I" Id.
Im Id.
tantamount to a methodology that could be assessed for reliability and objectivity in empirical interpretation; and
- 3. The reliability of Ms. Carr's so-called methodology is further brought into question by her claim to have "assessed" whether the discovery is consistent with "typology and indicators of trafficking." Even if all allegations and Plaintiff testimony are accepted as true, descriptive comparisons clearly illustrate that the present matter is significantly atypical of trafficking trends in the United States. Ms. Carr provides absolutely no objective data or method to suggest otherwise; therefore, the basis of her opinion remains wholly unclear and, more likely than not, subjective and/or skewed by confirmation bias.
While Ms. Can claims to have "arrived" at her testimony by "applying the principles and methods commonly used in the field of human trafficking in the United States," she fails to define what "principles" or "methods" she used. The closest Ms. Can comes to describing what could possibly be considered a "method" would be her claim to have conducted a "review" of the "authoritative literature." Ms. Can does not explain whether her "review" was narrative, integrative, semi-systematic, or systematic,'" nor does she define what constitutes "authoritative" research in her opinion.
Moreover, although Ms. Canr fails to specify the type of "review" she conducted, it appears that her methodology consisted of nothing more than a narrative review or literature review, at best. A narrative review or literature review is the type first-year college students often learn as a general approach to research. Its purpose is to identify a few studies that describe a problem of interest. Narrative reviews and literature reviews should have no predetermined research question or specified search strategy, only a topic of interest;'" however, they also be affected by intentional or unintentional "cherry-picking" of a subset of research to lead to a desired finding or conclusion.
Traditional literature reviews or narrative reviews often lack thoroughness and rigor, can be affected by bias, and are conducted ad hoc, rather than following a specific methodology.' They are not systematic and there are no standards or protocols used to guide the review. As such, although the reviewers may learn something about the problem, they will not arrive at a comprehensive understanding of the state of the science related to the problem and the findings will have no articulable reliability, per se.158
I55 Supra, Section II.
136 Science Direct, n.d, Narrative Review, retrieved from:
hups:/Avww.sciencedirect.com/topics/psychologyinarrative-review.
157 Hannah =, Literature review as a research methodology: An overview and guidelines, Journal of Business Research, vol. 104, pp. 333-339 (Nov. 2019), https://doi.org/10.1016/j.jbusres.2019.07.039.
I" Science Direct, n.d, Narrative Review, retrieved from:
hups://www.sciencedirect.comkopics/psychologyinarrative-review
Despite conceptualizing her “review” of “authoritative literature” as a “methodology,” Ms. Carr provided no list of databases that were searched or any Boolean159 search phrase that was used to identify literature (for example, see Figure 10).160
| Search method | Keywords | Constraints | Exclusion |
|---|---|---|---|
| Title search | TITLE(“modern slavery” or “trade in human being” or “human trafficking” OR “trafficking in human” OR “lab”r trafficking” OR “forced lab”r OR “compulsory lab”r OR “sex” traffick” OR “sex” trade” OR “trafficking in persons” OR “traffick” person” OR “traffick” wom” OR “traffick” people” OR “traffick” girl” OR “wom”n traffick” OR “child” traffick” OR “organ traffick” OR “transplant tourism” OR “trafficking in wom” OR “traffick” in organ” OR “forced prostit” OR “trafficking of child” OR “trafficking of wom” OR “sex” slavery” OR “commercial sexual exploitation” OR “lab”r traffick” OR “organ trade” OR “forced marriage” OR “bonded lab”r OR “child harvesting” OR “modern slavery” OR “child prostitut” or “forced prostitut” or “domestic servitude” or “debt bondage” or “debt slavery” or “bonded lab”r or “child pornography”) | NONE | AND NOT TITLE-ABSTRACT (Insect or droso\* OR sexta OR cell OR molecular OR biology OR leukocyte\* OR DNA) |
Figure 10. Sample Boolean Search Phrase
As such, the “reliability” of the findings from her so-called methodology are questionable at best.
Opinions
Despite the vague and non-scientific methodology used by Ms. Carr she proffered 11 opinions on the present matter, which are summarized on page 77 of her report; each discussed further in the section below.
Carr Opinion A: Human trafficking presents in different ways but has the same core elements.
While I do agree that human trafficking presents in different ways, I disagree with Ms. Carr on the elements that are consistent across trafficking cases. In support of her opinion, Ms. Carr claims that there are two core elements:
- 1. Targeting of vulnerable individuals; and
- 2. Compelled service.161
Ms. Carr provides no citation for her opinion, which seems to be based on nothing more than a simplified and generalized background of human trafficking. [REDACTED] have chosen to focus on a general application of “core elements,” as opposed to “trends” and “commonalities” across cases, because the later would illustrate the atypicality of the present allegations, when compared to human trafficking cases, and perhaps expose limitations with regards to reliability. For example, Ms. Carr’s colleague and mentor, Luis C.deBaca previously issued reports in separate matters, which identified what he perceived were “trends” and “commonalities” of coercion across cases (see Table 6). Only two of Mr. C.deBaca’s purportedly generalizable “trends” and/or “commonalities” were consistent across the cases for which he issued the reports:
- 1. Overt threats and violence; and
- 2. The effect of official corruption on trafficking victims’ willingness to come forward.
159 Supra, Section II.
160 Sampled from Sweileh, W.M., Research trends on human trafficking: a bibliometric analysis using Scopus database, Global Health vol. 14, 106 (2018), https://doi.org/10.1186/s12992-018-0427-9.
161 Carr Report, ¶ 16.
Table 6. "Trends" and/or "Commonalities" identified by Luis C.deBaca in Separate Cases
| Case 1 “Trends”162 | Case 2 “Trends”163 |
|---|---|
| Holding of passports or other identification documents. | |
| Physical isolation and control of movement. | |
| Leveraging of pre-existing debt, smuggling debts, or recruitment fees. | |
| Levying additional debts in the workplace (the “company store”). | |
| Unsafe work environment. | |
| Overt threats and violence | Overt threats and violence. |
| The effect of official corruption on trafficking victims’ willingness to come forward. | The effect of State power and political corruption on workers’ willingness to come forward. |
| Breach of contract, withholding of contracts, or substitution of contracts during the recruitment or transportation stages. | |
| Imbalances of power between guestworkers, recruiters, and their sponsoring employers. | |
| The particular vulnerabilities of workers on guestworker visas in the United States and other countries. | |
| The effect on foreign workers of both explicit threats and more subtle reminders of the potential for law enforcement or deportation. |
While Mr. C.deBaca's "trends" and/or "commonalities" can be evidenced in other trafficking cases, the Plaintiff cannot point to any evidence or testimony to suggest that JPMC was aware of any of these elements in the present matter. Instead of acknowledging the atypicality of the present matter and the inherent difficulty with third party identification of human trafficking crimes, Ms. Carr uses a broadened interpretation of general information and a subjective application of unreliable indicia to support her capricious opinions.
While I agree with Ms. Carr that human trafficking presents in different ways, the most consistent element across cases is exploitation. For example, using a sample of cases from a database developed by Ms. Can (Appendix G), victims are often compelled to turn over all or most of their money to their trafficker; thus, illustrating the atypicality of the present matter.
Carr Opinion B: One Common Theme In Human Trafficking Is The Targeting Of Vulnerable People To Victimize.
While I do not disagree with this opinion in principle, Ms. Can's interpretation of the elements of vulnerability and the indicia of victimization are not rooted in state of the science research, but rather her subjective and anecdotal experience.
162 Rathay. Phatthana Seafood Co., Case No. 16-2-28453-I KNT.
163 Casilao v. Hotelmacher LLC, Case No. CIV-17-800-M; Francis v. Apex. USA, Case No: CIV-I 8-583-HE.
In support of this opinion, Ms. Carr cites "the first National Survivor Study" published by the Polaris Project in 2023.164 Ms. Can attempts to authoritatively claim that the study found that "[t]he vast majority of trafficking survivors faced trauma, abuse, poverty, mental health challenges, and other struggles in childhood,"165 which is "consistent with" the experiences of her clients.166 Ms. Can ignores the fact that this study was based on a small, non-random sample of only 457 survivors and, more importantly, the authors of the report acknowledge, in bold, "our data is not representative of all trafficking survivors and generalizations about all survivors should not be made from this data."167 Yet, despite this limitation, which is clearly highlighted for readers, Ms. Can irresponsibly and erroneously attempts to generalize these data to the present case and reference these findings as reliable fact.
Despite the dearth of empirical data, trafficking risk and targeting can be best conceptualized through the established theory related to Maslow's hierarchy of needs, as discussed in my book, Hidden in Plain Sight America's Slaves of the New Millennium, (for reference, see Figure 11). Essentially, an individual at-risk of being trafficked, more often than not, has a void. In order to manipulate the victim, a trafficker typically makes a false promise that will ostensibly fulfill the respective void. As such, the determination of whether a trafficker coerced, defrauded, and/or exploited a particular victim is highly individualized by both victim risk and trafficker recruitment and control methods. Self-Actualization e-Sci nal nrce.lh fulfillment Self-Esteem Needs achievement respect from community. reputation Social Needs belonging, love family. work groups Safety Needs protection, security. law. Job, health-care Physical Needs food. shelter. Comfort, temperature Figure II. Madow's Hierarchy of Needs
While non-profits such as Polaris recognize that smaller, non-random surveys are "not representative of all trafficking survivors and generalizations about all survivors should not be made" from their data (emphasis in the text of the cited document), Ms. Can repeatedly and inappropriately attempts to use her anecdotal experiences to make generalizable claims to the present matter, which are even inconsistent with the evidence in record.
For example, Ms. Can states that based on her experience, victims have access to money and victims do not appear to be financially deprived because "traffickers may expect their victims to maintain a certain look, shop, obtain beauty services, and receive money for shopping or gifts for
161 Can. Report, 1 26.
165 lesId. 1 27.
167 Polaris Project, In Harm's Way: How Systems Fail Human Trafficking Survivors, Survey Results from the First National Survivor Study, p. 17 (Jan. 2023), hlips://polarisproject.ors/wp-content/uploads/2023/06/In-Harms-Way-How-Systems-Fail-Human-Trafficking-Survivers-by-Polaris./xlf
their birthday."168 Ms. Carr references no research and cites to no cases to support this claim, which, as stated, is inconsistent and atypical of trafficking. In reality, victims are often financially deprived and have little or no access to money during their trafficking period (for examples, see Appendix G). If they are provided with services, this is typically under the direction of the trafficker, not at the victims request, and the associated costs are quickly recouped through exploited labor.
Ms. Carr then claims that she "saw evidence that Epstein paid for clothes, haircuts and spa services. This is likely because Epstein wanted the women to look a certain way and was consistent with the trafficking venture."169 Not only is Ms. Carr's statement atypical of most trafficking cases and speculative in nature, but it is also contradicted by evidence in the record. For example, [REDACTED] asked "for color and a cut" and asked whether she should "do Phillipe for cut and Hubert for color"170. After the requested services were provided, these purported victims often expressed gratitude. For example, after receiving her hair cut and color treatment, [REDACTED] wrote, "Hey Jeffrey!! Thank you sso (sic) much for hair © here is a picture. Can't wait til you get back! Xoxoxo171." There is no reliable evidence to suggest that this was because Epstein wanted the women to look a certain way and was consistent with the trafficking venture.
Instead, many of the women who purported to be Epstein's sexual assault victims (but are accused by others to be co-conspirators) often asked for the items and services they received in a manner that is inconsistent with typical trafficking claims. For example, [REDACTED] sister, [REDACTED] received gifts of cash and food, as well as concert and airline tickets.172 She also received money for rent, education, clothes, and dance supplies, as well as medical and dental treatment.173 Moreover, like JPMC, none of the third parties encountered by Epstein's sexual assault victims suspected trafficking, reported "red flags," or were in a position to intervene.
The only case cited by Ms. Carr under her support for Opinion B was United States v. Maksimenko—a forced labor case from 2006, which Ms. Carr acknowledges that she worked on174 and as such, should have had close familiarity. In her report, Ms. Carr references the Maksimenko case as an example of how victims "may feel they are in a loving or reciprocally affectionate relationship" through "sexual coercion."175 This is diametrically different from how Ms. Carr and her client described the victimization during an MSNBC interview in 2007, as well as how it is described in the court documents. (For examples, see Table 7):
168 Carr Report, ¶ 29.
169 Id.
170 ESTATE\_JPM005030; ESTATE\_JPM005031
171 ESTATE\_JPM005032
172 ESTATE\_JPM018226, ESTATE\_JPM018227.
173 ESTATE\_JPM018227.
174 Carr Report, ¶ 2.
175 Id. ¶ 30.
Table 7. Maksimenko Allegations, ILO Operational Indicators, and Applicat ion lo the Present Matter
| Maksimenko All ation | ILO O rational Indicator' | A . dication to the Present Matter |
|---|---|---|
| Excessive working days. | Not alleged. | |
| hours . da | ||
| Excessive working hours. | Not alleged. | |
| A victim's mother was threatened. | Violence on family (threats or | |
| Withholding of money/wages. | Not alleged. |
Ms. Carr's description of the Maksimenko case in the report for the present matter appears to attempt to repackage the claims to match the facts of this case. While the Maskimenko case is typical of other trafficking cases, given the debt bondage, withholding of identification documents, excessive working days and hours, confiscation of money, overt threats, and violent
16 Strong Indicators are coded in Red. Medium Indicators are coded in Yellow. Weak Indicators are coded in Carr specifically stated, "They were met at the airport by Michael Aronov and Alex Maksimenko—the traffickers—and they were told that, 'You know what? Plans have changed. You're going to be going to Detroit." In the Shadows: Sex Slaves in America. 2007. MSNBC. htins://www.msnbc.com/documentarics/watch/sex-slaves-inamerica-44658243732.
178 While some of Epstein's alleged victims were told that the massages would have a sexual component, others claim that the sexual element was unexpected. This is not consistent with the type of deception about the nature of a job in a typical trafficking case, b t rath r th t of sexual harassment endemic in the massage therapy industry. JDoe .IPMC 003402, at 003405; Dep. Tr. 121.19-123:25, Mar. 3, 2023 (discussing the recruitment of
19 While alleged that on at least one occasion she had her passport confiscated, KLIMAN0000000I, there is no evidence that this was done for the purpose of commercial sexual exploitation. Moreover, there is also evidence that Epstcin's alleged victims travelled commercially both internationally and domestically and would therefore have had access to their identification documents. See. e.g., ESTATE\_JPM0I 8238 (noting domestic and overseas commercial flights for . Additionally, documents in evidence illustrate that purported victims were often asked if they wanted to travel (E.g., ESTATE\_JPM005196) or the purported victims proactively invited themselves to travel.
18e While this is alleged by in the Carr report (page 68). these allegations are inconsistent with the claims by others. Moreover, non-prosecution agreement, as well as by other victims. Despite was described as a ns irator b law enforcement in the 2007 claims, the records show that she received significant financial benefit from her relationship with Epstein. For example, according to Ms. Carr's Exhibit E from her report, was paid a total of \$767,772.64 from 2003 to 2013.
acts, these case facts are very different from the allegations in the present matter. Not only does Ms. Can's inconsistent and curated description undermine the reliability and objectivity of her testimony, but if allowed, it is at risk of significantly misinforming the trier of fact.
