Court filing, 2023-06-23

Exhibit 1¶

GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS,¶

Plaintiff,¶

v.¶

JPMORGAN CHASE BANK, N.A.,¶

Defendant/Third-Party Plaintiff.¶

JPMORGAN CHASE BANK, N.A.,¶

Third-Party Plaintiff,¶

v.¶

JAMES EDWARD STALEY,¶

Third-Party Defendant.¶

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK¶

Case No. 22-cv- I 0904-JSR¶

Expert Report of Dr. Kimberly Mehlman-O rano CEO of Break the Chain LLC 15920 Fairway Drive Dumfries, Virginia 22025 (703) 362-9405¶

June 23, 20231¶

I may prepare graphic or illustrative exhibits based on the information reviewed and/or my analyses for use at trial. I reserve the right to amend my analysis, opinions, and this report should additional information be made available.¶

Table of Contents¶

I. INTRODUCTION	5
Overview	5
IL DEFINITIONS	11
111. SUMMARY OF OPINIONS	14
IV. JEFFREY EPSTEIN	18
Opinion	18
Basis	18
V. HUMAN TRAFFICKING OVERVIEW	23
Opinion	23
Basis	23
VI. MISIDENTIFICATIONS AS SENTINEL EVENTS	31
Opinion	31
Basis	31
VILINDICIA AND ANTI-TRAFFICKING INTERVENTIONS FOR BUSINESSES	34
Opinion	34
Basis	34
Affected Industries	36
Human Trafficking “Indicators” in Aviation	17
Human Trafficking “Indicators” in Hospitality	40
Sensitivity and Specificity	42
VIII. “BEST PRACTICES” IN THE FINANCIAL SERVICES INDUSTRY	45
Opinion	45
Basis	45
IX. ACTUAL OR CONSTRUCTIVE KNOWLEDGE	51
Opinion	51
Basis	51
X. REBUTTAL	53
Bridgette Carr	53
Credentials	53
Methodology	53
Opinions	56
XL SECONDARY EXPLOITATION	83
Opinion	83

Basis…	83
XII. CONCLUSION…	85
APPENDIX A. Curriculum Vitae …	87
APPENDIX C. Materials Reviewed and Considered …	109
APPENDIX D. ILO Operational Indicators of Commercial Sexual Exploitation of Children…	246
APPENDIX E. ILO Operational Indicators of Commercial Sexual Exploitation of Adults…	247
APPENDIX F. Summary of Operational Indicator Protocols on Commercial Sexual Exploitation…	248
APPENDIX G. Sample of Michigan Law Center Human Trafficking Case Summaries 249

TABLE OF FIGURES¶

Figure 1. Epstein Allegation and Action Timeline	21
Figure 2. Timeline of Burgeoning Data on Human Trafficking	25
Figure 3. Estimated Arrests of Juveniles for Prostitution by Year	26
the Safe Harbor Law	27
Figure 5. “Swiss Cheese Effect” Regarding Trafficking Intervention	32
Figure 6. Polaris Project Matrix on Human Trafficking Types by Industry	37
Figure 7. Blue Lightning Initiative for Aviation Personnel “Indicators”	38
Figure 9. Blue Lightning Initiative for Aviation Personnel “Indicators”	51
Figure 10. Sample Boolean Search Phrase	56
Figure II. Maslow’s Hierarchy of Needs	Error! Bookmark not defined.
Figure 12: Comprehensive Screening Tools Identified by the Urban Institute	68

TABLE OF TABLES¶

Table 1. Maryland Scientific Methods Scale (SMS)	35
Claims of Racial Profiling	38
Table 3. Sample of Blue Campaign “Indicia” and Countervailing Information	41
Table 4. FinCEN Red Flags of Human Trafficking: 2014	48
Table 5. FinCEN Behavioral Indicators of Human Trafficking: 2020	49
Table 6. “Trends” and/or “Commonalities” Identified by Luis C.deBaca in Separate Cases	57
Matter	60
Table 9: Polaris Methods of Control in Escort Services versus Allegations Against Epstein	63
Allegations Against Epstein	64
Table 11: Polaris Methods of Control in Arts and Entertainment Industries	versus Allegations
Against Epstein.	65
Allegations Against Epstein	66
Table 13: Indicators Referenced by Carr, by Agency, and Applied to the Present Case	68
Table 14. Summary of Carr’s Opinions, Basis, and Countervailing Information	76

I. INTRODUCTION¶

Overview¶

I have been engaged by JPMorgan Chase Bank, N.A.2 in the matter of Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 22-cv-10904-JSR (S.D.N.Y) (the Epstein Litigation) to provide opinions as an expert on human trafficking. I am being compensated for my review, analysis, and time in this case, as follows:¶

• Consultation retainer: $10,000
• Merits report retainer: $10,000
• Review, analysis, and consultation: $750/hour
• Review, analysis, and consultation overtime: $1,125/hour
• Travel: $375/hour

My compensation is not contingent upon offering any specific opinions or on the outcome of this matter.¶

Over the past fifteen years, I have accumulated a variety of work experiences that contribute to my qualifications as an expert on human trafficking (see Appendix A for a copy of my Curriculum Vitae). As the CEO of Break the Chain, LLC and former CEO of Mahn, Mehlman & Associates, LLC, I regularly serve as an expert witness for human trafficking cases (see Appendix B for a list of cases). I also provide pro bono expert witness services for human trafficking survivors and currently serve on the advisory network for anti-trafficking non-profit Empower Her Network, where I assisted in building the qualitative measurement tools used by their organization for the last five years.¶

I am the author of a book on the different forms of human trafficking, which is entitled Hidden in Plain Sight: America’s Slaves of the New Millennium. For this book, I performed extensive primary and secondary research, including:¶

• I. A systematic review of over 300 human trafficking cases;
• 2. Content analyses on more than 1,000 media reports of human trafficking arrests;
• 3. Qualitative interviews of human trafficking victims;
• 4. Qualitative interviews of convicted human traffickers;
• 5. Qualitative interviews of consenting sex workers; and
• 6. Qualitative interviews of commercial sex consumers.

My book was incorporated into the three-day Advanced Human Trafficking Law Enforcement Class curriculum used by ERASE Child Trafficking to train law enforcement in the United States on human trafficking identification and investigation.3 The book also received a variety of¶

{sup}2 Herein referred to as JPMorgan or JPMC.¶

{sup}3 For example. San Bernadino County Sheriff’s Department, San Bernardino Police Department, City of Fontana Police Department, and Redlands Police Department.¶

advanced praise from experts within the field.’¶

In addition, I formally served as an adjunct human trafficking subject matter expert for RAND Corporation, a non-profit institution that helps improve policy and decision-making through research and analysis, where I worked on three study proposals:¶

• 1. Research design to evaluate the National Human Trafficking Hotline;
• 2. Development of an evidence-based human trafficking risk assessment tool for organizations working with minors; and
• 3. Evaluating the outcomes of housing services for adult and juvenile human trafficking survivors.

In these capacities, I have had the opportunity to train various law enforcement agencies around the country on my human trafficking research for investigations, including Homeland Security Investigations in Buffalo, New York; Montebello Police Department in Montebello, California; the North Carolina State Bureau of Investigation; and the Canadian Mounted Police in Halifax, Nova Scotia, among others. I have also presented my research at various human trafficking summits and conferences and served on the Greater Prince William County Human TraffickiniSt Force (GPWCHTTF) as the data collection sub-committee chair, as well as on the Prince County Human Trafficking Task Force. In 2019, I served as an invited panelist for the Police Executive Research Forum’s Critical Issues in Policing Conference—The Police Response to Human Trafficking, which led to a published report in 2020.5¶

With regards to human trafficking in the erotic massage industry, I have conducted primary research into recruitment and control schemes, advertisements, the mechanics of commercial sex exchanges, and the distinction between sex trafficking and consenting commercial sex. Various aspects of my research have been presented to law enforcement agencies, including but not limited to special agents for Homeland Security Investigations in Buffalo, New York; fire marshals in Fairfax, Virginia; and law enforcement officers in County and Palm Beach County.¶

In addition to my work on human trafficking, I have received formal traininiiiiwell as quantitative and qualitative research experience, during my graduate coursework at Mason University. Specifically, I served as a research associate on the Trinidad and Tobago Crime Reduction Project, which involved government-sanctioned surveys of both police officers and members of the community in Trinidad. I also led participant outreach for the Office of Juvenile Justice and Delinquency Prevention (OJJDP) Census of Juveniles on Probation and served as the Clinical Trial Search Coordinator for the Cochrane’ Justice Health Field.¶

For example, from Louise I. Shelley, Omer L. and Nancy Hint Professor of Public Policy at the Schar School of Policy and Government at Mason University in Virginia and Director, Terrorism, Transnational Crime and Corruption Center and John Cotton Richmond, Former Federal Human Trafficking Prosecutor and Founding Director of the Human Trafficking Institute.¶

{sup}5 Police Executive Research Forum (PERF), How Local Police Can Combat the Global Problem of Human Trafficking: Collaboration. Training. Support for Victims, and Technology Are Keys to Success, (2020), https://www.policeforum.orgiassets/CombatHumanTrafficking.pdf,¶

The Cochrane Library is a collection of high-quality, independent evidence to inform healthcare decision-making.¶

In addition to my practical and research experience, I also formally taught about human trafficking as part of my course material at [REDACTED] Mason University and at University of Maryland, College Park, the #1 ranked criminology doctoral program in the nation.{sup}7¶

I hold a Ph.D. in Criminology, Law and Society from [REDACTED] Mason University, as well as a M.S. in Justice, Law, and Crime Policy and a B.S. cum laude in Administration of Justice.¶

My research on the efficacy of anti-trafficking interventions has been published in the Journal of Social Inclusion,{sup}8 which was guest edited by leading human trafficking expert Siddharth Kara, an Adjunct Lecturer at Harvard University and author of “Sex Trafficking: Inside the Business of Modern Slavery.” My qualitative interviews with convicted human traffickers were also published in the journal Trends and Organized Crime.{sup}9 Additionally, my work has also been published through magazines such as the Diplomatic Courier{sup}10 and in media outlets, such as USA Today,{sup}11¶

{sup}7 While at University of Maryland, College Park, I contributed to and was named as a faculty member for the U.S. Department of Homeland Security, U.S. Customs and Border Protection, CBP Leadership Institute grant proposal, which was awarded in 2014.¶

