but rather examples of the type of evidence I relied on in reaching this opinion.

197. The NPA identified tential co-conspirators of "including but not limited to Lesley Groff, or ."3°3 The terms of the NPA state "if Epstein successfully fulfills all of the terms and conditions of this agreement, the United States also agrees it will not institute any criminal charges against any potential coconspirators of Epstein."3°6

3°2 JPM-SDNYLIT-00054521.

3°3 JPM-SDNYLIT-W-00000001 at 00000175.

"'The Associated Press, Jeffrey Epstein Associate Jean-Luc Brunel Is Found Dead in a Jail Cell, NPR (Feb. 19, 2022), https://www.npr.org/2022/02/19/1081961087/jeffrey-epsteinjean-luc-brunel-dead.

3°3 NPA at 5.

3°6 Id.

3°7 Id.

1°8Exhibit F is Figure 15 from the Amador Report.

3°9 Exhibit G is Figure 9.3 from the Amador Report.

31°Exhibit H is Figure 9.2 from the Amador Report.

3" Dan Mangan, 'Unhappy Ending' Plea Deal, N.Y. Post (Oct. 1, 2007), haps://nypost.com/2007/10/01/unhappy-ending-plea-deal/; Dareh Gregorian, / Was Teen Prey of Pervert Tycoon, N.Y. Post (Oct. 18, 2007), https://nypost.com/2007/10/18/i-was-teen-preyof-pervert-tycoon/.

312 Prince Andrew: Ties to Jeffrey Epstein and His Tenuous Position in 'the Finn', Vanity Fair (June 29, 2011), https://www.vanityfair.com/news/2011/06/prince-andrew-ties-to-jeffreyepstein-and-his-tenuous-position-in-the-firm.

313 Jeffrey Epstein Gets Off With a Little Help From His Friends, Gawker (July 27, 2016), https://www.gawker.com/190237/jeffrey-epstein-gets-off-with-a-little-help-from -hi s-friends.

200. Based on the materials I reviewed, Epstein relied, in part, on others to recruit and obtain victims for his sex trafficking venture, including:

314Nolan, Jeffrey Epstein Kept Company in Jail By His Alleged Lesbian Sex Slave, Gawker (July 22, 2009), https://www.gawker.com/5320323/jeffrey-epstein-kept-company-injail-by-his-allesd-lesbian-sex-slave,

315 Stephen M, Prince Andrew Named in Sex liz But Billionaire Pervert's Girl Aides Refuse to Say if They Even Know Daily Mail (Mar. 7, 2011), https://www.dailymail.co.uk/news/article-1363701/Prince-Andrew-named-sex-quiz-Jeffrey-Epsteins-aides-refuse-say-know-royal.html.

316 Catherine Ostler, Unsavoury Association: How Robert Maxwell's Daughter 'Procured Young Girls' for Prince Andrew's Billionaire Friend, Daily Mail (Mar. 5, 2011), hnps://www.dailymail.co.uk/news/article-1363247/Unsavoury-association-How-Robert-Maxwells-daughter-procured-young-girls-Prince-Andrews-billionaire-friend.html.

317 Tom Leonard, Prince Andrew Risks Losing Ambassador Job as Girl in Underage Sex Case Reveals Meeting Him, Daily Mail (Mar. 2, 2011), https://www.dailymail.co.uk/news/article-1361296/Prince-Andrew-risks-ambassador-job-underage-sex-case-girl-reveals-meetinghim.html.

318 Vincent M, Prince Andrew: David Cameron's Adviser Gives Dressing Down to of York Over Links to Billionaire Child Sex Offender Jeffrey Epstein, Mirror (Mar. 6, 2011) hnps://www.mirror.co.uk/news/uk-news/prince-andrew-david-camerons-adviser-114577.

319 VI-JPM-000001756 at 31 ([REDACTED] Dep. (May 3, 2016) at 113:18-117:12).
320 Unsealed Maxwell Documents at 53 (Tony [REDACTED] Dep. (June 24, 2016) 88:12-24).
321 Unsealed Maxwell Documents at 65 (Tony [REDACTED] Dep. (June 24, 2016) 200:5-24).
322 2006 PBPD Probable Cause Affidavit Incident Report at 1-4, 14.
323 [REDACTED] Dep. (May 5, 2023) at 77.
324 Id. at 84.
325 Id. at 86.
326 Id. at 88.
327 [REDACTED] Dep. (Mar. 3, 2023) at 93.