Last, in her support of Opinion Carr states that in many cases, she has "seen victims fear the police or fear they will be ignored..s181 Based on my research, experience, and education, I agree with this statement. However, Ms. Can fails to acknowledge how this fact undermines the central theory of this case—that third party businesses should be liable for the failures of law enforcement and governmental authorities. In her support of this statement, Ms. Carr cites to an article by Amy Farrell, Meredith Dank, Ieke de Vries, Matthew Kafafian, Andrea Hughes, & Sarah Lockwood titled Failing Victims? Challenges of the Police Response to Human Trafficking. The article cited by Ms. Can acknowledges that "Victims of human trafficking rarely self-report their victimization, and those around the victim such as family members are unlikely to bring victimization to the attention of the police."'" The study also found that "even when investigators are aware of human trafficking, they struggle to distinguish individuals engaged in sex work as pe►petrators from people who may be victims of human trafficking."'"
As such, it is curious why Ms. Can's report attempts to hold a private business to a higher standard than the family members of victims and law enforcement.
Carr Opinion C: Human Trafficking Typologies And Red Flags Can Be Helpful When Assessing Potential Human Trafficking.
Again, while I agree with Ms. Can's opinion in principle, human trafficking typologies and red flags are most helpful when comparing typical facts to trends and commonalities, as evidenced across validated human trafficking cases.18A Conversely, it is unhelpful and potentially misinformative to opine on the basis of unsupported speculation or subjective belief, ecological fallacies, fallacies of composition, or unreliable so-called "indicia" or "red flags." Throughout her report, Ms. Carr demonstrates a clear and consistent misunderstanding on the reliability and/or generalizability of various data sources. For example, in an attempt to support her Opinion C, Ms. Carr cites to the Human Trafficking Hotline operated by Polaris as "verifiable data" on the prevalence of human trafficking, which is estimated as more than 32,000 cases between December 2007 to December 2016.185 This is potentially misinformative considering that there is no confirmation on what percentage of those cases led to trafficking adjudications and these purported calls for service were not random. Nevertheless, Ms. Carr attempts to apply these non-generalizable data to the present case; specifically, applying the Polaris "typologies" to
w ' Carr Report, 131.
u Emphasis added, page 656. Farrell, A, Dank, M, de Vries, 1, Kafafian, M, Hughes, A, Lockwood, S. Failing victims? Challenges of the police response to human trafficking. Criminol. Public Policy. 2019; 18: 649— 673.
183 Emphasis added, page 659. Farrell, A, Dank, M, de Vries, I, Kafafian, M, Hughes, A, Lockwood, S. Failing victims? Challenges of the police response to human trafficking. Criminol. Public Policy. 2019; 18: 649— 673.
1" Herein, a "validated human trafficking case" is defined as a case where a determination of trafficking was made either through a guilty plea or via adjudication by a trier of fact (e.g., a formal judgment on a disputed matter by a judge or a jury).
'" Carr Report, 1 32-33.
what Ms. Can categorizes as "Epstein's behavior." Not only is this purported "methodology" not based in reliable principles or methods, but Ms. Carr doesn't even accurately apply these empirically unvalidated typologies in a narrative fashion, as discussed further below.
Residential Trafficking
For example, with regards to residential trafficking, Ms. Carr writes:
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. ' lab
Although Ms. Carr claims that Epstein's behavior fits into this human trafficking typology, she provides no reference to any citation for this assessment. Sex trafficking within residences, as referenced in her cited report, is referring to private households that cater to commercial sex buyers and are run as traditional brothels. Epstein's victims do not affirmatively allege that they worked in a residential brothel. Moreover, in applying the "methods of control," as identified by Polaris, to the present matter, the facts of the current case were predominately atypical from the cases reported to the hotline regarding residential brothels (see Table 8).
fable 8: Polaris Methods of Control in Residential Brothels" versus Allegations Against Epstein.
| Method of Control | Application to the Present |
|---|---|
| Physical violence | Not alleged in a manner that is |
| Lethal threats to victims | Not alleged |
| Lethal threats to victims' families | Not alleged |
| Debt bondage | Not alleged |
| Extreme confinement | Not alleged |
| Monitoring | Not alleged in a manner that is |
| Addiction to illicit substances | Not alleged |
| Threats to harm or expose | Not alleged |
| Exploitation of familial or intimate relationship | Not alleged in a manner that is |
Escort Services
18b1d. 1 35a.
I" Polaris claims these findings were based on 1,290 cases reported over the course of approximately nine years.
18° In fact, some of the documents in evidence could be used to suggest that certain alleged victims were attempting to monitor Epstein's whereabouts. For example, ESTATE\_WM005034; ESTATE\_JPM005137; ESTATE \_JPM005151; ESTATE\_JPM005174; ESTATE JPM005184; and ESTATE\_JPM005195.
Next, with regards to escort services, Ms. Carr writes:
This typology includes commercial sex acts "...that primarily occur at a temporary indoor location." 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. "189
Again, although Ms. Carr claims that Epstein's behavior also fits into this human trafficking typology, she provides no reference to any citation for this assessment. Escort service sex trafficking, as referenced in the cited Polaris report, is referring to commercial sex acts that occur at temporary indoor locations, which are often described as "out-call," where traffickers deliver victims to a commercial sex consumer's hotel room or residence for "private parties," or as "incall," where potential commercial sex consumers cycle in and out of a temporary domicile, such as a hotel room. Epstein's victims do not affirmatively allege that they provided escort services. Moreover, in applying the "methods of control," as identified by Polaris, to the present matter, the facts of the current case were predominately atypical from the cases reported to the hotline regarding escort services (see Table 9).
Table 9: Polaris Methods of Control In Escort Services" versus Allegations Against Epstein.
| Method of Control | Application to the Present |
|---|---|
| Extreme physical violence, often accompanied by weapons | Not alleged |
| Extreme sexual violence, often accompanied by weapons | Not alleged in a manner that is |
| Unmanageable quotas | Not alleged |
| Debts | Not alleged in a manner that is |
| Threats of harm | Not alleged |
| Threats of police involvement | Not alleged |
| Excessive monitoring | Not alleged in a manner that is |
| Gang intimidation | Not alleged |
| Social isolation | Not alleged |
| Constant surveillance | Not alleged in a manner that is |
189 Cart Report,135b.
190 Polaris claims these findings were based on 4,641 cases reported over the course of approximately nine years.
Illicit Massage, Health, & Beauty
Ms. Can then goes on to discuss trafficking within illicit massage, health, & beauty industries as follows:
In this typology, a facade 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." The trafficker profile for these cases includes onsite managers which "...tend to be women of the same ethnicity and may have been trafficked themselves in these businesses before becoming part of the larger trafficking network." To control the victims in these cases, they may be forced to live on-site and have their movement monitored.19I
Again, although Ms. Carr claims that Epstein's behavior also fits into this human trafficking typology, she provides no reference to any citation for this assessment. Sex trafficking in the illicit massage, health, & beauty industries, as referenced in the cited Polaris report, is referring to commercial sex acts that occur in "single storefronts" under the facade of legitimate spa services. Epstein's victims do not affirmatively allege that they provided commercial sex services while trapped working in a single storefront. Moreover, in applying the "methods of control," as identified by Polaris, to the present matter, the facts of the current case were predominately atypical from the cases reported to the hotline regarding trafficking in the illicit massage, health, & beauty industry (see Table 10).
Table 10: Polaris Methods of Control In Iffielt manage, Health, & Beauty Industries' versus Allegations Against Epstein.
| Method of Control | Application to the Present |
|---|---|
| Extreme intimidation | Not alleged |
| Threats of shame | Not alleged |
| Isolation from the outside community | Not alleged |
| Debt bondage | Not alleged |
| Exploitation of communication bathers | Not alleged |
| Explicit threats | Not alleged |
| Implied threats | Not alleged in a manner that |
| Forced to live at the business | Not alleged |
| Controlled movement between work and home | Not alleged |
| Day-to-day actions monitored in-person or off-site with a CCTV camera | Not alleged |
191 Carr Report, ¶ 35c.
12 Polaris claims these findings were based on 2,949 cases reported over the course of approximately nine years.
Arts and Entertainment
Ms. Carr then goes on to discuss trafficking within the arts and entertainment industries as follows:
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." Traffickers may be "recruiters and executives in model management companies" and they may control victims through sexual abuse and harassment193
Again, although Ms. Can claims that Epstein's behavior also fits into this human trafficking typology, she provides no reference to any citation for this assessment. Labor trafficking in the arts and entertainment industries, as referenced in the cited Polaris report, is referring to labor trafficking in exotic dancing, with no accompanying sex act, or in a variety of sectors of the arts and entertainment industry, including modeling, athletics, and less commonly performing arts such as acting, choirs, and dance troupes. Moreover, in applying the "methods of control," as identified by Polaris, to the present matter, the facts of the current case were predominately atypical from the cases reported to the hotline regarding trafficking in the arts and entertainment industries (see Table 11).
Table I I: Polaris Methods of Control In Arts and Entertainment versus Allegations Against Epstein.
| Method of Control | Application to the |
|---|---|
| Sexual abuse and harassment | Not alleged in a manner |
| Not paid | Not alleged |
| Charged exorbitant fees for crowded housing | Not alleged |
| Excessive practice and/or exercise routines | Not alleged |
| Exhaustion | Not alleged |
| Limited access to food | Not alleged |
| Limited access to hygiene | Not alleged |
| Wage confiscation | Not alleged |
| High fees | Not alleged |
| Emotional abuse | Not alleged in a manner |
| Psychological manipulation | Not alleged in a manner |
Personal Sexual Servitude
Finally, Ms. Carr discusses personal sexual servitude trafficking as follows:
193 Carr Report, 35d.
1" Polaris claims these findings were based on only 102 cases reported over the course of approximately nine years.
In this typology, payment is not always cash and the "line between ongoing sexual abuse and personal sexual servitude is complex." Trafficker profiles and recruitment vary, although victims "may be 'sold' by a family member to a trafficker." Traffickers use multiple forms of control including ongoing sexual assaults, threats, and isolation.195
Again, although Ms. Carr claims that Epstein's behavior also fits into this human trafficking typology, she provides no reference to any citation for this assessment. Personal sexual servitude, as referenced in the cited Polaris report, can occur when a woman or girl is permanently sold, often by her family to settle a drug debt, to an individual buyer for the explicit purpose of engaging in periodic sex acts over a long period of time. It can also occur within a commercial non-consenting marriage situation, primarily involving adult foreign national women. Moreover, in applying the "methods of control," as identified by Polaris, to the present matter, the facts of the current case were predominately atypical from the cases reported to the hotline regarding personal sexual servitude trafficking (see Table 12).
Table 12: Polaris Methods of Control in Personal Sexual Servitude Trafficking"'versus Allegations Against Epstein.
| Method of Control | Application to the Present |
|---|---|
| Sexual assaults | Not alleged in a manner that is |
| Physical abuse | Not alleged in a manner that is |
| Confinement | Not alleged |
| Isolation | Not alleged |
| Threats | Not alleged in a manner that is |
| Substance abuse | Not alleged |
| Withholding of food | Not alleged |
| Withholding of shelter | Not alleged |
| Drugs as forms of abuse or punishment | Not alleged |
Ultimately, it appears as though Ms. Carr has repeatedly curated information in an attempt to match the facts of the present matter. Overwhelmingly, using Ms. Can's own citations, the methods of control alleged in the present matter are remarkably different from the methods of control reported to the Polaris hotline. Moreover, even though there are a few allegations that may ostensibly fit within these trends, this should be interpreted cautiously. In fact, Ms. Carr goes on to note that protocols and indicators for human trafficking typically include caveats about the limitations, which is absolutely correct. Ms. Carr acknowledges that:
- I. The presence or absence of indicators is not definitive proof of human trafficking;
- 2. Not all indicators are present in every human trafficking situation;
195 Carr Reportli 35e.
16Polaris claims these findings were based on only 405 cases reported over the course of approximately nine years.
- 3. These lists are not exhaustive; and
- 4. No single indicator, by itself, is conclusive of trafficking.
Here, I agree with each of the four caveats listed by Ms. Can, but after acknowledging these appropriate limitations, Ms. Can claims, "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." Although all minors involved in the commercial sex industry should be treated as persons in need of social services, not all minors involved in the commercial sex industry are trafficked some minors engage in survival sex and some minors are not induced, but rather engage in commercial sex for money. If Ms. Can were correct, children would not continue to be criminalized for commercial sex acts. For examples, see the cases of In re. N.C.,I97 In re. M. V.,198 In re. M.D.,199 and In re. Aarica 5.200 Additionally, according to the Office of Juvenile Justice and Delinquency Prevention, in 2018 there were 260 children under the age of 18 arrested for prostitution and/or commercialized vice, 50 of whom were under the age of 15."
Finally, in attempt to support her Opinion C, Ms. Carr cites to three sets of "human trafficking indicators" from:
- (1) Department of Homeland Security;
- (2) Department of State; and
- (3) Department of Health and Human Services, Administration for Children and Families.
Ms. Can provides absolutely no reference to the basis of these indicators, the methodology used in their development, their sensitivity or specificity, or the venue for which these are most appropriately applied. Moreover, Ms. Carr offers no explanation for why these three sets indicators were referenced, other than claiming they were a "sampling" of "typical indicator lists under United States law" and were "representative" of the types of indicators relied upon by "experts within the field." Ms. Can does not state the sampling frame from which she selected these indicator sets and fails to provide the sampling criteria to elucidate on the selection. However, it should be noted that none of the "human trafficking indicator" sources selected by Ms. Can are named as a "comprehensive" human trafficking screening tool, identified by the Urban Institute in 2017202 (see Figure 12). However, the Operational Indicators of Trafficking in Human Beings, published by the International Labor Office in September of 2009 is listed as one of the first, if not the first, comprehensive human trafficking screening tool. It is also one of the few sets of indicators that was developed and tested through a research methodology. As such, it is commonly used by experts in application to civil trafficking cases internationally and in the United States.
linIn re N.C., 4 Cal. App. 5th 1235 (Cal. Ct. App. 2016).
IN In re M.P., 225 Cal.App.4th 1495 (Cal. Ct. App. Jul. 27, 2012).
'" In re M.D., 231 Cal. App. 4th 993 (Cal. Ct. App. 2014).
00In re Aarica S., 223 Cal. App. 4th 1480 (Cal. Ct. App. 2014).
S01 OJJDP. Estimated number of arrests by offense and age group. 2018.
buos://www.oiido.tov/oistatbb/crime/ucr.asp?table in=1
Meredith L. Dank, et al., Pretesting a human trafficking screening tool in the child welfare and runaway and homeless youth systems. New York, NY: Urban Institute, 2017.
Comprehensive Human Trafficking
| Tool Creator Department of Children and Families Human Connecticut Department of Children and Trafficking Nursing Toolkit Families Model Canadian Screening Tool to Help Identify a Department of Justice Canada Potential Victim of Human Trafficking Human Trafficking Identification: Screening Tool and Indiana Protection for Abused and Trafficked Humans Task Force Report Operational Indicators of Trafficking in Human Beings International Labour Organization Kentucky Rescue and Restore Coalition Screening Tool for Human Trafficking Victims Standardized Screening Trafficking Questions Ohio Human Trafficking Task Force Screening Protocol Tailored for the Ohio Department Ohio Human Trafficking Task Force of Rehabilitation and Corrections (DRC) and the Ohio Department of Youth Services (DYS) A Screening Protocol Tailored for the Ohio Department | Year n.d. n4. n.d. 2009 2010 2013 2013 |
|---|---|
| Ohio Human Trafficking Task Force of Rehabilitation and Corrections (DRC) and the Ohio Department of Youth Services (DVS) B Comprehensive Human Trafficking Assessment Tool Polaris Project Human Traff kking Assessment for Medical Polaris Project Professionals | 2013 |
| Polaris Project Human Traff icking Assessment for Domestic Violence and Sexual Assault Programs | 2011 |
| Polaris Project Human Traffkking Assessment for Airlines and Airports | 2011 |
| Polaris Project Human Traff kiting Assessment Tool for Domestic Violence Programs Human Traff kking Assessment Tool for Educators | 2011 |
| Polaris Project Human Trafficking Incident Report | 2011 |
| Toledolucas County Department of Health | n4. |
| US Department of Health and Human Screening Tool for Victims of Human Trafficking for Law Enforcement Services. Administration for Children, Youth and Families (ACYF) Screening Tool for Victims of Human Trafficking for US. Department of Health and Human Health Care Providers Services. ACYF How to Identify a Human Trafficking Victim | n4. |
| United States Conference of Catholic Bishops | 2014 |
| Vera Institute for Justice Trafficking Victim Identification Tool (TVIT) | 2014 |
Figure 12: Comprehensive Screening Tools Identified by the Urban Institute
Ultimately, the sets of indicia included on page 11-13 of Ms. Carr's report have a questionable evidence base and many are hypothesized to have low rates of sensitivity and specificity. However, even when using the indicators sets selected by Ms. Carr, the overwhelming majority of indicia are absent from the present case (see Table 13).