{sup}8 Kimberly Mehlman-Orozco, Safe Harbor Policies for Juvenile Victims of Sex Trafficking: A Myopic View of Improvements in Practice, 3 Soc. Inclusion 52 (2015).¶

{sup}9 Kimberly Mehlman-Orozco, Projected Heroes and Self-Perceived Manipulators: Understanding the Duplicitous Identities of Human Traffickers, 23 Trends in Organized Crime 95, 105-106 (2017).¶

¹⁰ See, e.g., Kimberly Mehlman-Orozco, America’s Symbolic, Not Effective, Anti-Trafficking Policy, Diplomatic Courier (May 31, 2016), https://www.diplomaticcourier.com/posts/americas-symbolic-not-effective-anti-trafficking-policy; Kimberly Mehlman-Orozco, Sex Slaves or Prostitutes?: How Human Trafficking is Hidden in Plain Sight in America’s Capital, Diplomatic Courier (May 4, 2016), https://www.diplomaticcourier.com/posts/sex-slaves-prostitutes-human-trafficking-hidden-plain-sight-americas-capital; or Kimberly Mehlman-Orozco, Devoid of Research: An Evaluation of Human Trafficking Interventions, Diplomatic Courier (Mar. 18, 2014), https://www.diplomaticcourier.com/posts/devoid-of-research-an-evaluation-of-human-trafficking-interventions.¶

¹¹ See, e.g., Kimberly Mehlman-Orozco, Jeffrey Epstein’s deal with Alexander Acosta wasn’t out of line with what I have seen, USA Today (July 10, 2019), https://www.usatoday.com/story/opinion/2019/07/10/jeffrey-epstein-alexander-acosta-donald-trump-sex-trafficking-agreement-column/1686687001; and Kimberly Mehlman-Orozco and William [REDACTED], Robert Kraft spa scandal: Sex trafficking is hard to prove, that doesn’t mean it’s a lie, USA Today (Apr. 4, 2019), retrieved from: https://www.usatoday.com/story/opinion/2019/04/04/robert-kraft-lawyers-sex-trafficking-conviction-difficult-column/3325857002.¶

Politico,12 The Houston Chronicle,13 The.’ The Washington Post,I5 The Baltimore Sun,I6 The¶

{sup}32 See, e.g., Kimberly Mehlman-Orozco, How to Fight Sex Trafficking, Politico (Feb. 24, 2019), retrieved from: https://svww.politico.com/magazine/story/2019/02/24/sex-trafficking-225203/.¶

{sup}11See, e.g., for example, Kimberly Mehlman-Orozco and Hedlin, Mehlman-Orozco, Hedlin: Stop criminalizing victims of sex trafficking, Houston Chronicle (Jan. 19, 2017), https://www.houstonchronicle.com/opinion/outlook/article/Mehlman-Orozco-Hedlin-Stop-criminalizing-10869881.php.¶

{sup}&quot;See, e.g., Kimberl Mehlman-Orozco and William D. EMI, Legalizing prostitution could end sex-trafficking investigations. The (March 19, 2019), retrieved from: https://thehill.com/opinion/criminal-justice/434272 legalizing-prostitution-could-end-sex-traffickinginvcsti ations/4:—:text=Researcle/020suggestsVaOthar/a0legalization°420would,it%20wouldVaOhamperVaOtraffic Kimberly Mehlman-Orozco, Trafficking victims get lost under unjust criminal convictions, (Dec. 8, 2017), retrieved from: https://dtehill.com/opinion/civil-rights/363902-trafficking-victims-get-lostunder-unjust-criminal-convictions/; Kimberly Mehlman-Orozco, Decriminalize sex work to bring trafficking victims out of the shadows, The. (Oct. 21, 2017), https://thehill.com/opinion/civil-rights/356512-decriminalize-sexwork-to-bring-trafficking-victims-out-of-the-shadows/; Kimberly Mehlman-Orozco, Sex Trafficking is often hidden in plain sight,. (Oct. 21, 2016), hups://thehill.corn/blogs/pundits-blog/immigration/302150-sex-trafficking-isoften-hidden-in-plain-sighta and Kimberly Mehlman-Orozco, What happens after a human trafficking victim is ‘rescued’?, IN (July 29, 2016), https://thehill.conAlogs/congress-blog/judicial/289709-what-happens-after-ahuman-trafficking-victim-is-rescued/.¶

{sup}15 See. e.g., Kimberly Mehlman-Orozco, Decriminalizing sex work would help bring victims out of the shadows, The Washington Post (Dec. 20, 2017), https://www.washingtonpost.com/opinions/decriminalizing-sex-work-wouldhelp-bring-victims-out-of-the-shadows/2017/10/20/4b7d8be8-b38a-lle7-9b93-697043e57a22\_story.html; and Kimberly Mehlman-Orozco, Vilifying Backpage.com won’t help fight sex trafficking, Wash. Post (July 18, 2017). hops://www.washingtonpost.com/opinions/vilifying-backpagecom-wont-help-fight-sextrafficking/2017/07/18/101b0d34-6b12-11e7-abbc-a53480672286_story.html.¶

{sup}16 See. e.g., Kimberly Mehlman-Orozco, Sex trafficking bill likely to do more harm than good, The Baltimore Sun (March 22, 2018), hdps://wv.w.baltimoresun.com/opinion/op-ed/bs-ed-op-0323-fosta-trafficking-20180322 story.html; Kimberly Mehlman-Orozco, What every parent should know about sex trafficking, Baltimore Sun. (Mar. 28, 2017), https://www.baltimoresun.com/opinion/op-ed/bs-ed-sex-trafficking-20170328-story.html; and Kimberly Mehlman-Orozco, Consenting prostitutes or trafficked victims?, Baltimore Sun (June 19, 2016), https://www.baltimoresun.com/opinion/op-edibs-ed-sex-trafficking-20160619-story.html.¶

Crime Report,{sup}17 Thomson Reuters,{sup}18 and others. Moreover, I am frequently interviewed and consulted by the media on topics related to human trafficking; for example, most recently by Forbes,{sup}19 as well as by CNN, NBC, CBS, Fox News, among others.¶

I also serve as a peer-reviewer for empirical research articles on human trafficking, for example with the Journal of Human Trafficking and American Journal of Evaluation and I serve as a peer-reviewer for grant applications for human trafficking research. Most recently, I was invited by the Journal of Human Trafficking to review a manuscript entitled “A Quasi-Experimental Intervention Trial to Test the Efficacy of a Human Trafficking Awareness Campaign: The Blue Campaign.” Additionally, in June 2022, I served as an invited peer-reviewer for the U.S. Department of Justice, Office of Justice Programs, National Institute of Justice Research and Evaluation on Trafficking in Persons. Previously, I was invited by the Office of Justice Programs and National Institute of Justice to serve as a peer-reviewer for FY 2020 Research on Law Enforcement Responses to Sex Trafficking of Minors.¶

With regards to the present matter and in full disclosure, it should be noted that in October 2020 Assistant United States Attorney for the Southern District of New York Alison Moe reached out¶

¹⁷ See, e.g., Jennifer Lowery-Keith and Kimberly Mehlman-Orozco, ‘Justice Denied’: A Sex Trafficking Survivor Tells Her Story, Crime Rep. (Feb. 28, 2022), https://thecrimereport.org/2022/02/28/justice-denied-a-sex-trafficking-survivor-tells-her-story/; Kimberly Mehlman-Orozco and Greg Bristol, Suing Social Media Sites Won’t Curb Sex Trafficking: Advocates, The Crime Report (Nov. 30, 2021), https://thecrimereport.org/2021/11/30/suing-social-media-sites-wont-curb-sex-trafficking-advocates/; Kimberly Mehlman-Orozco and Marisa Trasatti, Does ‘Nirvana’ Lawsuit Undermine Struggle Against Trafficking?, Crime Rep. (Aug. 31, 2021), retrieved from: https://thecrimereport.org/2021/08/31/does-nirvana-lawsuit-undermine-struggle-against-trafficking/; Kimberly Mehlman-Orozco, The ‘Racialization’ of Sex Trafficking in America, Crime Rep. (May 4, 2021), retrieved from: https://thecrimereport.org/2021/05/04/1294014/; Kimberly Mehlman-Orozco, COVID-19, the Commercial Sex Industry and Sex Trafficking, The Crime Report (Mar. 22, 2021), https://thecrimereport.org/2021/03/22/covid-19-the-commercial-sex-industry-and-sex-trafficking/; Kimberly Mehlman-Orozco, Why the Stop Enabling Sex Traffickers Act is the Wrong Solution, Crime Rep. (Sept. 13, 2017), retrieved from: https://thecrimereport.org/2017/09/13/why-the-stop-enabling-sex-traffickers-act-is-the-wrong-solution/; Kimberly, Mehlman-Orozco, Child Trafficking: The Tragedy of ‘Princess’, The Crime Report (July 10, 2017), https://thecrimereport.org/2017/07/10/child-trafficking-the-tragedy-of-princess/; Kimberly Mehlman-Orozco, Hunting the Internet’s Sex Predators, Crime Rep. (June 14, 2017), retrieved from: https://thecrimereport.org/2017/06/14/hunting-the-internets-worst-predators/; Kimberly Mehlman-Orozco, Sex Trafficking: A Surprising Rescue Story, Crime Rep. (May 17, 2017), retrieved from: https://thecrimereport.org/2017/05/17/sex-trafficking-a-surprising-rescue-story/; and Kimberly Mehlman-Orozco, Why Do We Criminalize Young Victims of Sex Trafficking?, Crime Rep. (Jan. 17, 2017), https://thecrimereport.org/2017/01/17/why-do-we-criminalize-young-victims-of-sex-trafficking/.¶

¹⁸ Kimberly Mehlman-Orozco, Why cracking down on websites won’t stop online sex trafficking, Thomson Reuters Foundation (Mar. 2, 2018), https://news.trust.org/item/20180302174534-se03q/; Kimberly Mehlman-Orozco, Why we should question the FBI’s recent human trafficking sting, Thomson Reuters Found.(Oct. 24, 2017), https://news.trust.org/item/20171024161910-x96o5; Kimberly Mehlman-Orozco, To sue or not to sue third-party businesses for sex trafficking?, Thomson Reuters Found. (July 3, 2017), retrieved from:¶

https://news.trust.org/item/20170703203545-k6b8z; and Kimberly Mehlman-Orozco, Will shutting down Backpage.com end the scourge of child sex trafficking in America?, Thomson Reuters Found. (May 30, 2017), retrieved from: https://news.trust.org/item/20170530154532-pjag0.¶

¹⁹ [REDACTED] Brewster, Sex Traffickers Used America’s Favorite Family Safety App To Control Victims, Forbes (April 6, 2023), https://www.forbes.com/sites/thomasbrewster/2023/04/06/sex-traffickers-use-parenting-apps-like-life360-to-spy-on-victims/?sh=92d15c864c3a.¶

to me, along with her colleagues Lara Pomerantz and Maurene Comey, to discuss my availability to testify at the trial of United Slates v. Ghislaine Maxwell; however, I was not ultimately retained on that case. Additionally, I issued a class certification report in the matter of Jane Doe 1 v. JPMorgan Chase Bank, N.A.¶

At present, I have testified in court for a total of ten cases:¶

• I. Five cases in state criminal court in California20;
• 2. One case in federal criminal court in California21;
• 3. One case in federal criminal court in New Mexico22;
• 4. One case in state criminal court in New York”;
• 5. One case in state criminal court in Virginian; and
• 6. One case in federal civil court in Virginia.25

I have also sat for depositions for a total of seven civil cases:¶

• I. Three cases in state civil court in Georgia;
• 2. One case in federal civil court in New York;
• 3. One case in federal civil court in Virginia;
• 4. One case in federal civil court in California; and
• 5. One case in federal civil court in Oklahoma.