328 Id. at 120-124.

329 III Dep. (Mar. 3, 2023) at 115-120.

33° JDoeDBAG\_005816 at 5824.

331 Dep. at 198.

332 Dep. at 198.

333 2006 PBPD Probable Cause Affidavit at 11-12.

334 Unsealed Maxwell Documents at 22 (John Alessi Dep. (June I, 2016) at 103:4-104:14).

338 a

also took and Epstein to the airport where Epstein's private jet was parked. His wife would drive the staff and luggage.336

b.

I. JPMorgan Had A Unique Opportunity To Intervene And Help Epstein's Victims Who Banked With JPMorgan—Including M 343

336 id.

337 ESTATE 000077.

338 ESTATE\_000149 at 0149.

339 Id.

34° Id. at 0157.

341 Amador Report at 25, Ex. F; NPA at 5.

342 JPM-SDNYLIT-00152809.

343told me that her name when she entered the United States was ' and she later changed her name to . This combination of ' and ' rears throughout JPMorgan's documents, the NPA, and sometimes the media. I do not believe " was ever her legal name.

focusing on one victim, M, because in my opinion, she represents multiple human trafficking typologies employed by Epstein and multiple red flags were present in JPMorgan's own records and communications about her.

344 JPM-SDNYLIT-00013546 (JPMorgan's DDR for Epstein states that Bnmel's agency was called "Karin Paris")

As described above, Epstein asked JPMorgan to open an account for in early 2004 solely with information supplied by Epstein's associate, Eric Ganey.?'15 Epstein was listed as the Decision Maker (referred to also as "DM") on the DDR.Ith According to JP.an's own DDR, the bank did not obtain a date of birth for . Also, the social security number provided by Epstein's associate was identified by JPMorgan as "a valid number, but not yet issued."347 JPMorgan also did not look at 's government issued identification and documented that

JPM-SDNYLIT-00036564.

345 JPM-SDNYLIT-00036564.

had a net worth of \$100,000 from modeling assignments.348 In the DDR, Mary Reith (= promised to follow up and talk with 349 but admitted in her deposition she never did.35°

34B JPM-SDNYLIT-00036564 at 6565.

349 Id.

350Mary Dep. (Apr. 7 2023 at 138.

's recollection of this year and the amount is consistent with information compiled in IPMorgan Due Diligence about Epstein which noted: "MC2 Model Management received \$1 million from Epstein in 2005. It is unknown if the money was given as a secret investment or payment for services as a procurer."353

352 I was not taking notes during this meeting and this is my best recollection of what words she used. My understanding from the interview was that Epstein meant the \$1 million to MC2 Model was what he had to pay to obtain or keep her and now she owed him that same amount.

353 JPM-USVI-00000594

355 JPM-SDNYLIT-00030057.

208.

209. Based on the materials I reviewed, JPMorgan Private Banking employees never spoke with They never confirmed her account information or asked her about any of the information they knew about her from their due diligence research. However, even if we ignore everything I learned from and look only at JPMorgan's own due diligence and its own human trafficking typology, there were multiple documented indicators or red flags of 's human trafficking.

Epstein sponsored in the private bank "the opening of DDA accounts and a cc for "two 18 year olds (turned 19 days later) that appear to be part of his inner entourage. One is mentioned in many of the recaps of the escapades as a willing participant and assistant when hosting visitors. She has received about \$450,000 since opening from Epstein...The willing participant had some lovely debit

356 JPM-SDNYLIT-00013546 at -00013562.

357 Typology at 37.

388 JPM-SDNYLIT-00174075.

359 JPM-SDNYLIT-00036580 at 00036596.

3613 JPM-SDNYLIT-00174075.

361 JPM-SDNYLIT-00036564.

367 JPM-SDNYLIT-00152809.

charges and spends a good deal at spa establishments. He did pay other girls, many models, no huge amounts. Sugar Daddy!" 363

211.

3° Id.

364 JPM-USVI-00000594

365 JPM-USVI-00000595

366 JPM-USVI-00000594

367 JPM-USVI-00000594.

369 JPM-USVI-00000592.

369 JPM-USVI-00000592.

37° JPM-SDNYLIT-00036564.