Table 13: Indicators Referenced by Carr, by Agency, and Applied to the Present Case
| Purported Indicator | Agency | Application to the Present Matter |
|---|---|---|
| Does the person appear disconnected from family, friends, community organizations, or houses of worship? | Department of Homeland Security | No indication of JPMC being made aware of this purported indicator during the alleged victimization period in the present case. In |
| Purported Indicator | Agency | Application to the Present Matter |
|---|---|---|
| fact, the alleged victims were frequently connected with family, friends, etc. | ||
| Has a child stopped attending school? | Department of Homeland Security | No indication of JPMC being made aware of this purported indicator during the alleged victimization period in the present case. In fact, the alleged victims continued attending school. |
| Has the person had a sudden or dramatic change in behavior? | Department of Homeland Security | No indication of JPMC being made aware of this purported indicator during the alleged victimization period in the present case. |
| Is a juvenile engaged in commercial sex acts? / Under 18 in prostitution | Department of Homeland Security & Department of State | Alleged, but is unclear of whether the sexual abuse of minors in these instances meet the definition of a commercial sex act, considering that the money paid was associated with massages, referrals, or silence, not sexual acts. Although, according to the legal interpretation of the federal statute, all juveniles engaged in commercial sex acts are not trafficked, they are at high risk and should be treated as persons in needs of services. |
| Is the person disoriented or confused, or showing signs of mental or physical abuse? / Is unsure of day, date, month, year / Doesn't know where they live. | Department of Homeland Security & Department of HHS203 | No indication of JPMC being made aware of this purported indicator during the alleged victimization period in the present case. |
| Does the person have bruises in various stages of healing? / Signs of physical abuse / Physical abuse | Department of Homeland Security & Department of State & Department of HHS | No indication of JPMC being made aware of this purported indicator during the alleged victimization period in the present case. |
| Is the person fearful, timid, or submissive? / Submissive or fearful / Seems afraid to answer questions. | Department of Homeland Security & Department of State & Department of HHS | No indication of JPMC being made aware of this purported indicator during the alleged victimization period in the present case. |
| Does the person show signs of having been denied food, water, sleep, or medical care? | Department of Homeland Security | No indication of JPMC being made aware of this purported indicator during the alleged victimization period in the present case. |
| 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? / Is with a person who speaks for them. | Department of Homeland Security & Department of HHS | No indication of JPMC being made aware of this purported indicator during the alleged victimization period in the present case. |
| Does the person appear to be coached on what to say? / Answers appear to be scripted and rehearsed / Story doesn't make sense; seems scripted. | Department of Homeland Security & Department of State & Department of HHS | No indication of JPMC being made aware of this purported indicator during the alleged victimization period in the present case. |
203 Department of Health and Human Services, Administration for Children and Families Office.
| Purported Indicator | Agency | Application to the Present Matter |
|---|---|---|
| Multiple people in cramped space. | Department of State | No indication ofJPMC being made aware of |
| Inability to speak to individual alone. | Department of State | No indication ofJPMC being made aware of |
| Owes a debt to employer. | Department of HHS | No indication ofJPMC being made aware of |
| Department of HIIS | No indication ofJPMC being made aware of | |
| Department of NHS | No indication ofJPMC being made aware of |
SO1See, e.g., ESTATE\_JPM0 18238 (noting domestic and overseas commercial flights for
| Purported Indicator | Agency | Application to the Present Matter |
|---|---|---|
| Signs of having sex with multiple people | Department of HHS | No indication ofJPMC being made aware of |
| Department of MIS | No indication ofJPMC being made aware of | |
| Tattoos or branding of ownership | Department of II l IS | No indication ofJPMC being made aware of |
| Uses language of the sex industry | Department of HHS | No indication ofJPMC being made aware of |
| Department of HHS | No indication ofJPMC being made aware of | |
| Drugs/alcohol | Department of HHS | No indication ofJPMC being made aware of |
That said, if Ms. Carr had performed even a cursory review on the evidence-base of the indicator sources that she cites, she would know that the Department of Homeland Security indicators are not based on any empirical research. Rather, these purported "indicia" were developed through unscientific reference to anecdote from working groups.205 Although these indicia were recently
2° I personally interviewed Mick McKeown, who was Executive Director of the Homeland Security Advisory Council and Campaign Office during the time this toolkit was created, and he confirmed absolutely no research was used in the development of these indicators or to test their sensitivity or specificity for identifying potential trafficking.
tested to assess trainee retention of information,206 their efficacy, sensitivity, and specificity are still unknown, but are hypothesized to be low, due to documented issues related to misidentification, as discussed in greater detail in Supra Section V.
Carr Opinion D: Jeffrey Epstein Directed A Sex Trafficking Venture.
Despite the demonstrable limitations of the indicia that she attempts to rely upon, Ms. Carr makes the legal conclusion that "Jeffrey Epstein directed a sex trafficking venture," citing to:
- I. A reference to the grand jury findings from 2019, where Epstein was indicted for trafficking six years after the end of his business relationship with JPMC; and
- 2. A reference to the media article, where JPMC acknowledge that the 2019 indictment exposed a reality about Epstein, which they (and the rest of the American public) were not fully aware of during the business relationship, which nevertheless ended six years earlier.
JPMC do not contest that Epstein was a sexual predator, who was indicted for sex trafficking in 2019. However, a reliable analysis on his crimes will conclude that his sexual predilections are atypical of trafficking cases. Moreover, the public, including JPMC, were not made aware of the extent of his abuses until his indictment in 2019. Allegations alone are not actionable for most third-parties, which is why there is a reliance on law enforcement to properly investigate and intervene when and if allegations are brought to their attention.
Unfortunately, law enforcement repeatedly failed to adequately intervene; thus, delaying interventions by third parties. In fact, officers of the court were alleged to have deliberately withheld information, even from victims."?
Nevertheless, Ms. Carr incredulously claims that Epstein's behaviors were "textbook human trafficking" because "the power and control" Epstein "exerted over his victims" was "consistent with both the academic literature on sex trafficking" and other "sex trafficking ventures" that Ms. Carr claims to have analyzed in her casework.208 These statements are made without citation to any academic source and are made without reconciling the differences between the present allegations and the overwhelming majority of trafficking cases (e.g., which typically involve a lack of payment and/or debt). Car repeatedly terms "abuse." this article. 2' Carr Report, 140.
Instead of relying upon state of the science research, Ms. Can claims that her opinion is supported by Epstein's 2019 indictment and Ghislaine Maxwell's 2022 conviction for what Ms.
20G E. Savoia et al., A Quasi-Experimental Intervention Trial to Test the Efficacy of a Human Trafficking Awareness Campaign: The Blue Campaign, Journal of Human Trafficking 1-20 (2023).. Note: I served as a peer reviewer on
207 For example, in 2009, Brad filed suit on behalf of clients regarding the failure of the federal government to provide them information under the Crime Victims Rights Act. OPR Report, ii.
Again, although Ms. Carr claims that Epstein\_directed a "textbook human trafficking" venture, she fails to cite to a single case or academic source which is comparable.
Instead, Ms. Carr simply cites to a curated selection of facts to support the contention that:
- I. Epstein engaged in commercial sex with girls under the age of 18; and
- 2. Epstein used fraud, force, and/or coercion to induce girls and young women to perform commercial sex acts.
In this section, it is important to first acknowledge that Ms. Can discounts the fact that the discovery of the extent of the allegations against Epstein and Maxwell came in 2019, six years after the end of the business relationship. To this effect, Ms. Carr fails to properly address the impact of confirmation bias and/or hindsight bias as significant limitations to her opinions (see Supra Section II).
Ms. Can• claims that the Palm Beach Police Department's investigation into Epstein in 2006, "provides evidence of a pattern consistent with a sex trafficking venture."209 This opinion is most certainly impacted by confirmation bias and/or hindsight bias, considering the fact that the Palm Beach Police failed to indict Epstein for trafficking crimes at the time. Ms. Carr further completely ignored the language in the police report, which predominately accused Epstein of "molestation" or "sexual battery", not trafficking. Ms. Cart also ignores the implication of the fact that Palm Beach charged Epstein with "unlawful sex with a minor," but he was eventually indicted for and convicted of "procuring for prostitution a girl below age 18."
Yet, even though (1) Palm Beach police did not charge Epstein with trafficking in 2006; (2) Palm Beach prosecutors did not charge Epstein with trafficking in 2006; (3) The Grand Jury did not indict Epstein for trafficking in 2006; and (4) Epstein was not convicted for trafficking in 2006,210 Ms. Carr claims that the incident report "provides evidence" of a pattern consistent with a sex trafficking venture.'"
Ms. Can failed to cite to any testimony, fact, evidence, literature, or case law that would suggest that these allegations are ostensibly consistent with trafficking. Instead, Ms. Carr's interpretation relies heavily upon the non-prosecution agreement212 that Epstein signed on December 7, 2007213 and was made public on September 18, 2009,214 which states that there was a federal investigation into offenses that may have been committed by Epstein from 2001 through approximately September 2007. This investigation included multiple offenses regarding illicit
2°9 Carr Report, 1 43 (citing JDoe\_DBAG\_005374 ("2006 PBPD Incident Report")).
310 As acknowledged by Ms. Carr, 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 JDoe\_JPMC\_004535 at 42.
211Note: I contest the notion that a police report "provides" evidence, as described by Ms. Cam
212 JDoe\_DBAG005165 ("Non-Prosecution Agreement" or "NPA").
213 For example, see Can Report 1 46.
2" See OPR Report 240.
sexual conduct involving minors and an investigation into sex trafficking; however, Epstein was not ultimately indicted or convicted for these alleged offenses.
The comparable cases of Charlie Chaplin, Jack M, and Eleanor as discussed in Supra Section VII, is an example of why allegations alone should not be actionable.
Prior to 2019, although Epstein's crimes were not apparently consistent with trafficking, he was not indicted for trafficking, he was not convicted of trafficking, and there is no reliable empirical basis or fact evidence to conclude that Epstein was engaged in trafficking, Ms. Carr proffers the legal conclusion that Jeffrey Epstein directed a sex trafficking venture. Ms. Carr attempts to support this conclusion by stating that:
- I. Jeffrey Epstein engaged in commercial sex with girls under the age of 18; and
- 2. Jeffrey Epstein used fraud, force, and/or coercion to induce girls and young women to perform commercial sex acts.215
Ms. Carr's first basis of support for Opinion D is founded in the unsubstantiated notion that commercial sex with girls with minors was de facto considered trafficking in 2008, which is not accurate, as discussed in Supra Section V. As referenced by Ms. Carr, the distinction between the "prostitution" of minors, sex trafficking, and sexual abuse was not reconciled until a year after the JPMC Defendants chose to end their business relationship with Mr. Epstein. Specifically, Ms. Can• writes:
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." This law was repealed in 2014 by Fla. NB 989, which was "an act relating to human trafficking. "216
Regardless, and even assuming Ms. Can is correct in her interpretation of the statute, the point is moot, considering this change did not occur until after the end of the JPMC business relationship with Epstein. Moreover, as previously stated, the present allegations should not be evaluated through the lens of hindsight bias.
While Ms. Can presently claims that Epstein's guilty plea to "Procuring a Person under 18 for Prostitution" in 2008 satisfies the definition of sex trafficking under the TVPA (i.e., solicits commercial sex with a person under the age of 18), she is mistaken, especially considering the prevailing interpretation of the law prior to 2014. In 2014, even officers of the court who portrayed themselves as anti-trafficking advocates, such as former California Attorney General and current Vice Present Kamala Harris, did not interpret the TVPA to mean that minors
215 Carr Report Pages 14 and 17.
216 Carr Report, ¶ 50.
involved in the commercial sex industry are de facto victims of sex trafficking.217 Even as recent as 2020, children are still being arrested and charged for trafficking crimes, which further undermines the reliability of Ms. Can's interpretation. However, this is a common misconception made by persons without an in-depth and specialized expertise in the field, which explains why 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 is a criminal act under the TVPA.218
Ms. Can's second basis of support for Opinion D is founded in nothing more than a credibility determination.2 I9 Instead of citing to any reliable literature or comparable cases, Ms. Can spends nearly ten pages of her report restating allegations made by various alleged victims (some of whom are accused by others as co-conspiratorsno) . Interestingly, Ms. Can omits the fact that Mr. Epstein's co-conspirator, Ghislaine Maxwell. was convicted of one substantive count of sex trafficking related to one individual , not the others referenced in this section , Carr's report.' For example, Ms. Carr provides a statement from as an example of how she claims Jeffrey Epstein used "force, fraud, and/or coercion to induce girls and young women to perform commercial sex acts."222 Specifically, Ms. Carr writes:
said, "When 1 was recruited by Ghislaine Maxwell at Mar-a-Lago, just before I was 17, 1 thought I was given a big break, and I'd be able to reset my life and become an actual real massage therapist. My hopes were quickly dashed, and my dreams were stolen. " 223
However, Ghislaine Maxwell was not indicted or convicted for trafficking a fact Ms. Can wholly ignores. Additionally, Ms. Carr completely fails to provide any discussion on the criminological trend of compensated trafficking victims being conceptualized and prosecuted as co-conspirators in criminal court.
Instead of relying upon evidence-based information, Ms. Can's opinions appear to be severely skewed by confirmation bias. For exam le in Ms. Can's "conversation" (not a qualitative or "trauma informed" interview) with (a woman who was previously accused by law enforcement of being a co-conspirator), Ms. Can incredulously claims (without citation) that "many of the women to whom Epstein made payments have Eastern European surnames,
217 See, for example, In re Aarica S., 223 Cal. App. 4th 1480 (Cal. Ct. App. 2014).
21\$ Cam Report, 1 52, citing Stephen Cutler Dep. (May 24, 2023) at 21:12-20; 90:7-93:4.
219 See, for exam le Cam R rt 56.
22° For example,
221One of the five counts of which the jury convicted Ghislaine Maxwell was count six, see Transcript of Record at 3176:5, United States v. Maxwell, 20-cr-00330-AJN (S.D.N.Y. Dec. 29, 2021), i.e., sex trafficking of an individual under the age of 18 ("M only"). Verdict Sheet at 2, Uniiiiries v. Maxwell, 20-cr-00330-AJN (S.D.N.Y. Dec. 19, 2021 E F N . . The witness who testified as ' in United States v. Maxwell later selfidentified as See Briquelet, Kate, Ghislaine Maxwell Sentenced to 20 Years For Sex Trafficking Girls to Jeffrey Epstein (June 28, 2022), Daily Beast. Retrieved from: https://www.thedailybeast.cornighislainemaxwell-jeffrey-epsteins-socialite-girlfriend-tumed-sex-trafficker-sentenced4o-20-years).