Additionally, there are four orders recognizing the admissibility of my expert witness testimony:¶

• I. One case in federal civil court in Virginia26;
• 2. Two cases in federal criminal court in New Mexico; and
• 3. One case in federal criminal court in California.

i0 All five were at trial.¶

{sup}21 Trial.¶

{sup}22 At a Daubers hearing only, where I was admitted. Case was resolved through plea bargain.¶

{sup}23 At Frye hearing only for another expert, Chin Raghavan.¶

{sup}21At a Daubers hearing only, where I was admitted, but court did not issue a written order.¶

{sup}25 Trial.¶

{sup}36 Note: I was also admitted in state court in Virginia, but the challenge was withdrawn before an order was issued.¶

II. DEFINITIONS¶

In order to facilitate precision in language, which is undoubtedly important when evaluating the present claims, I proffer the following definitions, which reflect either a commonly accepted understanding of key concepts in the sex trafficking literature or social scientific research, or definitions from the United States Code and New York Penal Code, as referenced in my report.¶

Labor Trafficking: The recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery?¶

Sex Trafficking: The recruitment, harboring, transportation, provision, obtaining, patronizing, or soliciting of a person for the purpose of a commercial sex act and in which the commercial sex act is induced by force, fraud, or coercion or in which the person induced to perform such act has not attained 18 years of age.?¶

Commercial Sex Act: Any sex act on account of which anything of value is given to or received by any person?¶

Sexual Harassment: Sexual harassment may be verbal, visual, and/or physical, including:¶

• Sexually offensive remarks or jokes;
• Unwanted touching or groping;
• Coerced sex acts;
• Requests for sexual favors of a sexually suggestive coins out of a supervisor’s pants pocket);
• Displaying pornographic images;
• Comments (either complimentary or derogatory) preferences;
• Sexual gestures (e.g., pantomiming sex acts)? nature (e.g., asking employee to dig about a person’s gender or sexual

Sexual Misconduct: A person is guilty of sexual misconduct when:¶

• I. He or she engages in sexual intercourse with another person without such person’s consent; or
• 2. He or she engages in oral sexual conduct or anal sexual conduct with another person without such person’s consent; or

{sup}27This definition is based on a prong of the term “[s]evere forms of trafficking in persons” from 22 U.S.C. § 7102(11XB).¶

{sup}28 22 U.S.C. § 7102(11XA), (12).¶

{sup}29 22U.S.C.§ 7102(4).¶

{sup}&quot; Patsy Gen. of N. Y., Sexual Harassment: In The Workplace: Know Your Rights, https://ag.ny.govisites/defauWfiles/sexual\_harrassment\_brochure.pdf (last accessed Mar. 15, 2023).¶

• 3. He or she engages in sexual conduct with an animal or a dead human body?’

Rape: A person is guilty of rape in the first degree when he or she engages in sexual intercourse with another person:¶

• I. By forcible compulsion; or
• 2. Who is incapable of consent by reason of being physically helpless; or
• 3. Who is less than eleven years old; or
• 4. Who is less than thirteen years old and the actor is eighteen years old or more.32

Coercion: the term “coercion” means: (A) threats of serious harm to or physical restraint against any person; (B) any scheme, plan, or pattern intended to cause a person to believe that failure to perform an act would result in serious harm to or physical restraint against any person; or (C) the abuse or threatened abuse of the legal process.33¶

Exploit: Benefit unfairly from the work of (someone), typically by overworking and underpaying them.¶

Venture: Defined in Section 1591(eX6) of the TVPA as “any group of two or more individuals associated in fact, whether or not a legal entity.s34¶

Ecological Fallacy: Inferences about the characteristics/behavior of individuals are derived from inferences about the group to which the individuals belong.35¶

Fallacy of Composition: The error of assuming that what is true of a member of a group is true for the group as a whole.¶

Facilitate: To make (an action or process) easy or easier.¶

Sensitivity: The ability of law enforcement, service providers, and other third parties to correctly identify true victims of human trafficking (true positive).¶

Specificity: The ability of law enforcement, service providers, and other third parties to correctly identify persons who are not victims of human trafficking (true negative).¶

Methodology: The specific methods, procedures, or practices needed to derive or interpret data within the scope of a particular discipline.¶

Reliability: The degree to which the result of a methodology can be depended on to be accurate¶

{sup}31 N.Y. Penal Law §130.20.¶

{sup}32 N.Y. Penal Law § 130.35.¶

{sup}33 22 U.S.C. § 7102(3).¶

{sup}34 18 U.S.C.11591(eX6); Noble v. Weinstein, 335 F. Supp. 3d 504, 524 (S.D.N.Y. 2018).¶

{sup}35 J.T. “Ecological fallacy,” 2 Encyclopedia of Rsch. Methods in Criminology and Crim. Just., 478-482 (2021).¶

(e.g., through the overall consistency of a measure by using a statistical approach).¶

Narrative Review or Literature Review: A descriptive and subjective summary of literature on a specific topic.¶

Systematic Review: A structured, rigorous, and replicable examination of the literature on a specific topic.¶

Boolean Search Phrase: A combination of keywords alongside specific words (e.g., AND, OR, NOT, NEAR) and symbols (e.g., •, -) known as Boolean operators used limit or expand search results in a review of literature.¶

Confirmation Bias: The tendency to process information by looking for, or interpreting, information that is consistent with an existing belief.¶

Hindsight Bias: The tendency, upon learning an outcome of a criminal case to overestimate a third party’s ability to have foreseen the crime.¶

Secondary Exploitation: The act of making use of or benefiting from a human trafficking survivor’s victimization or the human trafficking phenomenon.’¶

{sup}36See, e.g., Kimberly Mehlmann-Orozco, Hidden in Plain Sight: America’s Slaves of the New Millennium 199 (2017) and Claudia Cojocaru. My experience is mine to tell: Challenging the abolitionist victimhood framework. 7 Anti•Traficking Review 12 (2016).¶

III. SUMMARY OF OPINIONS37¶

• I. Although Epstein’s crimes are atypical of human trafficking, based on the allegations in the public record, 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.
• 2. Based on my expertise on human trafficking, it is more likely than not that many of Epstein’s crimes could have been prevented if law enforcement had intervened when they were first contacted.
• 3. There is no evidence to suggest that Epstein’s crimes would have been prevented if his business relationship with JPMC ended sooner.
• 4. There is no evidence to suggest that Epstein’s crimes would have been prevented if JPMC
• 5. 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.
• 6. As a consequence of misidentification, sex trafficking victims, including minors, are often erroneously criminalized by the judicial system and denied services.
• 7. Epstein’s sexual victimizations involving illicit massage were atypical of a sex trafficking operation 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.
• 8. Claims of alleged sex trafficking, especially those made by third parties against third parties, are at high risk of secondary exploitation.
• 9. I am not aware of any reliable or generally accepted empirical research to estimate the prevalence of sex trafficking encountered by financial institutions in the United States.
• 10. Indicia of “sex trafficking” in the banking industry have not been adequately evaluated for sensitivity or specificity.
• II. Based on my expertise on human trafficking, the financial services industry has been lauded for its innovative and proactive efforts to meet the challenge of addressing trafficking and staying abreast of diverse forms of trafficking and shifting patterns.
• 12. Based on my expertise on human trafficking, the policies, procedures, and internal controls used by JPMC were consistent with those employed by others in the financial services industry.
• 13. While the purported “best practice” indicia of sex trafficking for the financial services industry are not supported by reliable empirical research, they are not consistently evident in the present case, which illustrates the atypicality of the present allegations. For example:
  • a. There is no evidence that Epstein or anyone associated with him took control of the prospective class members’ respective financial identity.

{sup}37 All of my opinions are stated to a reasonable degree of social scientific certainty in my profession as an expert in human trafficking and Ph.D. educated criminologist.¶

• b. There is no evidence that Epstein or anyone associated with him took control of the prospective class members’ respective banking products in a manner that is consistent with human trafficking (e.g., long-term confiscation for the purpose of exploitation{sup}38).
• c. There is no evidence that Epstein or anyone associated with him limited or prevented the prospective class members’ respective access to any financial system.
• d. There is no evidence that Epstein or anyone associated with him spoiled the prospective class members’ respective credit record.
• e. There is no evidence that Epstein or anyone associated with him used prepaid credit cards to conceal their illicit activities.
• f. There is no evidence that Epstein or anyone associated with him used crypto currencies to conceal their illicit activities.
• g. There is no evidence that Epstein or anyone associated with him attempted to conceal the true originator or beneficiary of his payments.