37' Shannon Thaler, Jeffrey Epstein Victims Plead with JPMorgan Execs to Admit They Knew about Abuse, N.Y. Post (June 6, 2023), https://nypost.com/2023/06/06/jeffrey-epstein-victimsplead-with-jpmorgan-execs-to-admit-they-luiew-about-abuset

and your bank should have recognized that what he was doing was criminal and illegal." She also said, "Knowing full well that your bank and your bank alone had information to corroborate what dozens of kids like me were saying about the cash that he used to lure us in, abuse us and keep us quiet, you never notified law enforcement who were investigating his crimes." A third unidentified woman wrote to JPMorgan: "Why did you let him stay at your bank after you knew the horrible things that he had done to so many little girls."

J. Compensation For The Harms Victims Suffered Should Reflect The Severity, Scope, And Duration Of The Abuse They Suffered

372 JPM-SDNYLIT-00036564 at 36566.

373Mary Dep. (Apr. 7, 2023) at 136:14-138:13.

374 Supra note 2 at 273.

375 In its 2022 report, Using Civil Litigation to Combat Human Trafficking, the Human Trafficking Legal Center reported that since the passage of the civil remedy and as of December 31, 2021 there were 539 human trafficking civil actions filed in federal court. The report ends with this statement "[for trafficking survivors, the civil remedy has become — and continues to be — an essential tool to hold traffickers accountable in the federal courts." Merrick M. Black, Using Civil Litigation to Combat Human Trafficking: Federal Human Trafficking Civil Litigation: 2021 Data Update, Human Trafficking Legal Center (Sept, 2022) at 5, 24.

376 Jordana Dep. (May 1,2023) at 83:2-4.

377 EVCP00000006.

378 According to documents prepared by the EVCP, 361 individuals applied to the EVCP, 245 were sent claims packets and of those 148 were deemed eligible and 136 of those individuals accepted offers.

379 Epstein Victim Compensation Program, Protocol (May 29, 2020) at 7, htms://www.epsteinvcp.com/documents/4.

38° EVCP00000006.

381 This approach has been utilized by courts to assess a labor-trafficking victim's emotional distress damages. See, e.g.,Mv. Jenkins, 325 F. Supp. 3d 1141,1173-74 (D. Kan. 2018).

the U.S. Virgin Islands this amount; rather, it is my opinion this is a reasonable proxy for assessing how much money per victim would be needed to set up such a fund.

382 Unsealed Maxwell Documents at 257 (David Rodgers Dep. (June 3, 2016) at 103:10-22) (explaining that at least one of Epstein's pilots did not keep a flight log).

383 I picked these years because the flight logs seemed more complete than other years.

384 For the total number of potential female victims, I did not include Ghislaine Maxwell or females traveling in family units with individuals I assumed were male relatives (e.g., , I did not include an individual listed as "nanny" or someone referred to as "JP." nor did I include Larry Visoski's (pilot) family members. I did include individuals without a name but listed as "female".

385told me she traveled to the USVI many times with Epstein. She said it was so many times she was could not even estimate because it was such a regular occurrence.

K. JPMorgan Should Implement Meaningful Injunctive Relief To Prevent Future Participation In Sex Trafficking Ventures

386 In Harm's Way: How Systems Fail Human Trafficking Survivors, Survey Results from the First National Survivor Study, Polaris Project (Jan. 2023), https://polarisproject.org/wpcontent/uploads/2023/06/In-Harms-Way-How-Systems-Fail-Human-Trafficking-Survivors-by-Polaris.pdf, at 37.

387 /d.

3g8 Id.

389 Id. at 38.

experiences in re resenting and advocating for trafficking victims and with experience. After was exited by JPMorgan, she struggled to access basic banking services. I believe, to prevent recurrence of the failures I observed, JPMorgan should work with human trafficking experts and individuals who have been victims of trafficking to develop special accommodations or banking products and protocols to address the unique needs trafficking victims face after being exploited and financially abused. This may, as the National Survivor Study suggests, include "providing access to bank accounts without overdraft fees and penalties."39°

39° Id. at 39.

V. CONCLUSION

236. Given the above facts and principles and my expertise in the area, I herein state the following summary opinions:

237. I reserve the ability to supplement or amend my opinions, to state further opinions, or to rebut any subsequent allegations, depositions, expert reports, etc. that might arise in these matters.

Respectfully submitted, this 16th day of June 2023.

Bridgette

Exhibit A

BRIDGETTE CARR Clinical Professor of Law University Of Michigan Law School

FDITCATION

University of Michigan Law School Juris Doctor, Cum Laude December 2002

University of Notre Dame Bachelor of Arts, Cum Laude May 1998

ACADEMIC PROFESSIONAL EXPERIENCE

Clinical Professor — University of Michigan Law School Co-Director, Human Trafficking Clinic and Lab September 2011 — Present (Clinical Assistant Professor 2011-2013)

Teach and supervise law students providing direct legal representation to victims of human trafficking. Direct and facilitate a social justice innovation lab with graduate students from multiple disciplines to address the root causes of human trafficking.