7-22 Cam Report,1 57b.
223 Carr Report, ¶ 57b.
suggesting they may also be immigrants." Ms. Carr then goes on to say it is "well known" that "Eastern Europe is a source country for human trafficking victims." 224 The indications of bias in Ms. Carr's quantum leaps of logic include, but are not limited to:
- I. Making the speculative assumption of what constitutes an "Eastern European" surname;
- 2. Making the speculative assumption that a person with a purported "Eastern European" surname is an immigrant;
- 3. Making the erroneous assertion that Eastern Europe is a major source country for human trafficking victims in the United States; and
- 4. Suggesting that JPMorgan knew that Eastern Europe is a source country for human trafficking victims and somehow could have intervened on the basis of these assumptions.
In an attempt to support these erroneous assumptions, Ms. Can cites to the 2009 Trafficking in Persons Report, published by the U.S. Department of State. I found this interesting, considering that there was not a country narrative on the United States in this report in 2009.225 A country narrative on the United States was not added to the Trafficking in Persons (TIP) Report until 2010. /f Ms. Carr had read the 2010 TIP Report's country profile on the United States, she would know that there is no mention of "Eastern Europe" being a source country to America.226 Instead, the 2010 TIP report found that primary countries of origin for foreign victims certified by the U.S. government were "Thailand, Mexico, Philippines, Haiti, India, Guatemala, and the Dominican Republic."
With that being said, although there was no United States specific information in the 2009, it should be noted that JPMC nevertheless accurately cited the document for the general information it provides, such as definitions and trafficking typologies.227
Ultimately, Ms. Carr goes on to make numerous conclusory statements based on nothing more credibility determinations, confirmation bias, and unsupported speculation or subjective belief (for example, see Table 14).
Table 14. Summary of CIIIT'S Opinions, Basis, and Countervailing Information
| Carr's Statement | Basis | Sample of Countervailing Information228 |
|---|---|---|
| Peastin or others acting under his direction recruited economically | Statements from Jane Doe 5, [REDACTED] "a Jane Doe," "another | Ms. Carr omits the fact that: 1. [REDACTED] is accused by [REDACTED] of being a co-conspirator. 2. [REDACTED] was accused of being a co-conspirator by law enforcement. |
224 Carr Report,1 58.
222 Trafficking in Persons Report U.S. Dep't of State (2009), https://2009-
2017.state.gov/j/tip/rIshiprpt/2009/index.htm.
226 Trafficking in Persons Report U.S. Dep't of State (2010), https://2009-
2017.state.gov/j/tip/rls/tiprpt/2010/142761.htm.
227 IPM-SDNYLIT-00174047
23 Additional examples can be provided during deposition and/or in a supplement.
| Carr's Statement | Basis | Sample of Countervailing Information228 |
|---|---|---|
| vulnerable girls and young women for commercial sex under the false pretense of receiving payment for providing a massage. | Jane Doe, M.J., Jane Doe 2, and [REDACTED] |
Ms. Carr relies on nothing more than a credibility assessment of the alleged victims. |
| 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. | Statements from [REDACTED], C.D., "A Jane Doe", and M.J. |
Ms. Carr omits the fact that:
Again here, Ms. Carr relies on nothing more than a credibility assessment of the alleged victims. |
| In some cases, Epstein would coerce young girls and women into commercial sex by making them believe he cared about them. | Statements from [REDACTED], C.D., T.D., and [REDACTED]. |
Ms. Carr omits the fact that:
Again here, Ms. Carr relies on nothing more than a credibility assessment of the alleged victims. |
| Epstein coerced his victims into commercial sex by establishing control over their lives and emotionally manipulating them. | Statements from [REDACTED], and [REDACTED] |
Ms. Carr omits the fact that:
|
229 See Supra Section II.
230 Id.
| Carr's Statement | Basis | Sample of Countervailing Information228 |
|---|---|---|
| effectuate them, and would solicit praise after their completion.231 Again here, Ms. Carr relies on nothing more than a credibility assessment of the alleged victims. |
||
| Epstein coerced his victims into commercial sex by confiscating their passports | Statements from [REDACTED]232 | Ms. Carr omits the fact that: 1. [REDACTED] is accused by [REDACTED] of being a co-conspirator. 2. Ms. Carr ignores countervailing evidence to the statements. For example, that [REDACTED] repeatedly asked to visit Epstein and that she used her identification documents to travel on other occasions.233 3. This claim is not corroborated by others. Again here, Ms. Carr relies on nothing more than a credibility assessment of a small segment of alleged victims. |
| Payment of cash and other types of financial support for sexual acts is consistent with the definition of inducing a commercial sex act under the TVPA. | Statements from alleged victims that: 1. Epstein said the more "you do the more you are paid". 2. They were paid \$200-\$300 dollars for a single massage session. 3. Epstein paid for [REDACTED]'s rent, dance classes, haircuts, which she was expected to repay. 4. [REDACTED] was told that she had the option to be paid \$100 to give Epstein a massage with |
First, and most importantly, Ms. Carr's erroneous interpretation of the TVPA demonstrably conflates purported indicia of sex trafficking with possible indicia of commercial sex. Specifically, it is a known fact that payment for commercial sex is correlated with the type of sexual services provided. As a result, some consenting sex workers may consent to sexual activities that they would otherwise decline solely on the basis of payment.234 Second, Ms. Carr cites to absolutely no reliable cases, research, or evidence to suggest that these payments are consistent with trafficking. In fact, the absence of payments or lower payments are typical of potential trafficking, especially in the erotic massage industry. Unlike trafficking victims, these individuals were compensated consistent with the amount that was promised (e.g., \$200-\$300 dollars for a single massage session). Moreover, I am not aware of any trafficking case where a victim was compensated with over \$1,000 for a single trip, much less over \$10,000, as evidenced in the present matter. However, it should be noted that recently some courts have started to expand the traditional interpretation of trafficking law with trafficking cases involving some payment to minor victims235, but that is still atypical of most trafficking claims and arguably inconsistent with the congressional intent for the TVPA. More importantly, that was not the understanding during the alleged victimization period in the present matter. Third, Ms. Carr's citation of [REDACTED] constant borrowing is inconsistent with the facts in evidence. Epstein paid for [REDACTED] rent, dance classes, haircuts, because she repeatedly asked him to.236 She was expected to repay, because she affirmatively |
231 ESTATE\_JPM005030; ESTATE\_JPM005031; ESTATE\_JPM005032
"'Cart Report.1 63.
233 ESTATE\_JPM 005212; ESTATE\_JPM004928-4934; ESTATE\_JPM004935-4937; ESTATE\_JPM 004788.
234 See, for example, the trial transcript of United States v. Mei Xing, No. 2:20-CR-0228(A)-FMO (C.D. Cal.).
276 For example, see United States v. Anton Lanaro hnpsilAvviw.justice.goviusao-mn/nressrelease/file/1424071 /download.
216 For examples, see ESTATE\_JPM005389, "I wanted to know if it would be ok to get a LIRR Card for the next two wIcs...1 don't have enough to get there."
| Carr's Statement | Basis | Sample of Countervailing Information228 |
|---|---|---|
| her clothes on or \$300 to give a massage with her clothes off. 5. After Epstein had sex with [REDACTED] and her sister [REDACTED] on a trip to the U.S. Virgin Island, Epstein sent them a \$11,000 wire payment. |
chose to borrow the money.237 This is not consistent with victims of trafficking, who are forced under threat or coercion to repay debts that they did not agree to or were deceived about. |
ESTATE\_JPM005422, "my roommate is losing her un employment and now she has to charge 900 for my room...I wanted to know if you can pay 300 just til I'm done with school.";
ESTATE\_JPM005251, [REDACTED] is wondering if she could pick up \$100 tomorrow to hold her spot for school.";
ESTATE\_JPM005290, [REDACTED] ...is asking if it would be ok to pick up money for books...Ok for her to pick up \$500 (more? Less?)";
ESTATE\_JPM005380, [REDACTED] just texted me you said it was okay for me to buy her point shoes...I know we spent close to \$500 with [REDACTED] do the same for [REDACTED]?"
ESTATE\_JPM005336, [REDACTED] would like to stop by and pu (sic) some money today. Pls advise how much to give."
ESTATE\_JPM005353, [REDACTED] is asking if she could purchase a dance card."
ESTATE\_JPM005356, [REDACTED] ...is wondering if she could pick up some money for (shiatsu and Thai massage as part of her midterm project."
ESTATE\_JPM005103, [REDACTED] is asking if she could possibly pick up her final tuition check for \$7072. She is on her way to pick up her money for the island now."
ESTATE\_JPM005104, [REDACTED] is asking if you could help pay for her last semester. She needs 2 check to take the NYS license exam."
237 For examples, see ESTATE\_JPM005198, "I wanted to as a favor. I have to pay 600 a month which I can afford, but I don't have 1st and last months rent to get started...If I could borrow it I can pay you back when I start the job.... Love and miss you, [REDACTED]";
ESTATE\_JPM005218, "I have no way to pay my phone bill and its going on being 2 months late :( would it be all right if I borrowed some money to pay it till I find a job?";
ESTATE\_JPM005327, [REDACTED] texted me...She did not make enough money to pay all her bills...she is hoping she can borrow \$600";
ESTATE\_JPM005339, [REDACTED] is wondering if she could borrow money to pay her phone bill. She is behind 2 months and they are going to shut off if she doesn't pay...Her bill is \$272.";
ESTATE\_JPM005344, [REDACTED] is asking if she can borrow some money.";
ESTATE\_JPM005363, [REDACTED] ...cannot pay the first and last months rent...she is wondering if she could borrow \$1200 and once she gets her ballet check, she can pay you back.";
ESTATE\_JPM005111, "Would it be possible to borrow money? I don't have Enough (sic) saved til my first pay check in 2 weeks."; and
ESTATE\_JPM005168, I don't have money for rent either. Can I borrow from you?".
Similarly, [REDACTED] would also repeatedly ask for money. For example, ESTATE\_JPM005319 and
ESTATE\_JPM016929.
Carr Opinion E: JPMorgan's Due Diligence Indicates Epstein Was Involved In Sex Trafficking.
Ultimately, a bulkm of Ms. Carr's report is spent discussing her subjective interpretation of various emails, transactions, Due Diligence Reports (DDR), and Rapid Response Team (RRT) meetings without any reliable basis in state of the science research or even citations to authoritative/reliable/academic sources. As discussed previously, much of her interpretation is more likely than not skewed by hindsight bias and confirmation bias. For example, the incredulous and baseless claim that "models is (sic) a red flag of trafficking"239 has absolutely no reliable or objective support and "modeling" as a purported indicator of trafficking would have low rates of sensitivity and specificity if used in any intervention protocol.
For all of the reasons mentioned through this report, JPMorgan's due diligence files regarding Epstein do not contain any reliable "red flags" for sex trafficking. While I will not belabor this point by discussing the lack of empirical basis for each of Ms. Car's curated citations, I am prepared to elaborate, if needed, at deposition with additional exam les e.g., the Vanity Fair Article contains no reliable red flags of trafficking. In fact, and accuse the publication of deliberately omitting information that would have further exposed Epstein's history of sexual abuse).
However, of most importance for the rebuttal of the reports issued by the Plaintiff's named experts, I would like to reiterate the following:
- I. The cash transactions evidenced in Epstein's accounts are not reliable indicators of commercial sex or human trafficking and were reported in accordance with legal requirements; yet, prompted no additional oversight by law enforcement;
- 2. While the opening of accounts by third parties can be considered a red flag of trafficking under certain circumstances, this was not included in best practice resources for financial institutions until after the alleged victimization period in the present matter (2014 and later). Moreover, given the totality of the circumstances surrounding these two counts, the activity was atypical of trafficking (e.g., demonstrably exercised agency and dominion over her account);
- 3. Epstein's indictment in 2006 is not an "extremely strong" or "conclusive" indication of "sex trafficking," especially during the alleged victimization period in the present matter;
- 4. A media report of a trafficking investigation, which yields no indictment is not tantamount to actual or constructive knowledge of trafficking;240
238 Can. Report, Page 27 to 47.
239Carr Report, 1 70.
140 Especially given the long history of false allegations regarding human trafficking in the United States and abroad—a fact that Ms. Carr wholly ignores. These false claims date back to 1885 with the Maiden Tribute of Modern Babylon expose being based on a fabricated account of alleged sex trafficking (see, for example, Soderlund, Gretchen. Sex trafficking, scandal, and the transformation ofjournalism, 1885-1917. University of Chicago Press, 2013). Despite this known issue specifically affecting the fidelity of trafficking allegations, Ms. Carr erroneously claims that an allegation in and of itself is a "glaring red flag" for human trafficking (see Carr Report, page 40, paragraph 122).
- 5. The internal discussions among JPMC employees about Epstein are not reliably indicative of a "sex trafficking venture"; and
- 6. Private air travel is not an evidence-based indicum of sex trafficking.
Not only does Ms. Carr erroneously rely on purported "indicia" that are without any reliable empirical basis, but she claims that these speculative indicators are "significant." Statistical significance is a determination made by an analyst to assess whether results in the data are explainable by chance alone. Ms. Carr provides absolutely no citation to support her claims of significance and available information can be used to hypothesize that the purported "indicia" or "red flags" discussed in her report would, more likely than not, have low rates of sensitivity and specificity. Ms. Cart's opinions on the significance of these indicia or "red flags" appear to be rooted in nothing more than her subjective interpretation, which seems heavily influenced by confirmation bias and hindsight bias. For example, throughout her report Ms. Carr refers to as an "employee" and "co-conspirator" for serving as a paid recruiter for Epstein. Yet Ms. Cart fails to acknowledge, much less explain, why other paid recruiters, such as and others are conceptualized as victims. Perhaps this is because conceptualizing these women as victims better fits the Plaintiffs theory of the case.
For example, I was literally named as a co-conspirator in Epstein's non-7rosecution agreement; yet, Ms. Carr accepts that she was a "sex slave"" because that is how now self-identifies. Ms. Can completely ignores countervailing evidence and testimony, which suggests that may have been a consenting participant. For example, I communications with Epstein are inconsistent with what would be expected from a "sex slave."'
Ms. Can relies heavily on her "experiences" and appears to ignore countervailing fact and empirical evidence. For example, Ms. Can claims that the term "sugar daddy" is a "red flag" for commercial sex acts and, depending on the context" for human trafficking,243 without any citation. If Ms. Cart had even done a cursory review on the history and/or research behind the use of the term, she would know that her interpretation is not consistent with the origin of the term or the current use, given the anti- trafficking interventions and anti- commercial sex interventions that are customarily employed on "sugar dating" platforms. Archetypal "sugar dating" relationships involve a May—December romance with an older male who expresses romantic attachment through gift giving and physical touch and a younger, adult female who expresses romantic attachment through quality time and physical touch. Instead, Ms. Can cites to a blog post, which states that "A sugar baby is a person who receives cash, gifts or other financial and material benefits in exchange for company. It can include sex or intimacy, but it doesn't have to." While the article recognizes that "sugaring can and does involve sex
241 Carr Report, 1 107.
See. e.g., ESTATE JPM005234, where writes, "Please remember you offered to do this last night so don't tell me I forced you into doing something you detest. I don't think I was forceful at all."
24) Carr Report, ¶ 125
244 Meeghan Sheppard, Exposing the Exploitative Realities ofSugar Dating, Human Trafficking
trafficking and prostituted people" like any other form of dating, Ms. Carr somehow misinterprets this finding to support her erroneous opinion that a mention of the term "sugar daddy" is a red flag for commercial sex acts.