14. While the purported “best practice” indicia of sex trafficking for the massage industry are not supported by reliable empirical research, they are not consistently evident in this case and/or there is no evidence to suggest JPMC knew or should have known. For example, with regards to the asserted indicia of trafficking for outcall and/or home-based massage:

• a. There is no evidence that the alleged victims worked at a massage business where the front door was locked and customers could only enter if “buzzed in” or enter through back or side doors that were more discreet;
• b. There is no evidence that the alleged victims worked at a massage business where the windows were covered, so passersby could not see into the establishment;
• c. There is no evidence that Epstein paid significantly below market level for massages, in fact he paid well above market level for massages;
• d. There is no evidence that the alleged victims demanded a large tip or expressed distress if they did not receive a large tip after a massage or that JPMC knew or should have known of this;
• e. There is no evidence that the alleged victims served Epstein or anyone associated with him for “excessive hours” or were “on call at all times,” in fact [REDACTED] declined meeting with Epstein on multiple occasions;
• f. While there is some evidence that certain alleged victims who performed massages only served male clientele, there is no evidence that JPMC knew or should have known of this;
• g. There is no evidence that there was a regular rotation of women (e.g. new women coming in every several weeks). In fact, [REDACTED] and other alleged victims were demonstrably in relationships with Epstein for years; and
• h. There is no evidence tying the allegations to advertisements on commercial sex websites (e.g., Rubmaps.com).

{sup}38 For example, Epstein set up accounts for [REDACTED] but evidence suggests that she maintained control and use over the accounts for the duration of their existence. See, e.g., JPM-SDNYLIT-00030057.¶

• 15. Based on my expertise on human trafficking, typically traffickers do not pay victims of sex trafficking. In fact, the absence of money, withholding of money, and/or confiscation of money is more commonly referred to as a purported indicum.
• 16. I am not aware of any reliable or generally accepted empirical research to suggest that “large, regular cash withdrawals” are a reliable indicum of sex trafficking.
• 17. To a reasonable degree of social scientific certainty, reporting large cash withdraws to law enforcement would not have had a statistically significant effect on the prevalence of sex trafficking or the identification of victims or offenders.
• 18. To a reasonable degree of social scientific certainty, there is no evidence to suggest that a change in JPMC’s would have led to the identification of Epstein’s victims or to an intervention or prevention to Epstein’s crimes.
• 19. I am not aware of any reliable or generally accepted empirical research to suggest that “round-dollar wire payments” are a reliable indicum of sex trafficking.
• 20. To a reasonable degree of social scientific certainty, would not have had a statistically significant effect on the prevalence of sex trafficking or the identification of victims or offenders.
• 21. To a reasonable degree of social scientific certainty, there is no evidence to suggest that a change in would have led to the identification of Epstein’s victims or to an intervention or prevention to Epstein’s crimes.
• 22. Based on my review of the evidence and testimony in this case, as well as my research, education, and experience, there are no reliable data to suggest that Epstein and his alleged co-conspirators would not have been able to victimize women and girls without JPMC’s financial infrastructure. Any suggestion otherwise is based on misinformation, unsupported speculation or subjective belief, ecological fallacies, or fallacies of composition, and is counterfactual.

The following sections of this report provide a summary and further explanation as to the evidentiary, empirical, and theoretical basis for each of the aforementioned opinions:¶

Section IV. Summarizes the crimes committed by Epstein and the associated claims against JPMC;

¶

Section V. Provides an overview on human trafficking and explores the challenges related to identification and intervention;

¶

Section VI. Conceptualizes human trafficking misidentifications as sentinel events;¶

Section VII. Examines the data, interventions, and indicia of sex trafficking and commercial sex in the private sector;¶

Section VIII. Highlights best practices in the financial services industry;¶

Section IX. Reviews actual or constructive knowledge standards regarding third-party liability trafficking claims;¶

Section X. Rebuts the testimony of the Plaintifrs Named Experts;¶

Section M. Discusses secondary exploitation of human trafficking; and¶

Section XII. Summarizes the opinions in the conclusion.¶

IV. JEFFREY EPSTEIN¶

Opinion¶

Jeffrey Epstein was indicted for sex trafficking in 2019, six years after his business relationship with JPMC ended. Although Epstein’s crimes are atypical of human trafficking, based on the allegations in the public record, 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. Many of Epstein’s crimes could have been prevented if law enforcement had intervened when they were first contacted in 1996 or if Epstein had been prosecuted for trafficking when law enforcement was contacted again in 2005. However, there are no facts in evidence to suggest that E stein’s crimes would have been prevented if his business relationshi with JPMC ended sooner¶

in fact, the exact opposite is true, as his alle ed crimes continued or six er the cessation o his business relationshi with JPMC¶

Epstein’s crimes also continued for 20 years after law enforcement was first contacted by and for 13 years after Epstein was first indicted, without intervention from any governmental authority including officials of the United States Virgin Islands.¶

Basis¶

No party involved in the present matter contests that Epstein victimized women and children. What is contested, however, can be summarized as follows:¶

• I. Whether Epstein’s crimes are typical of trafficking or other forms of sexually-based offenses;
• 2. Whether all women who allege to be victims of Epstein are in fact victims, as opposed to co-conspirators;
• 3. Whether there were evidence-based indicia of trafficking that JPMC knew or should have known; and
• 4. Whether Epstein’s business relationship with JPMC facilitated his crimes.

The Plaintiff and the Plaintiff’s named experts allege that:¶

• I. Epstein’s crimes are typical of trafficking; yet, they provide no reference to any case, research, or academic authority to support this claim;

• 2. All women who allege to be victims of Epstein are in fact victims, while ignoring the fact that some of these women have been publicly accused by both law enforcement and other Epstein survivors of being co-conspirators;
• 3. JPMC knew or should have known of trafficking indicia related to Epstein, despite the fact that there is no evidence-base to support these purported indicia and law enforcement failed to intervene; and
• 4. Epstein’s business relationship with JPMC facilitated his crimes, even though there is no evidence to support this claim and, to the contrary, these alleged crimes occurred before the business relationship began and after the business relationship ended.

While the lack of evidence-base for the claims made by the Plaintiff and the Plaintiff’s named experts are discussed further in the sections below, it is important to remember that Epstein was not indicted for sex trafficking until 2019, six years after the JPMC banking relationship with Epstein ended, and for allegations related to pre-2006 conduct.¶

Moreover, while overt disclosures of sexual abuse and molestation were repeatedly made to multiple other entities, such as the Federal Bureau of Investigation (FBI),39 New York Police,4° Palm Beach Police41 and Vanity Fair,42 at no time did any victim make an overt disclosure to any JPMC employee. The only entities who were truly in a position to know about the full extent of Epstein’s crimes, but failed to intervene, were members of law enforcement and officers of the court in Florida and New York. In fact, Epstein survivors, such as have publicly blamed these entities for allowing Epstein’s abuses to continue.43¶

With that being said, no party involved in the present matter contests that JPMC was made aware that Epstein was convicted of prostitution of a minor in 2008. Following his conviction, JPMC appropriately and consistently with industry standards categorized Epstein as a “high risk” client and increased the monitoring and¶

At the time of Epstein’s conviction in 2008, law enforcement overwhelmingly did not understand “prostitution of a minor” to be synonymous with sex trafficking.” However, the Plaintiff and the Plaintiff’s named experts make this leap of logic without any citation or reference.° It is unclear why the Plaintiff and the Plaintiff’s named experts insist on imparting an interpretation onto JPMC that was demonstrably not consistent with what was understood by law enforcement at the time, much less the American public and the private sector.¶

{sup}&quot; Mike Baker, The Sisters Who First Tried to Take Down Je re y E N.Y. Times (Aug. 26, 2019), retrieved from: https://www.nvtimes.com/2019/08/26/us/epstei maxwell.html. See also Dep’t of Just., Office of Pro. Resp., Investigation Into the U.S. Attorney’s (Wire for the Southern District of Florida’s Resolution of Its 2006-2008 Federal Criminal Investigation ofJeffrey Epstein and Its Interactions with Victims during the Investigation (OPR Report), 225.¶

{sup}4° Mike Baker, The Sisters Who First Tried to Take Down Je t- E N.Y. Times (Aug. 26, 2019), retrieved from: hups://www.nytimes.com/2019/08/26/us/cpstein maxwell.html. See also DANY0002.¶

{sup}41 OPR Report, 11-14.¶

{sup}42 Mike Baker, The Sisters Who First Tried to Take Down Je r E N.Y. Times (Aug. 26, 2019), retrieved from: https://www.nytimes.com/2019/08/26/us/cpstein maxwell.html.¶

{sup}43 Kate Briquelet, Epstein Victim Demands FBI Investigate Its ailur t t p Him. Daily Beast (May 2, 2023), retrieved from: https:/Avww.thedailvbeastcomiepstein-victim emands-fbi-investigaie-its-fai lure-tostop-him.¶

See Infra Section V.¶

{sup}45 See. e.g., Bridgette Carr Report (Can Report), June 16, 2023,1 37. “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.”¶

Nevertheless, the Plaintiff and the Plaintiff’s named experts appear to suggest that this conviction should have been the catalyst for JPMC to take action against Epstein. The Plaintiff and the Plaintiff’s named experts do not provide any case law, empirical research, or reliable academic analysis to support this assertion. Instead, they rely upon the unsupported speculation and subjective belief that it would have had an impact on Epstein’s ability to continue committing crimes. This is undermined, in part, by the fact that Epstein’s alleged crimes continued for another six years after his relationship with JPMC ended in 2013, and after JPMC approximately 150 Cash Transaction Reports (CTRs) between 2002 and 2013 on Epstein and Epstein-related accounts.46¶

With that being said, the Plaintiff and the Plaintiff’s named experts make a number of general suggestions, without any reliable evidence-base and while ignoring issues related to implementation, as well as conceivable collateral consequences. For example, it appears as though the Plaintiff and the Plaintiff’s named experts suggest that JPMC should have intervened differently by taking one of two possible actions:¶

• I. End the banking relationship with Epstein earlier. Had the information that is now available been provided to JPMC or had law enforcement formally charged Epstein with a sex trafficking offense in 2006, it is more likely than not that the banking relationship would have ended earlier. However, hindsight bias should not impact a determination of liability. Moreover, there is no evidence to suggest that this would have prevented Epstein’s crimes or had any impact on his illicit sexual proclivities whatsoever, especially considering the fact that his crimes continued for six years after the banking relationship with JPMC ended.
• 2. according to Defense expert Teresa Pesce, JPMC was consistent with prevailing regulatory expectations and industry standards under the Bank Secrecy Act (BSA). Specifically, in her report, Pesce notes that JPMC had in place policies, procedures, and internal controls to prevent and detect money laundering consistent with industry standards under the BSA. For example, JPMC:
  • a.
  • b. Filed approximately 150 Currency Transaction Reports (CTRs) regarding Epstein and Epstein-related accounts from 2002 to 2013;48 and
  • c. Treated Epstein as a high risk client following his arrest and conviction, per its internal polices, including conducting due diligence on the relationship.49