Associate for Strategic Initiatives — University of Michigan Law School August 2018 — June 2021

Provided academic and administrative oversight for a multidisciplinary program involving graduate and professional schools, including curriculum development, personnel, and strategic planning decisions. Created a problem-solving bootcamp used program-wide.

Adjunct Clinical Assistant Professor— University of Michigan Law School Director, Human Trafficking Clinic

Domestic and South Africa Externship Supervisor July 2009 — August 2011

Developed and directed the Human Trafficking Clinic and the Human Trafficking Law Project. Taught and supervised law students providing direct legal representation to victims of human trafficking and students in extemship courses.

Associate Clinical Professor of Law — Notre Dame Law School Director, Immigrant Rights Project July 2007 — June 2008

Developed and established the Immigrant Rights Project Clinic. Taught and supervised law students providing direct legal representation to indigent asylum seekers, immigrant victims of domestic violence and victims of human trafficking.

Ann Arbor. MI

Notre Dame, IN

Ann Arbor, MI

Ann Arbor, MI

Ann Arbor, MI

Notre Dame, IN

BRIDGETTE CARR Clinical Professor of Law University Of Michigan Law School

Assistant Clinical Professor of Law — Ave Maria School of Law Director, Asylum and Immigrant Rights Law Clinic October 2006 — July 2007

Directed the Asylum and Immigrant Rights Law Clinic. Taught and supervised law students providing direct legal representation to individuals seeking humanitarian immigration relief.

Assistant Clinical Professor of Law — Ave Maria School of Law June 2004 — September 2006

Developed and established the law school's first clinical program. Taught and supervised law students providing direct legal representation to individuals seeking humanitarian immigration relief.

Ann Arbor, MI

Ann Arbor, MI

PROFESSIONAL EXPERIENCE

Survivor Reentry Project — Expert Consultant Michigan November 2015 — November 2017

United Nations Office on Drugs and Crime — Expert Consultant Remote Work January 2014 — May 2014

Associate Attorney Canfield, Paddock & P.L.C. Michigan January 2003 — May 2004

SELECTED PUBLICATIONS

Bridgette Carr, Anne Milgram, Kathleen., and Stephen Wamath, Human Trafficking Law and Policy, LexisNexis (1st ed. 2014)

Munro-Kramer, M. L., M, D. C., =, K. E., & Carr, B. A. (2022). Understanding Health Facility Needs for Human Trafficking Response in Michigan, NATIONAL INSTITUTES OF HEALTH (Nov. 3, 2022).

M, Anna & Guikema, Seth & Cam Bridgette, Why are You Here ? Modeling Illicit Massage Business Location Characteristics with Machine Learning, JOURNAL OF HUMAN TRAFFICKING 1-21 (Oct. 4, 2021).

Munro-Kramer, & & Choi, Kristen & =, Rebecca & Gebhard, Annemarie & Carr, Bridgette, Human Trafficking Victims Service Needs and Outcomes: An Analysis of Clinical Law Data, JOURNAL OF HUMAN TRAFFICKING, No. 6, 95-108 (Apr. 1, 2019).

BRIDGETTE CARR Clinical Professor of Law University Of Michigan Law School

When Federal and State Systems Converge: Foreign National Human Trafficking Victims within Juvenile and Family Courts, Juv. & Fam. Ct. J. 63, No.1 (Winter 2012)

Examining the Reality of Foreign National Child Victims of Human Trafficking in the United States, 37 Wash. U. J.L. & Pol'y 183 (2011)

Special Symposium Feature: Successes and Failures in International Human Trafficking Law: Introduction, 33 Mich. J. Intl. L. 33 (2011)

Incorporating a "Best Interests of the Child" Approach into Immigration Law and Procedure, 12 Yale Hum. Rts. & Dev. L.J. 120 (2009)

We Don't Need to See Them Cry: Eliminating the Subjective Apprehension Element of the Well-Founded Fear Analysis for Child Refugee Applicants, 33 Pepp. L. Rev. 535 (2006)

BAR ADMISSIONS

State of Michigan

ERRATA SHEET FOR EXPERT REPORT OF BRIDGETTE CARR

ad, eco,\_ BridgetdeCarr

/4.93 Date