Yet, despite the lack of reliable evidence of trafficking, JPMC continued to monitor Epstein's accounts and cash usage closely245 and reported suspicious activity in compliance with the law and industry standards/best practices that were available at the time. Nevertheless, Ms. Can erroneously describes JPMC responses to the allegations against Epstein as being illustrative of "belated conclusions." This is especially counterfactual considering that JPMC's proactive exiting of Epstein was six years before any law enforcement indictment for trafficking, and his indictment concerned pre-2006 conduct.
To this effect, with regards to the remaining opinions, I proffer the following:
- I. JPMorgan's due diligence reports provide no reliable indicia to conclude that Epstein was involved in sex trafficking (Carr Opinion F);
- 2. Jeffrey Epstein's JPMorgan accounts illustrate no reliable indicia of sex trafficking (Carr Opinion G), for example:
- a. There is no reliable evidence or indicia to suggest that large cash withdrawals are a reliable indicum of sex trafficking;
- b. Them is no reliable evidence or indicia to suggest that round-dollar wire payments area reliable indicum of sex trafficking;
- c. In the absence of an individualized inquiry with alleged survivors, there is no method to objectively and reliably determine which individuals were paid for the facilitation of Epstein's alleged victimization;
- d. There is no reliable evidence or indicia to suggest that private air travel is a reliable indicum of sex trafficking; and
- e. There is no reliable evidence or indicia to suggest that relationships with established modeling firms are a reliable indicum of sex trafficking;
- 3. There is no reliable evidence or indicia to suggest that Epstein relied on his relationship with JPMC facilitate sex trafficking (Carr Opinion H); and
- 4. There is no reliable evidence or indicia to suggest JPMC had a unique opportunity to intervene and help Epstein's alleged victims, especially who was previously identified as a co-conspirator by law enforcement (Carr Opinion I).
Ultimately, the present matter should not be assessed or evaluated through the lenses of confirmation bias or hindsight bias. In accordance with best practices associated with sentinel events, JPMC will continue to ensure that the bank's policies, procedures, and internal controls to prevent and detect trafficking remain consistent and evolving with industry standards. (Carr Opinion K).
Search (2020), https://humantraffickingsearch.org/resource/exposing-the-exploitative-realitiesofsugar-datingt
245 JPM-SDNYLIT-00036575 as cited in Carr Report, Page 43.
XI. SECONDARY EXPLOITATION
Opinion
Secondary exploitation is the act of making use of or benefiting from a human trafficking survivor's victimization or the human trafficking phenomenon. Co-conspirators falsely claiming to be victims of trafficking for benefit can be considered a form of secondary exploitation. Similarly, uninjured third parties attempting to financially gain from the victimization of others can be considered a form of secondary exploitation.
Basis
Given the increased international attention on human trafficking, more service providers, practitioners, and politicians are becoming involved in the movement for modem-day abolitionism. However, the incentive for assisting victims of human trafficking is not always entirely altruistic. Qualitative data suggests that there are an increasing number of third parties who are secondarily exploiting human trafficking survivors, persons erroneously identified as victims, and the topic of human trafficking in general.
Secondary exploitation can take many forms. Generally, it can be defined as the act of making use of or benefiting from a human trafficking survivor's victimization or the human trafficking phenomenon.' For example, a human trafficking survivor could be exploited by a third party who wants to tell the victim's story in order to draw attention to themselves or their organization.' Politicians also use human trafficking and/or the stories of victimizations to help themselves get elected.208 Other types of possible secondary exploitation can include, but are not limited to:
- I. Non-trafficked persons who falsely claim to be trafficked due to the associated benefit (e.g., evasion of criminalization, obtaining a T-Visa, or financial benefit through civil litigation);
246 Mehlman-Orozco, Kimberly. (2017). Hidden in Plain Sight America's Slaves of the New Millennium. Praeger.
247 For example, see Cojocaru, C., My Experience is Mine to Tell: Challenging the abolitionist victimhood framework, Anti-Trafficking Review, issue 7, 12-38 (2016); Gregoriou, C., & Ras, I. A., Representations of Transnational Human Trafficking: A Critical Review, in Representations of Transnational Human Trafficking: Present-Day News Media, True Crime, and Fiction, 1, 3-4, 17 (2018); and Bernstein, E., & Shih, E., The Erotics of Authenticity: Sex Trafficking and "Reality Tourism" in Thailand, Social Politics: International Studies in Gender, State and Society, 1, 11-15 (Fall 2014).
248Kimberly Mehlman-Orozco, In Virginia race, human trafficking must be more than a talking point, The (Nov. 5, 2017 10:20 AM), litto://thehill.com/oninionkammign/358814-in-virginia-race-human-trafficking-must-bemore-than-a-talking-point.
- 2. Attorneys who repackage the victimizations of non-trafficked persons as trafficking in order to exploit the litigation advantages a TVPRA claim affords (e.g., longer statutes of limitations, evasion of intentional tort exclusions and caps on punitive damages);249
- 3. Attorneys who use the victimizations of trafficked persons to sue unwitting third parties due to the higher prospect of recovering damages (e.g., financial benefit through lawsuits); and
- 4. Third parties who blame unwitting third parties for self-interested benefit (e.g., attention or financial gain).
Human traffickers should undoubtedly be held criminally and civilly accountable for their crimes and human trafficking survivors should be provided with services and protected from revictimization and erroneous criminalization. However, the prospect and trends related to secondary exploitation should be acknowledged and assessed by any trier of fact involved with evaluating the credibility of a TVPA claim, especially when made against a third party. Efforts to hold third parties liable, despite no substantive and/or direct involvement with the crime, are at risk of secondarily exploiting the victims and/or secondarily exploiting the topic of trafficking by proffering non-victims as trafficking survivors or blaming unwitting third parties for failed interventions by law enforcement.
As an expert witness, it is not my role to proffer a legal conclusion on whether secondary exploitation is evident in the present matter. However, triers of fact in TVPA cases should undoubtedly be made aware of this phenomenon, as done in other trials.2" This is especially true for the present matter considering:
- I. The present claim is unprecedented, given that it was made by a third party against a third party;
- 2. Epstein survivor has publicly made accusations that are consistent with secondary exploitation a ainst attorne s Brad and Stan Pottin er• and
- 3. Epstein survivors have publicly accused others who purport to be Epstein survivors of actually being coconspirators.
149 For example, see Julie Dahlstrom. Trafficking to the Rescue?, 54 UC L. Rev. I, 24-28, 35.38 (2020) and McNeil, Maggie. 2017. Retrieved from the Honest Courtesan Blog. httos:llmaegiemcneill.com/20I7/03/18/in-thenews-722/. Regarding the latter reference, Ms. McNeill is a retired consenting sex worker who runs a well-known blog about the commercial sex industry entitled The Honest Courtesan. Ms. McNeill also perceives some of the third-party liability litigation as secondarily exploitative. Specifically, Ms. McNeill writes that certain cases constitute attempts to "rob" businesses by using "'sex trafficking' hysteria as a weapon."
2" For example, see the trial transcript of United States v. Mei Xing, No. 2:20-CR-0228(A)-FMO (C.D. Cal.).
XII. CONCLUSION
Through my education, experience, and research, I have developed a robust, reliable, and evidence-based understanding of human trafficking, methods of recruitment and control utilized by human traffickers, characteristics of victims, distinction between sex trafficking and prostitution, and the typologies of commercial sex consumers, as well as the evolution and efficacy of anti-trafficking interventions. I have trained law enforcement on my findings and have been retained on many cases involving Trafficking Victims Protection Act (TVPA) claims, with a particular familiarity with allegations against third parties. Additionally, unlike the Plaintiff's named experts, the reliability of my testimony has been vetted in courtrooms across the United States.
As previously discussed, although Epstein's crimes are atypical of human trafficking, it is undeniable that Epstein was a sexual predator, who engaged in illicit behavior to the physical and emotional detriment of an unknown number of women and children. If law enforcement had intervened when they were first contacted by Epstein's victims, it is more likely than not that many of Epstein's crimes could have been prevented. Even so, JPMC decided to end its business relationship with Epstein six years before Epstein was charged with sex trafficking.
Hindsight bias should not color the interpretation of the facts that were available to JPMC during the alleged victimization period. Using an objective assessment regarding the knowledge that was available to law enforcement and the private sector at the time, JPMC's policies, procedures, and internal controls to prevent and detect trafficking were consistent with industry standards. Moreover, there are no facts in evidence to suggest that Epstein's crimes would have been prevented if his business relationship with JPMC ended sooner. Additionally, there are no facts in evidence to suggest that Epstein's crimes would have been prevented if JPMC [REDACTED]
In the absence of an overt disclosure, sex trafficking is a clandestine crime and as a result victims can be difficult to identify and are frequently misidentified, even by trained law enforcement, social workers, and healthcare providers. The allegations regarding Epstein's sexual victimizations in particular were atypical of sex trafficking and therefore, to a reasonable degree of social scientific certainty, these victimizations were more difficult to detect by third parties in the absence of law enforcement intervention. This is especially the case in the private sector, considering that indicia of "sex trafficking" in the banking industry have not been adequately evaluated for sensitivity or specificity. Moreover, regarding the present matter, the purported "best practice" indicia of sex trafficking for the financial services industry are overwhelmingly inconsistent with the allegations in this case.
Ultimately, claims of alleged sex trafficking, especially those made by third parties against third parties, are at high risk of secondary exploitation. Secondary exploitation is also of particular concern in the present matter given the allegations by Epstein's victims against others who purport to be victims, but are accused of being co-conspirators. Given the information that I have reviewed
in preparation for this report, I have concluded that it is of the utmost importance for the trier of fact in the present matter to be empowered with evidence based and reliable data, while shielded from misinformation, unsupported speculation or subjective belief, or ecological fallacies and fallacies of composition.
APPENDIX A. Curriculum Vitae
DR. KIMBERLY B. MEHLMAN-OROZCO
(703) 362-9405 •ww mthlminortstro rom
EDUCATION
Doctor of Philosophy Criminology, Law and Society
Mason University
Dissertation: The "Crimmigration" Affect An Analysis of 287(g) and Latino/a Representation in the U.S. Juvenile Justice System
Expertise: Human Trafficking, Human Smuggling, Immigration, Survey Methods and Systematic Review
of Arts ustice Iaw, and Crime Policy
Mason University
Thesis: Foreign Nationals and Crime: An Exploratory Analysis of Undocumented Migrants in Northern Virginia
Bachelor of Science
Cita Lark
TEACHING F.xPF.ittENC.F
Surviving and Thriving Beyond Sex Trafficking SP18
Administration of Justice
Mason University
Ph.D. Research Course Sustainability Education Prescott College
CRIM307 Social Inequality, Crime, and Justice FA17
Criminology. Law and Society Mason University
CftIM405 Law and Justice Around the World SP17, SP18
Criminology, Law and Society Mason University
CRIM308 Human Rights and Justice FA16
Criminology, Law and Society Mason University
CCJS100 Intro to Criminal Justice FA12-SPI4
Department of Criminology & Criminal Justice University of Maryland College Park
CCJS370 Race and Crime FA12-SPI4
Department of Criminology & Criminal Justice University of Maryland College Park
CCJS432 Law of Corrections FA12
Department of Criminology & Criminal Justice University of Maryland College Park
CCIS418J Foreign Nationals and Crime FA12-SP13
Department of Criminology & Criminal Justice University of Maryland College Park
CRIM490 Foreign Nationals and Crime SU09, SUIO, Suit, SUI2
Criminology, Law and Society Mason University
GED, Work Place Essential Skills, and Adult Basic Education SUOSSU06
Adult Detention Center Prince William County
RESEARCH EXPERIENCE
CEO
Executive Director
EA19— Present Break the Chain
WI l8— Present Freedom Light
Partner/Human Trafficking Expert Witness FA16—WI18
Mahn, Mehlman & Associates
Human Trafficking Subject Matter Expert SUI6-FAIT
RAND Corporation
Executive Director/Human Trafficking Consultant WI12— FA16
The Justitia Institute
Director
Research Associate
Lead Clinical Trials Search Coordinator
Senior Research Associate
FAIO — WI12 Latino Policy Institute Roger University
SW 1 — WI12 Cochrane Collaboration College for Policy Mason University
SUIO — WI12 Justice Health Field The Cochrane Collaboration
SUO8 — SU I OIIDP Census of Juveniles on Probation Mason University
Graduate Research Assistant SD I° — FA10
Violence and Victimization Research Division
National Institute of justice (On Contract) Office of Justice Programs
Senior Fellow
Graduate Research Assistant
Graduate Research Assistant
SUO8 — FAIO The Lloyd Society
SUO6 — SUO8 & Tobago Crime Reduction Project Mason University
VII107-SP07, SPO8 Vaccines for Children Project Mason University
PUBLICATIONS
Lowery-Keith, Jennifer and Kimberly Mehlman-Orozco (2022). Justice Denied': A Sex Trafficking Survivor Tells Her Story. The Crime Report.
Mehlman-Orozco, Kimberly B and Greg Bristol. (2021). Suing Social Media Sites Won't Curb Sex Trafficking: Advocates. The Crime Report.
Mehlman-Orozco, Kimberly B and Marisa A. Trasatti. (2021). "Does 'Nirvana' Lawsuit Undermine Struggle Against Trafficking?" The Crime Report.
Mehlman-Orozco, Kimberly B and Marisa A. Trasatti. (2021). "Britney Spears, human trafficking and the law." New York Daily News.
Mehlman-Orozco, Kimberly B. (2021). 'The gRaciafization' of Sex Trafficking in America." The Crime Report.
Mehlman-Orozco, Kimberly B. (2021). "COVID-19, the Commercial Sex Industry• and Sex Trafficking." The Crime Report.
Nlehlman-Orozco, Kimberly B. (2019). "Jeffrey Epstein's deal with Alexander Acosta wasn't out of line with what I have seen." USA Today.
Mehlman-Orozco, Kimberly B. and Sheriff William D. =. (2019). "Robert Kraft spa scandal: Sex trafficking is hard to prove, that doesn't mean it's a lie." USA Today.
Mehlman-Orozco, Kimberly B. and William D. =. (2019). "Legalizing prostitution could end sextrafficking investigations." The M.
Mehlman-Orozco, Kimberly B. (2019). "How to Fight Sex Trafficking." Politico.
Mehlman-Orozco, Kimberly B. (2019). The Jihadi Next Door: I low ISIS is Forcing. Defrauding. and Coercing Your Neighbor into Terrorism. SkyHorst.
Mehlman-Orozco, Kimberly B. (2018). "Sex trafficking bill likely to do more harm than good." The Baltimore Sun.
MeltBrian-Orozco, Kimberly B. (2018). "\Vhy cracking down on websites won't stop online sex trafficking." Thomson Reuters Foundation.
Mehlman-Orozco, Kimberly B. (2018). "Legislation Aiming to Stop Sex Trafficking Would Hun Investigations." Homeland Searritt
Mehlman-Orozco, Kimberly B. (2017). "Trafficking victims get lost under unjust criminal convictions." Thee
Mehlman-Orozco, Kimberly B. (2017). "Projected Heroes and Self-Perceived Manipulators: Understanding the Duplicitous Identities of Human Traffickers." Trends in Organized Crime.
Mehlman-Orozco, Kimberly B. (2017). I liddcn in Plain Sight: America's Slaves of the New Millennium. ABC-CLIO/Praeger.
Mehlrnan-Orozco, Kimberly. (2017). "Why we should question the FBI's recent human trafficking sting." Thomson Realm.
Mehlman-Orozco, Kimberly. (2017). "Decriminalize sex work to bring trafficking victims out of the shadows." The
Mehlman-Orozco, Kimberly. (2017). "Decriminalizing sex work would help bring victims out of the shadows." The rashington Post.