Teresa A. Pesce Report (Pesce Report), June 23, 2023,1 19-21.¶

{sup}&#x27;MA 20-21.¶

{sup}&quot;MA 19.¶

Id.,1 100.¶

Ultimately, although the Plaintiff and the Plaintiff’s named experts want this court to believe that cash transactions are a red flag of sex trafficking,” there is no reliable basis for that claim. In fact, payments to women, in cash or otherwise, regardless of the denomination, are actually inconsistent with trafficking. Instead, at the time of the alleged conduct in the present matter, nonpayment of employees was the most reliable indicator of trafficking in persons or modern slavery—an indicator that is not alleged in the present matter. Moreover, and most importantly, Epstein’s survivors make clear that many of the women who Epstein paid were not victims, but instead were co-conspirators who allegedly facilitated his crimes—a limitation to the financial data that is wholly overlooked by the Plaintiff and the Plaintiff’s named experts.¶

For example, the Plaintiff and the Plaintiff’s named experts completely ignore the fact that Epstein survivors and both accuse a woman who self-identifies as an E victim/survivor, of being a recruiter enabler, sexual assaulter, and co-conspirator.” has named j as her recruiter {sup}32 has accused of a traumatic sexual assault, {sup}3 and has publicly accused and of being co-conspirators, who are liable for the victimization of others. As such, there is no reliable or objective method for determining which women paid by Epstein were co-conspirators, victims, neither, or both.¶

Ultimately, it is important to make note that even in the absence of any legal requirement, JPMC chose to end its business relationship with Epstein six years before he was indicted for sex trafficking. Hindsight bias appears to have significantly impacted not only the Plaintiff’s¶

allegations in this case, but also the Epstein Allegation and Action Timeline Plaintiff’s experts’ interpretation and application of the facts in evidence. testimony in this case, as well as my research, education, and experience, • • there were three possible missed opportunities for enforcement:¶

• I. 1996: Report
• 2. 2006: Palm Beach Indictment
• 3. 2007: Non-Prosecution Agreement” (see Figure 1). •••••••••n

• Missed Opportunities for intervention¶

Figure I. Epstein Allegation and Action Timeline¶

{sup}&quot; See, e.g., Cart Report, 1 74.¶

{sup}51 Tam Palmeri, The women who enabled Jeffrey Epstein, Politico, May 14, 2021,¶

ttps://www.politico.condstates/new-iersev/storv202I /05/14/the-women-who-enabled-ieffrev-enstein-1382200.¶

Dep. Tr. 43:10-45:22.¶

{sup}53 JDoe_JPMC 007438-007448.¶

s’ In a series of videos posted on her social media accounts. See, for example, https://youtube.com/shons/6GVWK4YY4r4.¶

ss JDoe_DBAG_005165 (“Non-Prosecution Agreement” or “NPA”).¶

Given the knowledge that was available during the business relationship between Epstein and JPMC, I have reviewed no evidence to suggest that there was any missed opportunity for intervention that could be reasonably calculated to have prevented Epstein’s illicit activity. My opinions and findings in relation to these conclusions are discussed further in the sections below.¶

V. HUMAN TRAFFICKING OVERVIEW¶

Opinion¶

Sex trafficking is a clandestine crime and as a result victims are dcult to identify andand are frequently misidentified, even by trained law enforcement, social workers, and healthcare providers. As a consequence of misidentification, sex trafficking victims, including minors, can be denied services and erroneously criminalized. With regards to the present matter, although Jetty Epstein was not charged with sex trafficking until 2019, for offenses that allegedly occurred before 2006, various law enforcement officials were made aware of Jetey Epstein’s predilection for sexual victimization of women and minors as early as 1996, but failed to intervene.¶

Basis¶

Human trafficking generally refers to the recruitment, transportation, transfer, harboring, or receipt of persons, by means of threat, force, coercion, abduction, fraud, or deception, for the purpose of exploitation.S6 This definition encompasses two general forms of human trafficking: labor trafficking and sex trafficking.’¶

Labor trafficking is defined as the recruitment, harboring, transportation, provision, or obtaining of a person for labor or services through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery.58¶

Sex trafficking, on the other hand, is defined as when a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such act has not attained 18 years of age.59¶

While human trafficking is generally understood to refer to “modern slavery,“60 the concept of human trafficking did not start becoming internationally popularized until the year 2000.¶

On October 28, 2000, the U.S. Congress enacted the Trafficking Victims Protection Act (TVPA), which set up actions to combat trafficking in persons through criminal prosecution of perpetrators and direct victim support. Specifically:¶

• I. Coordinate and monitor anti-trafficking activities through an interagency task force;

Se See, e.g., U.S. Dep’t of Justice, Office of Just. Programs, Nat’I Inst. of Just., Overview of Human Trafficking and NH’s Role, hnps://nij.ojp.gov/topics/articles/overview-human-trafficking-and-nijs-role.¶

{sup}&quot; Id.¶

SS Victims of Trafficking and Violence Protection Act of 2000, Pub. L. No. 106-386, H.R. 3244 (2000).¶

{sup}5a Id.¶

{sup}6° The term “modem slavery” is also used and recognized by the U.S. Supreme Court in regards to human trafficking. See, for example, Nestle USA, Inc. v. Doe; Cargill, Inc. v. Doe, hups://www.supremecoun.gov/DocketPDF/19/19-416/158424/20201021160124032 402296/020pdr/020Jacques.pdf.¶

• 2. Prevent human trafficking through vocational training, education, and human trafficking public awareness campaigns;
• 3. Protect human trafficking survivors by not detaining them in correctional facilities, providing them with medical care and other assistance, and protecting them and their families from revictimization and/or deportation; and
• 4. Strengthening prosecution and punishment of human traffickers.”

Less than two months after the TVPA was adopted in the United States, the United Nations met in Palermo, Italy, and adopted the Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, Supplementing the United Nations Convention Against Transnational Organized Crime—colloquially known as the Palermo Protocol. In signing the Protocol, signatories made a public commitment to adopt policies that would:¶

• I. Prevent and combat trafficking in persons, paying particular attention to women and children;
• 2. Protect and assist the victims of such trafficking, with full respect for their human rights; and
• 3. Promote cooperation among states’ parties in order to meet those objectives.’

In December 2008, Congress amended the TVPRA to provide human trafficking survivors with a civil claim against not only criminal perpetrators of trafficking, but, anyone who “knowingly benefits, financially or by receiving anything of value from participation in a venture which that person knew or should have known has engaged in an act” of human trafficking.63¶

In the years since these developments, there has been a substantial increase in public awareness of human trafficking. There are more anti-trafficking task forces, hotlines, and survivor services than ever before. In addition to federal legislation, more states have also passed legislation to combat trafficking.¶

However, even today there are still critical gaps between the human trafficking narrative, reality, and policy. Although more people are aware of the human trafficking concept, few understand how this crime manifests in real life, and there is little empirical data to support generalizable information. Typically, victims are coerced, defrauded, and deceived into exploitive situations, where they are manipulated into complacency. Many organizations and anti-trafficking authorities now provide information on how to identify the red flags of human trafficking; however, these “red flags” are not yet empirically tested for sensitivity and specificity, especially in the finance¶

{sup}61 Victims of Trafficking and Violence Protection Act of 2000, Pub. L. No. 106-386, H.R. 3244 (2000).¶

{sup}62 U.N., Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, Supplementing the United Nations Convention Against Transnational Organized Crime, (2000), https://www.ohchr.org/sites/defauWfiles/ProtocolonTrafficking.pdf.¶

{sup}63 William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008, Pub. L. No. 110-457, H.R. 7311 (2008).¶

industry, and even trained law enforcement and service providers frequently misidentify victims (Figure 2 illustrates the burgeoning knowledge on human trafficking, which remains in development).¶

Figure 2. Timeline of Burgeoning Data on Human Trafficking¶

In fact, the Plaintiff’s own proposed expert, Ms. Bridgette Carr, previously acknowledged that in 2013 data collection on human trafficking crimes was in its “infancy.”{sup}64 In her book, Human Trafficking Law and Policy, which was published in 2014, Ms. Carr goes on to write in the chapter dedicated to corporate accountability,¶

“The framework of legislation, regulations, and other measures needed to engage companies in the eradication of human trafficking within their supply chains — and hold accountable those that do not —is still in the early stages of development.”{sup}65¶

⁶⁴ Stacy Teicher Khadaroo, Human trafficking: As awareness grows, calls triple to national hot line. Christian Science Monitor (Nov. 22, 2013), https://www.csmonitor.com/USA/Justice/2013/1122/Human-trafficking-As-awareness-grows-calls-triple-to-national-hot-line.¶

{sup}65Emphasis added. Bridgette Carr, et al. Human trafficking law and policy 181 (2014).¶

To this effect, it is important to recognize that even though, according to the Plaintiff’s named expert, the framework of legislation, regulations, and other measures needed to engage companies in the eradication of human trafficking was in the early stages of development in 2014, JPMC chose to end their business relationship with Epstein a year earlier (in 2013).¶

Moreover, while burgeoning research continues to inform and refine so-called “best practices,” victims continue to be unwittingly encountered, misidentified, denied services, and even erroneously criminalized. For example, although juveniles, unlike adults, cannot consent to exploitation and therefore should be considered victims of trafficking if they were exploited, commercially sexually exploited minors continued to be criminalized in the United States, even twenty years after the passage of the TVPA (see Figure 3).66 Figure 3. Estimated Arrests of Juveniles for Prostitution by Year¶

Of note, there were 110 minors under the age of 18 arrested in 2020, compared to 760 in 2013.67 This illustrates the increasing awareness among law enforcement of the fact that minors involved in commercial sex should be treated as people in need of services, regardless of whether they are trafficked, as opposed to being criminalized.¶

This exponential decline in the number of children arrested for commercial sex was thanks, in part, to the increasing number of states that passed safe harbor legislation, beginning around 2010. State-level safe harbor laws are meant to further decriminalize commercial sexually exploited children. Although practitioners and anti-trafficking organizations make robust claims about the effects of safe harbor legislation,” research suggests that these policies may not be achieving their¶

{sup}&quot; Data sampled from the OJJDP Statistical Briefing Book. Estimated number of arrests by offense and age group, 1980-2020. Office ofJuv. Just. and Delinq. Prevention, Stat. Briefing Book, L. Enft & Juv. Crime, Jul. 8, 2022, https://www.ojjdp.gov/ojstatbb/critne/ucrasp?table\_in=1.¶