Mehlman-Orozco, Kimberly B. (2017). 'Why the Stop Enabling Sex Traffickers Act is the Wrong Solution." The Crime Report
Mehlman-Orozco, Kimberly B. (2017). "Identifying Victims of Human Trafficking." Dimensions of Dental Hygiene.
Syme, Sheryl, Camardese, Susan, and Kimberly Mehlman-Orozco. (2017). "Human Trafficking: Red Flags for Dental Professionals." Decisions in Dentistry.
Mehlman-Orozco, Kimberly B. (2017). "Vilifying Backpage.com won't help fight sex trafficking" The Ireabington Post.
Mehlman-Orozco, Kimberly B. (2017). "Child Trafficking: The Tragedy of `Princess"' The Crime Report.
Mehlman-Orozco, Kimberly B. (2017). "To sue or not to sue third-party businesses for sex trafficking?" Thomson Reuters Foundation.
Mehlman-Orozco, Kimberly B. (2017). "Hunting the Internet's Sex Predators." The Crime Report.
Mehlman-Orozco, Kimberly B. (2017). "Will shutting down Backpage.com end the scourge of child sex trafficking in America?" Thomson Renters Foundation.
Mchhnan-Orozco, Kimberly B. (2017). "Sex Trafficking: A Surprising Rescue Story." The Crime Report.
Mehhnan-Orozco, Kimberly B. (2017). "What every parent should know about sex trafficking."
Baltimore Sun.
Mehlman-Orozco, Kimberly B. and Hcdlin. (2017). "Mehlman-Orozco, Medlin: Stop criminalizing victims of sex trafficking." Tin Hairston Chronicle.
Mehlman-Orozco, Kimberly B. (2017). "Why Do We Criminalize Young Victims of Sex Trafficking?" The Crime Report.
Mehlman-Orozco, Kimberly B. (2016). "The Plight of Sex-Trafficking Survivors." The Gay and Lesbian Review Worldwide.
Mehlman-Orozco, Kimberly B. (2016). "Sex Trafficking is often hidden in plain sight." Thee
Mehlman-Orozco, Kimberly B. (2016). "Will Legalized Prostitution End the Sex Trafficking Scourge?" Tbe Fluffing/on Post.
Mehlman-Orozco, Kimberly B. (2016). "What happens after a human trafficking victim is rescued?" 'Met
Mehlman-Orozco, Kimberly B. (2016). "The Reality of Sex Trafficking in Washington's Red Light District." Baltimore Sun.
Mehlman-Orozco, Kimberly B. (2016). "America's Symbolic, Not Effective, Anti-Trafficking Policy. Diplomatic Courier.
Mehlman-Orozco, Kimberly B. (2016). America's Anti-Trafficking Efforts: Hollow victories for public accolade. Connection Newspaper. Chantilly, Centerville, Great Falls, Herndon, McLean, & Vienna.
Mehlman-Orozco, Kimberly B. (2016). "Sex Slaves or Prostitutes?: How Human Trafficking is Hidden in Plain Sight in America's Capital." Diplomatic Courier.
Mehhnan-Orozco, Kimberly B. (2015). "Safe Harbor Legislation for Juvenile Victims of Sex Trafficking: A Myopic View of Improvements in Practice. Soda! Inclusion.
Mehlman-Orozco, Kimberly B. (2015). "Tor and the Bitcoin: An Exploration into Law Enforcement Surveillance Capability Online". Diplomatic Courier.
Mehlman-Orozco, Kimberly B. (2014). "Human Trafficking in the Philippines: A Blemish on Economic Growth". Diplomatic Courier, Reanry in the Philippines.
Mehlman-Orozco, Kimberly B. (2014). "Devoid of Research: An Evaluation of Human Trafficking Interventions". Diplomatic Courier, Special issue: Breaking the Cycle of Human Trafficking
, Ramiro, and Mehlman-Orozco, Kimberly B. (2014). "Hispanic Immigration and Crime". Oxford Handbook of Ethnicity. Crime. and Immigration. Eds. Michael Toney and Sandra Bucerius. Oxford University Press.
Mehlman-Orozco, Kimberly B. (Contributing Author) (2010) "Breaking It Down: Justice, Law & Society Abstracts for Policy-makers and Practitioners". CenterforJustice Law and .codep..
RlaN)RTS
Mehlman-Orozco, Kimberly B. cv-5263.VHC. Mehlman-Orozco, Kimberly B 1:21-cv-04278-WMR. Mehlman-Orozco, Kimberly B. TWT. Mchlman-Orozco, Kimberly B. (2022). N.Z. v. Red Roof Inn, et. al. Civil Action Number 02642. Mehlman-Orozco, Kimberly B. (2022). G.D. v. Red Roof Inn, et. al. Civil Action Number 02631. Mehlman-Orozco, Kimberly B. (2022). Jane Doe v. Fairfax County Police. 1:21cv1150(AJT/JFA). Mehlman-Orozco, Kimberly B. (2022). S.Y. v. Inn of Naples Hotel LLC and Inn of Naples, LLC. Case No.: 2:20-cv-00609-JES Mehlman-Orozco, Kimberly B. (2022). S.Y. v. Naples Hotel Company and the Gulfcoast Inn of Naples Owners Association, Inc. 2:20-ev-00608 Mehlman-Orozco, Kimberly B. (2022). C.S. v. Inn of Naples Hotel, LLC and Inn of Naples, LLC 2:20 cv- 00629 Mehlrnan-Orozco, Kimberly B. (2022). C.S. v. Naples Hotel Company and the Gulfcoast Inn of Naples Owners Association, Inc. 2:20-cv-00631 Mchlman-Orozco, Kimberly B. (2022). The People of the State of California v. Rachele Eschenburg. Case Number: FCR350232 Mehbnan-Orozco, Kimberly B. (2022). People of the State of California v. Diane Mirabal. Superior Court of the State of California for the County of Santa Clara. Case No.: 98312 Mehlman-Orozco, Kimberly B. (2022). Casilao et. al. v. Hotelmacher LLC, et. al. Case No.: CI V-17-800- SIP (2022). W.K. et. al., v. Red Roof Inn, et. al. Civil Action Number 1:20- . (2022). Jane Does 1-4. v. Red Roof Inn, et. al. Civil Action Number (2022). J.A.. v. Red Roof Inn, et. al. Civil Action Number 1:21-cv-03655- Mehlman-Orozco, Kimberly B. (2022). Jane Doe v. TRX Insurance Services, Inc and Richard Metz. United States District Court for the Eastern District of Pennsylvania. Civil Action No. 2:20-cv-04095-MMB Mehlman-Orozco, Kimberly B. (2021). Expert Witness Report. Heidi Gilbert, AmberMeans, Mandy Me/con, Gabriekaloslin, and. Poe, it U.S.A Taeknondo, Inc., District of Colorado. 1: 18-cv-00981-CMA-NIEH Mehlman-Orozco, Kimberly B. (2020). Expert Witness Report. M.B. it Rooseirlt Inn, LLC, et al. Mehlman-Orozco, Kimberly B. (2017). Expert Witness Report. Keo Ratha et. al. v. Phatthana Seafood Co., et. al. Case No. 16-2-28453-1 KNT.
Mchlman-Orozco, Kimberly B. (2017). Expert Witness Report. State of P. Michael Moine. CR 16-3191.
Mehlman-Orozco, Kimberly B. (2011). The Effects of In-State Tuition for Non-Citizens: A Systematic Review of the Evidence. Latino Polio. Institute at Roger bttp://www.nvu.eduidepository/Ipi/lpi-reportiprif
Mehlman-Orozco, Kimberly B. (2008). Race and Reporting Burglary, Robbery•, and Assault in Trinidad and Tobago. (Completed under a grant from the Trinidad and Tobago Government).
ARI Y PRFSI:NTATIONS
Mehlman-Orozco, Kimberly B. and Greg H. Bristol. (Forthcoming, April 2023). Lies, Damn Lies, and Human Trafficking Statistics: The Truth Behind America's Failing War Against Modern Slavery. IAPSC Annual Conference.
Trasatti, Marisa and Mehlman-Orozco, Kimberly B. (2022). Hotel Industry and Human Trafficking. South Carolina Bar Convention.
Trasatti, Marisa and Mehlman-Orozco, Kimberly B. (2021). Human Trafficking Is Growing Exponentially: What your Corporation and Clients Need to Know about the Evolving Litigation Landscape. Lawyers for Civil Justice Conference.
Trasatti, Marisa, Mehlman-Orozco, Kimberly B., Harvey, Brittany. (2021). Human Trafficking The Silent Risk. RIMS Annual Conference.
Trasatti, Marisa, Mehlman-Orozco, Kimberly B., Yesowitch, Irene, Vomdran, Maryann, and M, Graham. (2020). Training to Combat Human Trafficking at Your Commercial Premise. Cyber, Management & Professional liability Conference.
Trasatti, Marisa, Mehlman-Orozco, Kimberly B., Clark, Fran, et. al. (2020). Training to Combat Human Trafficking at your Commercial Premise— Learn the Emerging Risks, Litigation Issues and Preventative Measures. Claims and litigation Management Alliance Conference.
Trasatti, Marisa, Mehlman-Orozco, Kimberly B., Ewing, Lance. (2020). Human Trafficking: The Silent Risk. Claims and Litigation Management Alliance Conference.
Mehlman-Orozco, Kimberly B. (2019). Keynote Speaker: National Capital Region Threat Intelligence Consortium (NTIC) Human Trafficking Seminar.
Mehlman-Orozco, Kimberly B. (2019). Law Enforcement's Role in Combating Human Trafficking and Assisting Victims. Police Executive Research Forum (PERT).
Mehlman-Orozco, Kimberly B. and Marisa Trasatti (2019). Human Trafficking The Silent Risk. The RIMS (Risk Management Society) Conference.
Mehlman-Orozco, Kimberly B. (2019). Social Policy and Justice Panelist. Harvard College Project of
Asian and International Relations. Harvard University.
Mehlman-Orozco, Kimberly B. (2018). Women in Homeland Security Human Trafficking Symposium Panelist. Marymount University. Mehlman-Orozco, Kimberly B. (2017). Human Trafficking Symposium Panelist. Liberty University School of Law. Favian, Mehlman-Orozco, Kimberly, and Wooditch, Alese. (2014). Mexican Migration to the United States: An Exploratory Study into Illegal Border Crossings. Academy of Criminal Justice Sciences. Philadelphia, PA Mehlman-Orozco, Kimberly B. (2010). "Justice Health Systematic Review Mcthods," Presented at the annual colloquium of the Cochrane and Collaborations: Keystone, CO. Mehlman-Orozco, Kimberly B. (2010). "Open Access Systematic Reviews for Juvenile Probation Information," Presented at the first annual OJJDP Probation Summit Washington, D.C. Mehlman-Orozco, Kimberly B., Chirieleison, J., Sebold, C. M., Douds, A., Gallagher, A.M., and Gallagher, C.A. (2010). "Characteristics of Juveniles on Probation: Collecting Data from Atlantic to Pacific". Presented at the 2010 American Probation and Parole Association Conference: Washington, D.C. Mehlman-Orozco, Kimberly B. (2010). "Justice Health Search Methods: PubMed and More," Presented at the International Network for Justice Health Meeting. Scottsdale, AZ. Gallagher, C.A., Douds, A.S., Mehlman-Orozco, Kimberly B., Chiricicison, J., and Olaghere, A. (2010). "Justice Health Bibliographic Data 'gapping," Presented at the International Network for Justice Health Meeting. Scottsdale, AZ. Mehlman-Orozco, Kimberly B. (2010). "Smuggling and the Likelihood of Detention among Undocumented Migrants," Law and Society Association Conference: Chicago, IL-Douds, Anne S. and Mehlman-Orozco, Kimberly B. (2010). "FASD in justice Facilities: What dots the research tell us?", Meeting of the Interagency Coordinating Committee on Fetal Alcohol Spectrum Disorders: Rockville, MD. Gallagher, Catherine, Taxman, Faye, Kinner, Stuart, MI, Jodie, Pardo-Rengifo, Monica, Mehlman-Orozco, Kimberly B., Olaghere, Ajima, Boyle, Nick, Gabriel Cuervo, Luis. (2009). "Knowledge mapping for research prioritization: examples from the Network for Justice Health". 17th Cochrane Colloquium, Singapore. Mehlman-Orozco, Kimberly B. (2009). "Justice Health Systematic Review Mcthods," Presented at the International Network for Justice Health Meeting. Orlando, FL. Mehlman-Orozco, Kimberly B. (2008). "Foreign Nationals and Crime: An Exploratory Analysis of Undocumented Migrants in Northern Virginia," American Society of Criminology Conference: St. Louis, MO.
OTHFR PRI:.SENTATION5
Mehlman-Orozco, Kimberly B. (2018). Invited Trainer on Human Trafficking Provided to the Advancing the Business of Healthcare Medical Coding Chapter in Woodbridge, Virginia (2 CEUs). Mehlman-Orozco, Kimberly B. (2018). Invited Trainer on Human Trafficking for the Canadian Police College Human Trafficking Investigator's Course, Canadian Mounted Police and Halifax Regional Police, Canada. Mehlman-Orozco, Kimberly B. (2018). Invited Annual Speaker for the College of Humanities and Social Sciences Degree Celebration, Mason University. Mehltnan-Orozco, Kimberly B. (2018). Invited Presenter for the Well Library Honors Event, Mason University. Mehlman-Orozco, Kimberly B. (2017). Invited Training Presentation on Human Trafficking Red Flags for Prevent Abuse and Neglect through Dental Awareness (P.A.N.D.A). Mehlman-Orozco, Kimberly B. (2017). Invited Guest S for Human Trafficking Awareness Event with Kappa Delta Phi International Sorority, Mason University. Mehlman-Orozco, Kimberly B. (2017). Invited Guest Speaker at the Mother's Union International Conference Human Trafficking Forum. Mchlman-Orozco, Kimberly B. (2017). Invited Guest Speaker at the Keeping Our Youth Safe Conference. Bernadette's House. Mehlman-Orozco, Kimberly B. (2016). Invited Guest Speaker for Girls at High-Risk of Sex Trafficking. Manassas City Police Department. Mehlman-Orozco, Kimberly B. (2016). Invited Guest Speaker on Human Trafficking. Woodbridge Woman's Club. Mehlman-Orozco, Kimberly B. (2016). Invited Guest Speaker for TEAM Summer Quest: High-Risk Youth Diversion Program. Manassas City Police Department. Mehlman-Orozco, Kimberly B. (2016). Invited Guest Speaker on Human Trafficking. Soroptimist International, Alexandria Chapter. Mehlman-Orozco, Kimberly B. (2016). Invited Guest Speaker on Human Trafficking. Republican Women of Clifton. Mehlman-Orozco, Kimberly B. (2016). Invited Guest Speaker on Human Trafficking in Northern Virginia. Westminster at Lake Ridge. Mehlman-Orozco, Kimberly B. (2016). Keynote Speaker. Soroptimist Human Trafficking Awareness Event. Mehlman-Orozco, Kimberly B. (2015). Invited Guest Speaker on Human Trafficking. Trinity Episcopal Church.
Mchlman-Orozco, Kimberly B. (2015). Invited Guest Speaker for TEAM Summer Quest: High-Risk Youth Diversion Program. Manassas City Police Department.
Mehlman-Orozco, Kimberly B. (2014). Invited Guest Speaker for TEAM Summer Quest: High-Risk Youth Diversion Program. Manassas City Police Department.
Mehlman-Orozco, Kimberly B. (2014). Invited Guest Speaker on Mapping Suspected Human Trafficking Networks through Advertisements. Homeland Security Investigations, DHS, Buffalo, NY.
Mehlman-Orozco, Kimberly B. (2013). Exhibitor. Governor's Summit on Human Trafficking. Richmond, VA.
Mehlman-Orozco, Kimberly B. (2013). Invited Guest Speaker on Labor Trafficking. St. Francis of Assisi Catholic Church.
Mehlman-Orozco, Kimberly B. (2011). Keynote Speaker. First Annual Quetzal Award Gala. Guatemalan Center of New England.
EXPERT WITNE-SS CASES—CONSULTATION AND/OR TESTIMONY
| Forthcoming | Woodhull Freedom Foundation et al. v. United States. |
|---|---|
| 2023 | People of the State of California v. Angelina Avila Case No. |
| 2023 | M.H. v. G6 Hospitality LLC, et. al. United States District Court |
| 2023 | United States of America v. Kamal Bhula, et al. United States |
| 2023 | United States of America v. Mei Xing, United States District Court |
| 2023 | Jane Doc v. Fairfax County Police. 1:21cv1150(AJT/JFA). |
| 2022 | Charity Pearrow v. ESA P Portfolio LLC, et. al. 21-cv-62276- |
| 2022 | KR. v. 4200 Roosevelt LLC, et. at Case Number 00552 |
| 2022 | C.A. v. 4200 Roosevelt LLC, et. at Case Number 03355 |
| 2022 | B.H. v. 4200 Roosevelt LLC, et. al. Case Number 03356 |
| 2022 | K.C. v. 4200 Roosevelt LLC, et. al. Case Number 01926 |
2022 T.E. v. 4200 Roosevelt LLC, et. al. Case Number 00994 2022 V.S. v. 4200 Roosevelt LLC, et. al. Case Number 00997 2022 Sherman, Gozun, and Nash v. Trinity Teen Solutions, Inc. Case Number 20-CV-215-SWS 2022 N.Z. v. Knights of Trevose, et. al. Civil Action Number 02642 2022 G.D. v. Knights of Trevose, et. al. Civil Action Number 02631 2022 Jane Doc 1-4 v. Red Roof Inns, Inc., et. al. Civil Action Number 1:21-cv-04278-WMR 2022 W.K., et. al. v. Red Roof Inns, Inc., et. al. Civil Action Number 1:20-cv-5263-VHC 2022 J.A. v. Red Roof Inns, Inc., et. al. Civil Action Number 1:21-cv-03655-TWT 2022 Casilao et. al. v. Hotelmacher LLC, et. al. Case No.: CIV-17-800- SLP 2022 S.Y. v. Inn of Naples Hotel LLC and Inn of Naples, LLC. Case No.: 2:20-cv-00609-JES 2022 S.Y. v. Naples Hotel Company and the Gulfcoast Inn of Naples Owners Association, Inc. 2:20<v-00608 2022 C.S. v. Inn of Naples Hotel, LLC and Inn of Naples, LLC 2:20-cv-00629 2022 C.S. v. Naples Hotel Company and the Gulfcoast Inn of Naples Owners Association, Inc. 2:20-cv-00631 2022 People of the State of California v. Diane Mirabal. Superior Court of the State of California for the County of Santa Clara. Case No.: 98312 2021-2022 MADELYN CASILAO, HARRY LINCUNA, and ALLAN on behalf of themselves and all others similarly situated, Plaintiffs, v. HOTELMACHER LLC, dba HOLIDAY INN EXPRESS; STEAKMACHER, LLC, dba MONTANA MIKE'S STEAKHOUSE; SCHUMACHER INVESTMENTS, LLC, dba WATER ZOO; APEX USA, INC.; WALTER SCHUMACHER; and CAROLYN SCHUMACHER, Defendants. UNITED STATES DISTRICT COURT WESTERN DISTRICT OF OKLAHOMA Case No.: CIV-17-800-SLP
2021-2022 Jane Doc v. TRX Insurance Services, Inc and Richard Metz. United States District Court for the Eastern District of Pennsylvania. Civil Action No. 2:20-cv-04095-MMB
2021-2022 The People of the State of California v. Rachele Eschenburg. Case Number. FCR350232
2021 Heidi Gilbert, Amber Means, Mandy Mcloon, Gabriela Joslin, and Poe, v. U.S.A Taekwondo, Inc., District of Colorado
2019.2021 United States v. Matthew , United States District of New Mexico
2019 United States v. Adonis Baker, United States District of New Mexico
2019 United States v. Cornelius Galloway, United States District of New Mexico
2018 RCMP Federal Serious and Organized Crime R vs. Downey & Beals C/O Human Trafficking 2016-465660, Halifax, Canada
2018 United States of America vs. Savanah April Via, U.S. District Court for the District of Arizona
2018 Commonwealth of Virginia v. Corey Cardoza, Henrico County
2018 People v. Karcem Abdur-Razzaaq, Ind. No. 3154/2013, and People v. Lemuel Skipper, Ind. No. 2409/2015, Bronx County
2017-2020 United States of America v. Miguel Scott Arnold, Terrence Hawkins, Tcvin Bynoe, Emonic M, and Joshua Guity-Nunez, United States District Court for the Middle District of Pennsylvania.
2017- 2018 Doe v. Subh Properties, et al., Civil Litigation, State of Maryland
2017-2018 State of Ohio v. Michael Moore, Lucas County Court
2017-2018 People of the State of California Plaintiff v. Tracy Sims Superior Court of California, County of Los Angeles
2017 Kco Ratha; Sem Kosal; Sophea Bun; Yem Ban; Nakry Phan; and Sok Sang v. Phatthana Seafood Co., Ltd; S.S. Frozen Food Co., Ltd.; Doe Corporations 1-5; Rubicon Resources, LLC; and Wales & Co. Universe, Ltd. United States District Court for the Central District of California
2017 In re: REFLEX MEDIA, INC., a Nevada corporation, Claimant, vs. VIBE MEDIA, INC. d/b/a CitvVibc.com, a California corporation; SOPHIA THOMPSON, an individual; PEAKRIDGE d/b/a SugarModels.com, an Anguilla compas S y DANIEL ROMAN a/k/a Daniel Romanesse, an individual; ASKARI, an individual; and DOES 1 through 10, inclusive 2016-2017 J.S., S.L., and L.C. v. Village Voice Media Holdings LLC, Supreme Court of the State of Washington 2016-2017 People of the State of California Plaintiff v. James =, et. Al. Contra Costa County Court 2016 People of the State of California Plaintiff v. Young Kyung Cho Superior Court of California, County of Los Angeles 2016 People of the State of California Plaintiff v. Mixon-Givens Santa Clara County Court
SELECTION OF MEDIA
April 6, 2023 January 10, 2023 September 1, 2022 July 31, 2022 July 22, 2022 December 16, 2021 April 24, 2021 April 10, 2021 April 4, 2021 July 4, 2020 Forbes. Sex Traffickers Used America's Favorite Family Safety App To Control Victims. Forbes. U.S. News & World Report. Jury Hears Case Alleging 4 Cops Enabled Prostitution Ring. Court TV. Only Fans Model Murder Case. CGTN. Kimberly Mehlman-Orozco on the role of internet in human trafficking. Court TV. Crystal Kizer. Sex Trafficking Murder Case. NPR. The Facts Of, The Myths About, And The Solutions For Child Trafficking. CBS News. Manhattan District Attorney's office to stop prosecuting prostitution cases. Fox News. Human smugglers using social media to transport migrants to US: Reports. Forbes. Inside the \$4.5 Billion Erotic Massage Parlor Economy. CBS News. Epstein's alleged accomplice Ghislainc Maxwell sot to be arraigned next week.
January 23, 2020 Stift. Opening Closed Doors: Can Hotels Do More to Fight Human Trafficking? August 9, 2019 ABC. This Week with Stephanopoulos. Panel discussion on Jeffrey Epstein. July 9, 2019 CBS News. Sex trafficking expert discusses Jeffrey Epstein case and sexual abuse. May 10, 2019 Hollywood Reporter. Sex Trafficking mars the Mystique of Cannes Film Festival. April 12, 2019 The M. Expert says it's 'very unlikely' Robert Kraft prostitution case would yield human trafficking convictions. March 21, 2019 CBS. Robert Kraft solicitation charge puts spotlight on sex trafficking. March 4, 2019 The Washington Post. Surveillance cameras, suitcases and billionaires: How an investigation into massage parlors unfolded in Florida. March 1, 2019 USA Today. From harmful fetishes to sex trafficking, Robert Kraft case highlights risks facing Asian women. February 24, 2019 CNN. Robert Kraft allegations: A sex trafficking expert weighs in. January 11, 2019 August 22, 2018 May 5, 2018 May 1, 2018 April 24, 2018 April 23, 2018 April 22, 2018 April 13, 2018 The Seattle Times. Documentary puts new attention on R. Kelly sex allegations. The Crime Report. Backpage Founders: We're Victims of Attack on Free Speech. Delaware Online. Human Trafficking Court shut down, to be merged with other treatment courts in Delaware. Delaware Online. Despite good intentions, Delaware slow to address human trafficking. ABC. Will new law protect women from sex trafficking? The Ringer. How Sex Ads Became a Battleground for the Future of the Internet. Miami Herald. He pimped a minor at Santa's Enchanted Forest. He got slapped with federal prison. Yahoo Lifestyle. Women's March lambasted for criticizing
shutdown of Backpage.com.
April 10, 2018
April 9, 2018
March 22, 2018
March 2, 2018
February 1, 2018
February I, 2018
January 31, 2018
January 25, 2018
January 23, 2018
January 11, 2018
January 8, 2018
December 21, 2017
December 12, 2017
November 4, 2017
September 22, 2017
August 8, 2017
August 2, 2017
Miami Herald. Florida's sex industry In a panic' after feds shut down notorious Backpage websitc.
The Crime Report. With Backpage Closed, Where Will The Sex Slave Trade Go?
Washington Post. Bill enabling prosecutors, victims to pursue websites that host sex traffickers heads to House.
Governing. 3 Cities Lead Fight Against Human Trafficking.
Vanity Fair. The Republican Party is Having Another Todd Akin Fiasco.
New York Magazine. Missouri GOP Senate Hopeful Goes Off the Deep End on the Sexual Revolution and Human Trafficking.
Kansas City Star. Josh Hawley blames sex trafficking on `sexual revolution' of 1960s in leaked audio.
Homeland Security Today. Expert Delves Into Real Face of Human Trafficking Victims and Perpetrators.
Huffington Post. Study Finds More Than 9,000 Brothels Masquerading As Legit Businesses.
International Business Times. Human trafficking. Why we arc all guilty of supporting the modern slave trade.
Majority Report Radio. America's Slaves of the New Millennium with Dr. Kimberly Mehlman-Orozco.
Fast Company. Hotels Are Key In The Fight To End Human Trafficking.
WNPR. The Colin McEnroe Show. Child Labor In America And Abroad.
C-SPAN. Hidden in Plain Sight Book Talk.
Gray Media. Interview by Kyle Midura. Sex Trafficking Internet Crackdown Proposal.
i24 news. Interview for Stateside with David Shuster. Model allegedly kidnapped for dark web auction.
Newsy. Interview for "The Why" on human trafficking on the
Internet.
July 30, 2017 Al janCra. Segment Produced by Ruairi M. World Day Against Human Trafficking.
July 25, 2017 Fox News Radio. Interviewed by Eben M. "Security America" segment on human smuggling deaths in San Antonio.
July 25, 2017 Dallas News. Interviewed by Sarah Mervosh. New trick of the sex trade: Pimps can use retail gift cards to buy Backpage.com ads.
July 24, 2017 WJLA. Interviewed by Stephen Loiaconi. Human smuggling deaths underscore need for immigration reform, experts say.
July 18, 2017 The Washington Post. Interviewed by Tom Jackman. Under attack, Backpage.com has its supporters as anti-trafficking tool. But many differ.
June 11, 2017 PJ Media. Interviewed by Karl Herchenroeder. Expert Notes Gap in Human-Trafficking Laws as Senators Press for Fund Renewal.
April 19, 2017 WYPR. Interviewed by Tom ■ Misinformation Sparked #DCMissingGirls Outrage, But It Highlights Real And Overlooked Issues.
March 30, 2017 CBS. Interviewed by Jennifer Earl. Mom's warning about "human trafficking" at IKEA goes viral; what you need to know.
March 29, 2017 Women's Health. Interviewed by Korin M. This Mom Claims She Encountered Human Traffickers At IKEA And People Are Freaking Out.
February 10, 2017 Miami Herald. Interviewed by David Ovalle. Florida lawsuit targets website decried as hub for human trafficking.
February 3, 2017 Miami Herald. Interviewed by David Ovalle. The 'adult' section might be closed but Miami sex workers still on the job.
January 1, 2017 OutSmart Magazine. Interviewed by Dr. Laura McGuire on Human Trafficking. Hidden in Plain Sight: Researcher Dr. Mehlman-Orozco Discusses the Realities of Human Trafficking.
February 3, 2015 NBC. Interviewed by Tracy . Shoe Bomber has 'Tactical Regrets' Over Failed American Airlines Plot.
January 19, 2015 CNN. Interviewed by Pam Jihad Jane' moved by 'love' and feminine 'pride.'
August 15, 2013 USA Today, Interviewed by Yamichc Alcindor. Dozens of States Pass Laws to Fight Human Trafficking.
June 6, 2013 USA Today. Interviewed by Yamiche Alcindor. Blue Campaign by DHS aims to combat human trafficking.
August 12, 2012 Fox 5 News (DC/MD/VA). Television interview on in-state tuition report on Maryland. Interview by reporter Shawn Yancy.
May 18, 2011 Chronicle of Higher Education. Interviewed for an in-state tuition story by Katherine Mangan, "In-State Tuition for Illegal Immigrants Can Be a Plus for Both States and Students."
March 24, 2011 NBC 10 (RI). Television interview on Latino population growth, "Digging Deeper: Hispanics on the Rise."
February 18, 2011 The Yale Herald. Interviewed for a story on racial profiling against immigrants by police. Story by Lucas Iberico-Lozada, "East Haven Police Accused of Brutality, Racism."
June 2, 2010 Style Weekly. Interviewed for a human trafficking story by Peter Galuszka, "The New Slavery: Virginia becomes haven for human trafficking."
OTHFR PROFESSIONAL. TR AININfl
Intelligence Community Conference
Summer 2021 Conference
Transportation Industry Against Human Trafficking
Fall 2020 Presentation
"Freedom Together" D.C., M.D., and V.A. Regional And Human Trafficking Task Force Conference
Spring 2018 Conference
Virginia Forum on Human Trafficking
Fall 2015 Conference
Regional Conference of Human Trafficking Task Forces
Fall 2015 Conference
Maryland Freedom Conference
Winter 2015 Conference
Sharing Lessons, Sharing Responsibility: Combating Human Trafficking
Spring 2013 Conference
Freedom Network Annual Conference
Spring 2013 Conference
Traffik Analysis Hub
U.S. Department of Commerce
D.C., M.D., and V.A. Task Forces
Dept. of Criminal Justice Services
DMV Anti-Trafficking Working Group
Towson University
Migration Policy Institute
Freedom Network
Human Trafficking Panel Discussion
Spring 2013 Working Group
Analytic Statistics and Meta Analysis
Spring 2011 Paid Training
Systematic Review and Meta Analysis
Spring 2009, Fall 2010 Independent Graduate Study
PubMed, NLMGateway, ToxNet and ClinicalTrials.gov
Summer 2009 Search Certifications
Ovid, ProQuest, and Web searches
Summer 2009 Search Certifications
Introduction to ArcGIS Workshops
Fall 2009-Summer 2010
Hand Searching Systematic Review Workshop
Fall 2009 Search Certifications
Ism ARDS
Independent Publisher Anal 2019
Independent Publisher Amami, 2018
Dissertation Completion AIM724 2012
Deans Challenge Award, 2009
SER1ICE
Peer Reviewer
Panel of Expert Witnesses
Reviewer
Invited Peer Reviewer
Advisory Board Member
Volunteer
Advisory Board Member
Washington Law
States
GMU
National Library of Medicine
AHRQ
Mason University
Cochrane Collaboration
Silver Medal for Current Events Oihadi Next Door).