{sup}&quot;r 1d.¶

{sup}&quot; See, e.g., Allison Newcombe, Child Sex Trafficking: Legal Overview, A.B.A., Oct. 1, 2015, httos://www.americanbar.orokrouosfoublic interest/child law/resources/childjaw oracticeonline/child law oracti ce/vol-34/october-2015/child-sex-trafficking—legal-overview/). and Human Trafficking Issue Brief: Safe Harbor, Polaris Project (2015), https://polarisprojectorg/wp-content/uploads/2019/09/2015-Safe-Harbor-Issue-Briefpdf)¶

intended effect in practice; commercial sexually exploited juveniles continue to be criminalized post safe harbor implementation? In fact, the first state to pass safe harbor protections for commercial sexually exploited children (New York) experienced an increase in juvenile prostitution arrests post-safe harbor implementation (see Figure 4). By 2013, 18 states had passed safe harbor laws.70¶

Misidentification by Law Enforcement¶

Given the lack of empirical evidence on human trafficking indicia and Figure 4. Estimated Arrests of Juveniles for Prostitution in New York by Year, Before and After the Safe Harbor Law identification strategies, the likelihood of U.S. law enforcement officials actually identifying a victim has historically been relatively low, and is even lower when it comes to private businesses. Year¶

For example, using a nationally representative survey of police organizations, Farrell, McDevitt, & Fahy (2010) found that between 2000 and 2006, less than 10% of police agencies identified a human trafficking case. Even with increases in awareness and new, more comprehensive legislation at the disposal of law enforcement, few human trafficking cases are ever identified (Farrell, & McDevitt, 2013).¶

In evaluating why many law enforcement agencies have identified relatively few cases, Farrell (2013) analyzed data from municipal police agencies in the United States. Her research found that despite changes in legislation, police agencies might still be unprepared to identify and respond to human trafficking locally. In part, the study found that due to theoretical and practical barriers with effectuating organizational change within police agencies, policy developments have not necessarily manifested into changes in practice.¶

As of 2014, The Polaris Project reported that only 32 states mandate or encourage training of law enforcement on human-trafficking crimes.’ Even when the police had received basic training about human trafficking, they generally were unable to identify a broad range of human¶

{sup}69See, e.g., Kimberly Mehlman-Orozco, Safe Harbor legislation for juvenile victims of sex trafficking: A myopic view of improvements in practice. 3 Social Inclusion, 52.62 (2015).¶

TO Mehlman-Orozco, K. B., Safe Harbor legislation for juvenile victims of sex trafficking: A myopic view of improvements in practice, Social Inclusion, Open Access Journal, 3.1: 52-62 (2015).¶

{sup}71 2014 State Ratings on Human Trafficking Laws (2015), Polaris Project httris://polarispro iectortdwocontent/uploads/20 I 9/09/2014-State-Ratings.pd f.¶

trafficking.72 Law-enforcement officials often struggle to distinguish human-trafficking crimes from other previously existing crimes such as prostitution. As a result, law enforcement commonly misclassifies human-trafficking victims as offenders.73¶

To retroactively correct the erroneous criminalization faced by human trafficking victims in the criminal justice system, an increasing number of states have passed vacatur statues.74 These laws provide post-conviction relief for survivors of human trafficking by completely erasing criminal convictions related to their victimization. By one count, 18 states had passed vacatur statutes and another 10 states had enacted partial vacatur laws by 2017.75¶

Ultimately, misidentifications of trafficking crimes and other sexually based offenses by law enforcement were even more prevalent durin the alle ed victimization period in this case. To this effect, it is no surprise that Epstein survivor has been very vocal in criticizing law enforcement’s “minimal action,” despite receiving reports in 1996, 2006, 2008, and 2011.76 According to attorney, Jennifer Freeman, had law enforcement intervened, the subsequent sexual victimizations “could have been avoided.”¶

Although there is a reasonable expectation for law enforcement to respond to overt reports of sexual victimization, that apparently did not occur in the present matter. And while there was no such overt disclosure made by any victim to any employee of JPMC, it appears as though the Plaintiff and the Plaintiff’s named experts are attempting to hold private businesses such as banks to a higher standard. Still, even though “best practice” indicators for trafficking were not yet available to the financial services industry and there was no legal requirement to do so, JPMC chose to end their banking relationship with Epstein six years before he was indicted for sex trafficking. This is particularly impressive, considering at that same time “local police were¶

{sup}72 Farrell, A. & Pfeffer., R., Policing Human Trafficking: Cultural Blinders and Organizational Barriers, The ANNALS of the American Academy of Political and Social Science (2014); Gallagher, A. & M, P., Developing an Effective Criminal Justice Response to Human Trafficking: Lessons from the Front Line, International Criminal Justice Review (2008). retrieved from:¶

Wilson, J.M. & Dalton, E., Human Trafficking in the Heartland: Variation in Law Enforcement Awareness and Response, Journal of Contemporary Criminal Justice, pp. 296-313 (2008).¶

T7 Farrell, A., =, C., & McDevitt, J., New laws but few cases: understanding the challenges to the investigation and prosecution of human trafficking cases, Crime, Law and Social Change, 661, 139-168 (2013); Farrell, A., Pfeffer, R., & Bright, K., Police perceptions of human trafficking, Journal of Crime and Justice, 38(3): 1-19 (2015).¶

{sup}&quot; Mehlman-Orozco, K. B. & Hedlin, S., Mehlman-Orozco, Hedlin: Stop criminalizing victims of sex trafficking, The Houston Chronicle (Jan. 19, 2017), retrieved from: hitps://www.houstonchroniele.com/opinion/outlook/anicle/Mehlman-Orozeo-Fledlin-Stop-criminalizing-10869881.php.¶

{sup}13 Rabjan, J., State Advocacy. Fact Sheet: Vacatur Laws, National Council of Jewish Woman, retrieved from: hups://www.ncjw.org/wp-content/uploads/2017/07/Fact-Sheet Vacatur-Laws Updated-2016.pdf.¶

T6 Briquelet, Kate, Epstein Victim Demands FBI Investigate Its Failur to top Him, Daily Beast (May 2, 2023), retrieved from: httos://wsmthedailvbeast.comfeestein-victi emands-fbi-investizate-its-failure-tostop-him.¶

T7 id.¶

confused about what human trafficking is.”78 This confusion, coupled with cultural blinders and organizational barriers has further inhibited law enforcement’s ability to identify possible trafficking situations and effectively/rapidly intervene. Nevertheless, even in the absence of evidence based indicia, JPMC elected to exit Epstein in 2013.¶

Misidentification by Healthcare Providers¶

Similar to law enforcement officers, the likelihood of medical and mental health providers successfully identifying a victim is also very low. Training on human trafficking for these professionals is correspondingly not evidence-based or universally mandated. For example, in Psychiatry’s Role in the Management of Human Trafficking Victims: An Integrated Care Approach, which was published in 2018, the authors wrote that “Victims are often underrecognized and there are few guidelines for how best to identify, care for, and safely reintegrate victims back into the conrmunity.s79 Additionally, the authors found that there were no integrated care models that provide decisional guidelines at different points of intervention for human trafficking patients. In another article, What are the Human Trafficking Policies of Professional Medical Organizations?, which was published in 2021, the authors wrote that “human trafficking is an international public health concern in which healthcare professionals are in a unique position to intervene. It is unclear how professional medical organizations have responded to the need to identify and assist trafficked patients.”80 Even in 2021, only eight out of 265 national medical organizations had policies regarding human trafficking and “although human trafficking is recognized as a public health issue, research on the health effects of human trafficking and best intervention practices is limited.”61¶

Failed opportunities for identification by medical professionals are a common experience by most victims of trafficking, especially considering that it is estimated that 88% of trafficking victims reported seeing an accredited healthcare professional during the time that they were trafficked.’¶

While the “red flags” of trafficking that can be screened for in medical are not empirically supported by rigorous and reliable research, they are beginning to be referred to as “best practices” and are being included in trainings and published guidance. For example, “best practice” indicia may include pelvic trauma, neglected care, and even “tattoos indicating ownership or sex work;” which include “names,” “dollar signs,” “references to money,” and “tattoos on the neck or pelvis,”¶

{sup}&quot; Farrell A. & Pfeffer R., Policing Human Trafficking: Cultural Blinders and Organizational Barriers, The Annals of the American Academy of Political and Social Science 60, 653:46, (2014) Retrieved from: hti,.m.sagepub.com/content/653/1/46.¶

i9 Mollie, et al., Psychiatry’s Role in the Management of Human Trafficking Victims: An Integrated Care Approach, Journal of Psychiatric Practice, 24.2, p. 79-86 (2018).¶

m Fang, S., et al., What are the Human Trafficking Policies of Professional Medical Organizations?, Journal of Human Trafficking (2021), retrieved from: hups://www.tandfonline.com/doifabs/10.1080/23322705.2019.1698895.¶

{sup}8I Jain, J., et al., Creating a collaborative trauma-informed interdisciplinary citywide victim services model focused on health care for survivors of human trafficking, Public Health Reports 137.1_suppl: 30S-37S (2022).¶

ar Mollie, Human Trafficking: In Plain Sight — Health Care Response to Trafficking: Recognize, Respond & Refer, retrieved from: https://www.voutubc.com/watch?v=nJxtfN9siLY.¶

among others.{sup}83 It should be noted that none of Epstein’s purported{sup}84 victims exhibited these indicia and those who were seen by medical health providers, such as [REDACTED]{sup}85, [REDACTED]{sup}86, {sup}87 were apparently not identified as victims during those interactions.¶

Ultimately, the medical and mental health communities have not yet adopted and/or generally accepted any particular indicia for identifying victims of trafficking. At present, I am not aware of any medical “red flags” that were detected by any third party during the alleged victimization period in this case, nor would a “red flag” for the medical or mental health setting be appropriate to assess in a business setting. Moreover, like most service providers, private businesses, and members of the public, health care providers often have misconceptions and stereotypes about what trafficking looks like and these pre-judgements can impede identification.¶

{sup}83 Fang, S., et al., Tattoo recognition in screening for victims of human trafficking, The Journal of Nervous and Mental Disease, 206.10: 824-827 (2018). Note: none of these are sufficiently alleged in the present complaint.¶

{sup}84 Note: The word purported is used here because, while Epstein clearly victimized some unknown number of women and girls, some of Epstein’s known victims are alleging that co-conspirators are secondarily exploiting the current situation and are erroneously self-identifying as victims, even though they facilitated his crimes. It would do a disservice to true victims to group actual survivors of Epstein’s sexual assaults with those who are alleged to have facilitated his crimes. Specifically, for example, [REDACTED] accuses [REDACTED] are alleged by various sources to have been co-conspirators, not victims, and [REDACTED] accuses [REDACTED] of being a co-conspirator.¶