Bronze Medal for Social Issues/Humanitarian (Hidden in Plain
Mason University, College of Humanities and Social Sciences.
Mason University, College of Humanities and Social Sciences.
Office of Justice Programs (OJP), 2020-Present
Los Angeles Superior Court, WI2017-Present
Journal of Human Trafficking, FA2014-Present
Office of Justice Programs, SP2020-Present
Empower Her Network, FA2017- Present
Prince William County Police Santa Cops, W12021
Dressember (Anti-trafficking foundation), SP2017-SU2021
Reviewer Reviewer Survey Methodologist Advisor Member Member Member and Former President Reviewer Member Reviewer President and Founding Officer Member Volunteer Taylor & Francis Books, SP2021 Justice Quarterly, WI2018- FA2019 United Against Slavery, FA2017-FA2019 Prince William County Human Trafficking Task Force, SU2013- SU2018 Prince County Human Trafficking Task Force, SU2012- SU2014 Soropiimist International of Woodbridge, FA2015-5P2018 American Journal of Evaluation, FA2014-FA2015 Prince County Human Trafficking Task Force, 5U2013- 2015 Columbia University Press, FA2013 Student Center for Immigration Research, University, FA2008 — FA2010 Mason Criminology, Law & Society Student Association, Mason University, FA2009 — W12012 Prince William County Jail, Classification Department, 500 hours, SP 2005
PROFESSIONAL MEMBERSHIP
National Society for Collegiate Scholars Phi-Alpha Delta Pre-Law Fraternity• Alpha Chi Honors Fraternity American Society of Criminology National Criminal Justice Honors Fraternity Alpha Phi Sigma Honors Society•
APPENDIX B. Expert Witness Testimony
I have testified and/or issued a report in the following cases, but have been retained in many others:
Criminal Prosecution
United States of America v. ICamal Bhula, et al. United States District Court, For the District of New Mexico. Case No. I :19-cr-01631-DFRJ
People of the State of California Plaintiff v. Mixon-Givens Santa Clara County Court
People of the State of California Plaintiff v. =, et. Al. Contra Costa County Court (Case No: 5-160639-1)25'
People v. Kareem Abdur-Razzaaq, Ind. No. 3154/2013, Bronx County252
People v. Lemuel Skipper, Ind. No. 2409/2015, Bronx County253
Commonwealth of Virginia v. Corey Cardoza, Henrico County2541
United States v. Cornelius Galloway, United States District of New Mexico255
State of Ohio v. Michael Moore, Lucas County Court (Case No. CR 16-3191)
Criminal Defense
United States of America v. Mei Xing, United States District Court for the Central District of California. No. 2:20-CR-0228(A)-FMO
People of the State of California v. Angelina Avila, Superior Court of the State of California, in and for the County of Los Angeles (Case No. BA508653-02)
United States of America v. Emonie M, U.S. District Court for the Middle District of Pennsylvania
251 Testified at grand jury on 4/13/2016 and at trial on 7/12/2017. Prosecutor's name is Aron DeFerrari: ADeFerrari@contracostada.org.
232 Testified at Frye motion for another expert witness on behalf of the prosecution.
253 Testified at Frye motion for another expert witness on behalf of the prosecution.
254 Testified at Daubert hearing and prevailed as an admitted expert. Case settled before trial.
255 Testified at Daubert hearing and prevailed as admitted expert.
People of the State of California Plaintiff v. Young Kyung Cho Superior Court of California, County of Los Angeles (Case No: 6CJ10198-01)256
United States of America v. Landrum et. Al. Via. U.S. District Court for the District of Arizona (Case No. 4:16-cr-01560-RM-JR)
The People of the State of California v. Rachele Eschenburg. Case Number: FCR350232
People of the State of California v. Diane Mirabal. Superior Court of the State of California for the County of Santa Clara. Case No.: 98312252
Civil Defense
M.H. v. G6 Hospitality LLC, et. al. 4:22-cv-198
Charity Pearrow v. ESA P Portfolio LLC, et. al. 21-cv-62276-BLOOMfValle
K.R. v. 4200 Roosevelt LLC, et. al. Case Number 00552
C.A. v. 4200 Roosevelt LLC, et. al. Case Number 03355
B.H. v. 4200 Roosevelt LLC, et. al. Case Number 03356
K.C. v. 4200 Roosevelt LLC, et. al. Case Number 01926
T.E. v. 4200 Roosevelt LLC, et. al. Case Number 00994
V.S. v. 4200 Roosevelt LLC, et. al. Case Number 00997
Sherman, Gown, and Nash v. Trinity Teen Solutions, Inc. Case Number 20-CV-215-SWS
N.Z. v. Knights of Trevose, et. al. Civil Action Number 02642
G.D. v. Knights of Trevose, et. al. Civil Action Number 02631
Jane Doe 1-4 v. Red Roof Inns, Inc., et. al. Civil Action Number 1:21-cv-04278-WMR
W.K., et. al. v. Red Roof Inns, Inc., et. al. Civil Action Number 1:20-cv-5263-VHC
J.A. v. Red Roof Inns, Inc., et. al. Civil Action Number 1:21-cv-03655-TWT
Casilao et. al. v. Hotelmacher LLC, et. al. Case No.: CIV-17-800-SLP
256 Testified in trial on 11/7/2016 and 12/2/2017.
257 Declaration only, not report.
S.Y. v. Inn of Naples Hotel LLC and Inn of Naples, LLC. Case No.: 2:20-cv-00609-JES
S.Y. v. Naples Hotel Company and the Gulfcoast Inn of Naples Owners Association, Inc. 2:20 cv-00608
C.S. v. Inn of Naples Hotel, LLC and Inn of Naples, LLC 2:20-cv-00629
C.S. v. Naples Hotel Company and the Gulfcoast Inn of Naples Owners Association, Inc. 2:20 cv-0063 I
M.B. v. Roosevelt Inn LLC (MARCH TERM, 2017 NO.: 00712)
Keo Ratha; Sem Kosal; Sophea Bun; Yem Ban; Nakry Phan; and Sok Sang v. Phatthana Seafood Co., Ltd; S.S. Frozen Food Co., Ltd.; Doe Corporations 1-5; Rubicon Resources, LLC; and Wales & Co. Universe, Ltd. United States District Court for the Central District of California.258
Jane Doe v. TRX Insurance Services, Inc and Richard Metz. United States District Court for the Eastern District of Pennsylvania. Civil Action No. 2:20-cv-04095-MMB
Heidi Gilbert, Amber Means Mandy Meloon, Gabriela Joslin, and Poe, v. U.S.A Taekwondo, Inc. and Steven =. United States District Court for the District of Colorado. Civil Action No. 1: 18-cv-00981-CMA-MEH
Civil Plaintiff
Woodhull Freedom Foundation et al. v. United States259
Jane Doe v. Fairfax County Police 1:21cv1150(AJT/JFA)26°
258 Also deposed in this case. Dismissed on summary judgement.
2" Not an expert witness report, but rather a declaration: https://www.eff.org/document/declaration-draimberlyrnehlman-oromo-suoport-woodhull-et-al-motion-prelitninarv-iujunction
m° Pro Bono case, which has received national media attention. See, for example: https://www.newsweek.comivirginia-cops-protected-sex-trafficking-ring-retum-free-sex-victims-lawsuit-1661937
APPENDIX C. Materials Reviewed and Considered
In addition to the materials specifically cited or mentioned in my report, I considered the following documents in forming my opinions:
| Document Type | Description |
|---|---|
| Produced Document | CU\_0001 |
| Produced Document | CU\_0003 |
| Produced Document | CU\_0005 |
| Produced Document | CU 0007 |
| Produced Document | CU\_0008 |
| Produced Document | CU\_0009 |
| Produced Document | CU 0013 |
| Produced Document | CU\_0015 |
| Produced Document | CU 0019 |
| Produced Document | CU 0020 |
| Produced Document | CU\_0022 |
| Produced Document | CU 0023 |
| Produced Document | CU 0024 |
| Produced Document | CU\_0025 |
| Produced Document | CU 0027 |
| Produced Document | CU 0028 |
| Produced Document | CU\_0032 |
| Produced Document | CU 0033 |
| Produced Document | CU 0035 |
| Produced Document | CU\_0036 |
| Produced Document | CU\_0037 |
| Produced Document | CU 0038 |
| Produced Document | CU\_0039 |
| Produced Document | CU\_0044 |
| Produced Document | CU 0045 |
| Produced Document | CU\_0046 |
| Produced Document | CU\_0047 |
| Produced Document | CU 0049 |
| Produced Document | CU\_0051 |
| Produced Document | CU\_0052 |
| Produced Document | CU 0053 |
| Produced Document | CU\_0055 |
| Produced Document | CU 0058 |
| Produced Document | CU 0060 |
| Produced Document | CU\_0064 |
| Produced Document | CU 0064 |
| Produced Document | CU 0065 |
| Produced Document | CU\_0066 |
| Document Type | Description |
|---|---|
| Produced Document | CU 0072 |
| Produced Document | CU\_0080 |
| Produced Document | CU\_0082 |
| Produced Document | CU 0083 |
| Produced Document | CU\_0089 |
| Produced Document | CU\_0091 |
| Produced Document | CU 0093 |
| Produced Document | CU 0097 |
| Produced Document | CU\_0100 |
| Produced Document | CU 0103 |
| Produced Document | CU 0105 |
| Produced Document | CU\_0108 |
| Produced Document | CU 0111 |
| Produced Document | CU 0113 |
| Produced Document | CU 0116 |
| Produced Document | CU 0122 |
| Produced Document | CU\_0125 |
| Produced Document | CU 0127 |
| Produced Document | CU 0131 |
| Produced Document | CU\_0141 |
| Produced Document | CU 0153 |
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| Document Type | Description |
|---|---|
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| Produced Document | ESTATE JPM018143 |
| Produced Document | ESTATE JPM018144 |
| Produced Document | ESTATE JPM018145 |
| Produced Document | ESTATE JPM018146 |
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| Produced Document | ESTATE JPM018150 |
| Produced Document | ESTATE JPM018151 |
| Produced Document | ESTATE JPM018152 |
| Produced Document | ESTATE\_WM018153 |
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| Produced Document | ESTATE JPM018156 |
| Produced Document | ESTATE \_JPM018157 |
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| Produced Document | ESTATE JPM018160 |
| Produced Document | ESTATE JPM018161 |
| Produced Document | ESTATE \_JPM018162 |
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| Produced Document | ESTATE JPM018165 |
| Produced Document | ESTATE JPM018166 |
| Produced Document | ESTATE JPM018167 |
| Produced Document | ESTATE \_JPM018168 |
| Produced Document | ESTATE JPM018169 |
| Produced Document | ESTATE JPM018170 |
| Produced Document | ESTATE \_JPM018171 |
| Produced Document | ESTATE JPM018172 |
| Produced Document | ESTATE JPM018173 |
| Produced Document | ESTATE JPM018174 |
| Document Type | Description |
|---|---|
| Produced Document | ESTATE JPM0I8 I 75 |
| Produced Document | ESTATE JPM018176 |
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| Produced Document | ESTATE JPM018179 |
| Produced Document | ESTATE JPM018180 |
| Produced Document | ESTATE JPM018181 |
| Produced Document | ESTATE \_JPM018182 |
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| Produced Document | ESTATE JPM018184 |
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| Produced Document | ESTATE JPM018186 |
| Produced Document | ESTATE JPM0I8 I 87 |
| Produced Document | ESTATE JPM018188 |
| Produced Document | ESTATE JPM018189 |
| Produced Document | ESTATE JPM018190 |
| Produced Document | ESTATE JPM018191 |
| Produced Document | ESTATE JPM018192 |
| Produced Document | ESTATE JPM018193 |
| Produced Document | ESTATE JPM018194 |
| Produced Document | ESTATE JPM018195 |
| Produced Document | ESTATE JPM018196 |
| Produced Document | ESTATE \_JPM018197 |
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| Produced Document | ESTATE JPM018204 |
| Produced Document | ESTATE JPM018205 |
| Produced Document | ESTATE \_JPM018206 |
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| Produced Document | ESTATE \_JPM018212 |
| Produced Document | ESTATE JPM018213 |
| Produced Document | ESTATE JPM018214 |
| Produced Document | ESTATE \_JPM018215 |
| Produced Document | ESTATE JPM018216 |
| Produced Document | ESTATE JPM018217 |
| Produced Document | ESTATE \_JPM018218 |
| Document Type | Description |
|---|---|
| Produced Document | ESTATE JPM018219 |
| Produced Document | ESTATE\_JPM018220 |
| Produced Document | ESTATE\_JPM018221 |
| Produced Document | ESTATE JPM018222 |
| Produced Document | ESTATE\_JPM018223 |
| Produced Document | ESTATE\_JPM018224 |
| Produced Document | ESTATE JPM018225 |
| Produced Document | ESTATE\_JPM018226 |
| Produced Document | ESTATE\_JPM018227 |
| Produced Document | JDoe JPMC 000001 |
| Produced Document | JDoe JPMC 000961 |
| Produced Document | JDoe\_JPMC\_001017 |
| Produced Document | JDoe JPMC 002031 |
| Produced Document | JDoe JPMC 003010 |
| Produced Document | JDoe JPMC\_003901 |
| Produced Document | JDoe JPMC 005107 |
| Produced Document | JDoe\_JPMC\_006556 |
| Produced Document | JDoe JPMC\_007367 |
| Produced Document | JDoe JPMC 007434 |
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| Produced Document | JDoe JPMC 007470 |
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| Produced Document | JDoe JPMC 007509 |
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| Produced Document | JDoe\_JPMC\_007514 |
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| Produced Document | JDoe\_JPMC\_007693 |
| Produced Document | JDoe JPMC 007706 |
| Produced Document | JDoe JPMC 007707 |
| Produced Document | JDoe\_JPMC\_007710 |
| Produced Document | JDoe JPMC 007712 |
| Produced Document | JDoe JPMC 007714 |
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| Document Type | Description |
|---|---|
| Produced Document | JDoe JPMC 007718 |
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| Produced Document | JDoe JPMC 007726 |
| Produced Document | JDoe\_JPMC\_007727 |
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| Document Type | Description |
|---|---|
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| Document Type | Description |
|---|---|
| Produced Document | JDoe JPMC 007817 |
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| Produced Document | JDoe\_JPMC\_007821 |
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| Produced Document | JDoe JPMC 007829 |
| Produced Document | JDoe JPMC 007830 |
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| Produced Document | JDoe JPMC 007841 |
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| Produced Document | JDoe JPMC 007854 |
| Produced Document | JDoe JPMC 007855 |
| Produced Document | JDoe JPMC 007856 |
| Produced Document | JDoe\_JPMC\_007857 |
| Produced Document | JDoe JPMC 007858 |
| Produced Document | JDoe JPMC 007859 |
| Produced Document | JDoe\_JPMC\_007860 |
| Document Type | Description |
|---|---|
| Produced Document | JDoe JPMC 007861 |
| Produced Document | JDoe\_JPMC\_007862 |
| Produced Document | JDoe\_JPMC\_007863 |
| Produced Document | JDoe JPMC 007864 |
| Produced Document | JDoe\_JPMC\_007865 |
| Produced Document | JDoe\_JP > This document was truncated for web display. See the linked source PDF for the complete record. |