{sup}85 ESTATE_JPM018244 (ledger reflecting medical treatment for [REDACTED])¶

{sup}86 ESTATE_JPM005201 (Apr. 14, 2009 email regarding medical treatment for [REDACTED]; ESTATE_JPM017420 (Apr. 29, 2010 email regarding medical treatment for [REDACTED]))¶

{sup}87 ESTATE_JPM005238 (email from [REDACTED] to Epstein regarding medical treatment).¶

VI. MISIDENTIFICATIONS AS SENTINEL EVENTS¶

Opinion¶

Missed opportunities for intervention and misidentification can be considered sentinel events and research on sentinel events is antithetical to the approach by Plaintiff’s named experts in the present matter. Hindsight bias should not be used implicate blame or impart culpability, but instead to identifit root causes and inform solutions.¶

Basis¶

As discussed in Supra Section IV, human trafficking is a clandestine crime, which is difficult to identify, even for trained law enforcement. Moreover, there is little research available to support any particular indicia or intervention. Even less information was available at the time of the alleged victimization period in this case regarding the “best practices” of human trafficking identification and interventions for businesses. As a result, unwitting encounters of trafficking crimes are best conceptualized as sentinel events.¶

“Sentinel events” can be generally defined as occurrences that signal the need for immediate investigation and response.” These occurrences are unexpected, adverse, and typically blamed on operator errors. An operator error can be defined as a mistake made by the human user of a complex system. An operator error proliferated through an organization or across agencies can manifest into a sentinel event. However, the effects of normal operator errors can be potentially contained with appropriate institutional safeguards; thus reducing the risk of mistake proliferation into a fullblown sentinel event. Originating from the medical field, sentinel event reviews provide the opportunity to analyze the root causes of these errors and identify mechanisms for reducing future risk.¶

Charles Perrow’s Normal Accident Theory is used to conceptualize organizational structures that contribute to the proliferation of sentinel events in certain organizations.89 With the criminal justice backdrop,90 human trafficking victims are identified as an underserved victim population, whom are adversely affected by a number of sentinel events, including misidentification and erroneous criminalization. Missed opportunities for intervention can also be viewed as “sentinel events.”¶

With 20/20 hindsight, observers and/or administrators are inclined to point out what an actor should have done differently.91 In fact, according to Charles Perrow (1999) 60-80 percent of accidents are attributed to “operator error.” However, this blame placing fails to recognize the underlying issues that may contribute to the process of a normal mistake manifesting into a¶

{sup}22For example, see New York State. Sentinel Events. Office of Mental Health. Available here: https://omh.ny.goviomhweb/dqnVbqi/sentinel events.html¶

{sup}29 Perrow, C. (1999). Normal accidents: Living with high risk technologies. Princeton University Press.¶

{sup}&quot; See, for example, =, J. M. (2010). Learning from error in American criminal justice. .1. Crim. L. & Criminology, 100, 109.¶

Perrow, C. (1999). Normal accidents: Living with high risk technologies. Princeton University Press.¶

sentinel event. While an operator error may be erroneously accused of being the proximate “cause” of an accident,{sup}92 these errors may not be the root cause. In response to sentinel events, operators often become the scapegoats, even though their actions were not the root cause.¶

Certain types of organizational systems are more prone than others to sentinel events. According to Charles Perrow (1999) organizations with complex, tightly coupled, and interdependent systems are more likely to have normal accidents proliferated throughout the organization, which in turn may result in more frequent sentinel events.{sup}93 The criminal justice system is one example of a group of organizations with complex, interdependent, and tightly coupled relationships. For example, in the criminal justice system, a mistake made by a police officer, if left unchecked, can affect the decision by a magistrate, prosecutor, jury, judge, correctional officer, and service provider. Police officers may be viewed by some as infallible, which may also contribute to the proliferation of the mistake, due to bounded rationality of other organizational actors. These types of problematic interactions are similar across disciplines. In studying the underlying processes associated with behavior, ethnographers recognize that people:¶

1. (1) Assume things are as they appear unless they have a reason to believe otherwise;
2. (2) Will be bounded by their rationality, or information they have at their disposal at the time; and
3. (3) Will assume that others see things as they do.

A bank can also be described as an organization with complex, interdependent, and tightly coupled organizational structures, which can make this type of business at risk of sentinel events. In response to this risk, JPMC had a multi-layered defense model to protect the organization against active and passive threats.{sup}94 Like any other similarly situated organization, JPMC attempted to mitigate risk through multi-layered safety and security protocols. However, given the clandestine nature of trafficking crimes, even the “best practice” barriers are recognized as being imperfect. While risks can be mitigated by using differing layers and types of defenses, also known as the “Cumulative Act Effect” or the “Swiss Cheese Effect,” these risks cannot be eliminated entirely (see Figure 5{sup}95).¶

Figure 5. “Swiss Cheese Effect” Regarding Trafficking Intervention¶

{sup}92 J. M. (2010). Learning from error in American criminal justice. J. Crim. L. & Criminology, 100, 109.¶

{sup}93 K., Dulac, N., & Leveson, N. (2004, March). Beyond normal accidents and high reliability organizations: The need for an alternative approach to safety in complex systems. In Engineering Systems Division Symposium (pp. 1-16). MIT Cambridge, [REDACTED].¶

{sup}94 Pesce Report, ¶ 4, 24-25.¶

{sup}95 Adapted from CC BY-SA 4.0¶

Ultimately, JPMC chose to end their banking relationship with Epstein in 2013 without any statutory requirement or best practice recommendation, which was six years before Epstein was indicted for a trafficking offense. Given the information that has been released since then, this sentinel event will more likely than not inform JPMC interventions moving forward, which is consistent with sentinel event research and best practices on anti-trafficking efforts.¶

VII. INDICIA AND ANTI-TRAFFICKING INTERVENTIONS FOR BUSINESSES¶

Opinion¶

Based on my education, training, experience, and research, indicia of sex trafficking are still in the process of being developed and tested for sensitivity and specificity and there is no reliable formula or common, generalizable indicia of trafficking available to private businesses.¶

Basis¶

Allegations are not actionable and, if not properly investigated and validated by a trier of fact in a court of law, can result in misidentification and legal consequences.¶

For example, take the cases of Charlie Chaplin, Jack and Eleanor Charlie Chaplin was accused—and later acquitted—of trafficking after paying his mistress’s train fare to New York, following an investigation intended to generate negative publicity about him over his suspected political leanings.96 Jack was convicted—and posthumously pardoner—of traffickini following racially motivated prosecutions under the Act.98 More recently, Eleanor false allegations that she was raped and trafficked across the United Kingdom by an Asian gang led to the arrest of multiple men who later said their lives had been ruined.”¶

Given the lack of reliable formula or common, generalizable indicia of trafficking for private businesses, these are just some examples of the dangers associated with interventions catalyzed by allegations alone, especially against celebrities or persons with a public profile.100¶

At the time of the alleged victimization period in this case, there were no evidence-based interventions to reliably identify sex trafficking. This applies not only to the financial services industry, but as discussed previously to law enforcement and direct service providers, such as medical and mental health care providers as well.¶

{sup}96 Weiner Eric The Lon Color I Histo o the arch 11 2008 retrieved from:¶

Eligon, John and Michael D. Shear, Trum Times (May 24, 2018), retrieved from: trumo.html. Pardons Jack Heavvwer ht Basin Chant ion. The New York¶

{sup}98id.¶

{sup}94 McCain Phil, Eleanor The grooming gang lies that sparked outrage, BBC (Jan. 3, 2023), retrieved from: https://vrem.bbc.cominews/uk-england-cumbria-64150026.¶

{sup}100 It should also be noted that related to the present matter Epstein survivor publicly accused attorney Brad of actions consistent with secondary exploitation and accused his partner, Stan Porringer, of sexual harassment. This also underscores the need t validate allegations before tion. See, e.g., htt s://www.tiktok.c rei https://www.tiktok.comgd¶

Within the field of criminology, it is generally accepted that randomized controlled trials (experiments) are considered the gold-standard—the highest quality research—for evaluating the effectiveness of an intervention. In order to promote more evidence-based interventions to effectively combat crime, criminologists have taken a distinct “experimental turn” and the sheer number of quantitative experiments in criminology has increased dramatically in recent decades.101 Most evidence-based criminological interventions have dozens of experiments supporting their efficacy. For example, Braga, Welsh, and Schnell (2015) conducted a meta-analysis of 30 randomized experimental and quasi-experimental tests of disorder policing.102 However, there is remarkably less research evaluating the efficacy of human trafficking interventions, including trainings.¶

In an assessment of extant research, Van der Laan et. al. (2011) conducted a systematic review of evaluations for interventions aimed to prevent and suppress trafficking in human beings in conjunction with the Collaboration.103 The search identified 144 studies, but there was no methodologically rigorous evaluation of interventions aimed to prevent and suppress trafficking in human beings.1°Therefore, the researchers could not draw any conclusions on actual outcomes or impacts of these interventions.”¶

In order to be considered “high quality,” a study would at least need to have a level 3 on the Maryland Scientific Methods Scale (SMS) (see Table I).¶

Table 1. Maryland Scientific Methods Scale (SMS)Is¶

Level	Study Design
I	Correlation between a prevention program and a measure of crime at one point in
2	Measures of crime before and after the program, with no comparable control
3	Measures of crime before and after the program in experimental and comparable
4	Measures of crime before and after the program in multiple experimental and control
5	Random assignment of program and control conditions to units.

{sup}101 Sampson, R.J., Gold Standard Myths: Observations on the Experimental Turn in Quantitative Criminology, 3. Quantitative Criminology, 26,489-500 (2010), retrieved from: bups://doi.org/10.1007/s10940-010-9117-3.¶

{sup}102 Braga, A. A., Welsh, B. C., et al., Can Policing Disorder Reduce Crime? A Systematic Review and Metaanalysis, Journal of Research in Crime and Delinquency, 52(4), 567-588 (2015), retrieved from: hit s://doi.or 10.1177/0022427815576576.¶

{sup}103Collaboration is a social science research network that produces high quality, open access evidence synthesis in the field of criminology.¶

No study was at least level 3 of the Maryland Scientific Methods Scale (SMS), i.e., a controlled design with both pretest and posttest measures and comparable control conditions.¶

{sup}103 Van der Laan, P. H., Smit, M., et al., Cross-border Trafficking in Human Beings: Prevention and Intervention Strategies for Reducing Sexual Exploitation, Systematic Reviews (2011).¶

ms Farrington, D. P., Gottfredson, D. C., et al., The Maryland Scientific Methods Scale. In Evidence-Based Crime Prevention, pp. 27-35, Routledge (2003).¶

However, at present, I am not aware of even a single published Level 1 study evaluating the efficacy of the human trafficking victim identification protocols and/or “red flags” espoused by the Plaintiff’s named experts. In fact, none of the Plaintiff’s named experts can cite any rigorous research to support the contention that there was even a single evidence-based red flag overlooked by JPMC. This is because, even in 2023, researchers acknowledge that the accuracy of trafficking indicators, such as The Blue Campaign, have not been tested for accuracy or reliability and their use is based on nothing more than an assumption that the content included appropriately depicts trafficking crimes107—an assumption that is not even supported by anecdote.¶

At present, instead of relying on state of the science research methods, businesses, service providers, and other practitioners are limited to implementing speculative “best practices” with relatively unknown efficacy. At the same time, a growing number of qualitative and anecdotal data suggests that there are significant issues with misidentification, as discussed further below.¶

Affected Industries¶

In 2018, the anti-trafficking non-profit Polaris Project released a report entitled On-Ramps, Intersections, and Exit Routes: A Roadmap for Systems and Industries to Prevent and Disrupt Human Trafficking, which included a section on recommendations for Financial Institutions.108 The survey included only 127 respondents and was not regulated by any institutional review board (IRB) process, which is standard practice for empirical research involving human subjects. While a nationwide sample of 127 respondents is too small to draw any generalizable inferences and the methodology was limited,109 resulting in empirically unreliable data, some purported experts rely upon the findings of this study when discussing industries affected by sex trafficking.¶

The report identified eight industries that encounter human trafficking crimes:¶

{sup}107 Savoia, E., et al. A Quasi-Experimental intervention Trial to Test the Efficacy of a Human Trafficking Awareness Campaign: The Blue Campaign, Journal of Human Trafficking (2023): 1-20.¶

l” Polaris Project, On-Ramps, Intersections, and Exit Routes: A Roadmap for Systems and Industries to Prevent and Disrupt Human Trafficking (July 2018), retrieved from: httos://oolarisoroiect.oreiwo-content/uoloads/2018/08/A-Roadmap-for-Systems-and-Industries-to-Prevent-and-Disrupt-Human-Trafficking.pdf.¶

{sup}10D For example, the survey was completed online and respondents were not asked for any kind of confirmation of victim status. Respondents were not selected randomly and were compensated for their participation. Results did not account for social desirability bias, nonresponse bias, or sampling bias.¶

1. 1. Financial Services;
2. 2. Housing and Homelessness Systems;
3. 3. Social Media;
4. 4. Temporary Work Visas;
5. 5. Transportation;
6. 6. Business Regulatory Systems;
7. 7. Healthcare; and
8. 8. Hotels and Motels.

Of those different industries, Financial Services Industry encountered the most diverse forms of trafficking (see Figure 6).¶

However, the reality is that human trafficking is a clandestine crime. Traffickers go to great lengths to conceal their activities from third parties. Therefore, even though a variety of industries may encounter trafficking victims on their platforms or premises, more often than not these encounters are obscured.¶

Figure 6. Polaris Project Matrix on Human Trafficking Types by Industry¶

Even in industries where businesses and service providers physically encounter victims of sex trafficking, misidentification is prevalent. Law enforcement, medical and mental health professionals, transportation staff, hoteliers, and beauty professionals are all at risk of unwittingly encountering victims of human trafficking; however, there are no reliable, evidence-based indicators available to any of these industries.¶

Human Trafficking “Indicators” in Aviation¶

For example, the FAA Extension, Safety, and Security Act of 2016, requires air carriers to provide initial and annual flight attendant training regarding recognizing and responding to potential human trafficking victims. The Blue Lightning Initiative (BLI), led by the Department of Transportation, the Department of Homeland Security, and U.S. Customs and Border Protection, is an element of the DHS Blue Campaign. The BLI trains aviation industry personnel to identify¶

potential traffickers and human trafficking victims, and to report their suspicions to federal law enforcement.¶

The BLI training was developed based on feedback from aviation industry “experts” and human trafficking survivors. The training is 25 minutes in length, and is comprised of four lessons that include:¶

• I. What is Human Trafficking?;
• 2. Indicators of Human Trafficking Activity;
• 3. Reporting Suspected Human Trafficking; and
• 4. Indicator Challenge.10

One of the supposed “indicators” or “red flags” that airlines were trained on was “a non-genuine relationship; particularly parent/guardian-child” (sec Figure 7).’” However, there was absolutely no empirical evidence to support this “indicator” or “red flag” as being a valid sign of trafficking and anecdotal evidence suggests that it may have remarkably low rates of specificity.¶

According to multiple airline patrons, employees began falsely accusing and/or initiating investigations for trafficking against predominately mixed-race passengers, even though they were law abiding (for examples, see Table 2).¶

INDICATORS OF HUMAN TRAFFICKING¶

a you notice a person or group of people’¶

No cc- No freedo—… identthcanon/documents social inte,,.¶

Difficulty anculafing reascoabletIcsocat travel plans¶

A non-genuine relabonsnto PaniCulanY parent/guarthan-chld¶

Figure 7. Blue lightning Initiative for Aviation Personnel “Indicators”¶

Table 2. Examples of Human Trafficking “Red Flag” Indicia Resulting in False Allegations and Claims of Racial Profiling¶

Case Name/Number Year	Allegations
2019 Plaintiff Peter DelVecchia (“Peter”) and his twelve-year old son, Plaintiff
African-American. Defendant	then falsely accused Peter of
ails of the complaint, the assault and the accusations were based on
belief that an older	man should not be traveling with a
younger black child.	had discussed these beliefs with the rest of the

{sup}&quot; U.S. Dep’t of Transportation, Blue Lightning Initiative, retrieved from: https://www.transportation.gov/administrations/officc-policy/blue-lightning-initiativc.¶

III Blue Lightning Initiative, A Guide for Aviation Personnel to Recognize and Report Suspected Human Trafficking, retrieved from: http://hiddeninplanesight.org/wp-content/uploads/afa-cobranded-blue-lightning-pocketguide-5.pdf.¶

Case Name/Number Year	Allegations
A.D.	then forced A.D. to leave his scat and father. He was forced to
N/A 2021 Mary	of Los Angeles and her 10-year-old dau hter Moira,
	were flying to Denver. When they arrived in Denver, said, she
	and her daughter were met on the jetway by two Denver police officers.
flight attendant.” which	believed was racial rofilin .I13
N/A 2021 Lakeyjanay	a 21-year-old Black woman, was travellm et Denver
	to Dallas with her 4-year-old adoptive sister, Olivia, who is . When
N/A 2015	Kathleen Chan and Jay Serrano are residents of Astoria, Queens, who were
trafficking,’ Is	even though the couple were in a consenting adult
N A 2017 Brian =,	from Arizona, was travelling back from a trip to Florida with
couple adopted from China. Mr.	said as the family got off their

{sup}112 See case information, retrieved from: https://casetext.com/case/delvecchia-v-frontier-airlines-l.¶

{sup}&quot;3 Tenn, S. & G., Mom says Southwest Airlines thought she was trafficking her biracial daughter, CNN (Nov. 8, 2021), retrieved from: https://www.cnn.com/2021/11/07/us/southwest-airlines-human-traffickingaccusation/index.html.¶

{sup}&quot; Wang, B., Black Aurora woman questioned for trafficking-sister at Dallas airport, Denver? (July 21, 2021), retrieved from: https:/Avww.thedenverchannel.com/newslocal-news/black-aurora-woman-questioned-fortrafficking-M-sister-at-dallas-airport¶

us Nolan MI E., Another Asian Air Traveler Detained Over Suspicions She’s Being Sex Trafficked, Reason (Jan. 14, 2016), retrieved from: https://reason.com/2016/01/I 4/another-asian-woman.detained-at-airport/.¶

{sup}16News.com.au, Man wrongly accused of human trafficking teenage daughter, (Dec. 22, 2017), retrieved from: hits://www.news.com.auAravel/travel-updates/incidents/man-wrongly-accused-of-human-trafficking-teenagedaughter/news-storv/0b54 I 932de32ad24c66894fd86bc7ce4.¶

Case Name/Number	Year	Allegations
N/A	2017	Osvaldo Maciel had been flying back to New York from a trip to Cancun to visit family with his fairer skinned young daughter on March 1, when another passenger accused him of child trafficking. When the plane touched down at Newark Airport, Mr. Maciel and his daughter were allegedly approached by a number of officers from the Port Authority and Customs and Border Patrol, escorted off the plane and interrogated. Mr. Maciel’s wife stated the incident was based on nothing more than a racially charged observation. {sup}117

Additionally, persons erroneously accused of trafficking and/or reported to the police as victims have started to file lawsuits alleging defamation. For example, Marcia Festen and E.L. recently filed a lawsuit against Eastside Medical Center LLC, Robin Lowman Elizabeth Davlantes, and Jane Marilyn Pineda on July 3, 2022 (Case No. 1:22-cv-02646-MHC) in the United States District Court Northern District of Georgia Atlanta Division asserting claims of defamation, slander and libel because E.L. was erroneously reported to the police as a suspected victim of trafficking.¶

Ultimately, although anti-trafficking training and interventions may be well-intentioned, they are largely untested or unsupported by rigorous empirical research. Extant information suggests that many “indicia” have low rates of specificity and misidentification, as well as missed opportunities for intervention, persist.¶

Human Trafficking “Indicators” in Hospitality¶

Similar to the guidance for the financial services industry and the aviation industry, the Department of Homeland Security Blue Campaign toolkit for identifying human trafficking in the hospitality industry is not considered evidence based either.¶

The Blue Campaign published a hospitality toolkit in 2016 that featured four sets of “indicators,” which were developed without any empirical testing or validation,118 for different types of staff:¶

• I. Hotel and Motel Staff;
• 2. Housekeeping, Maintenance, and Room Service Staff;
• 3. Concierge, Bellman, Front Desk, Security, and Valet Staff; and
• 4. Food and Beverage Staff.

This toolkit includes a number of “general indicators,” which lack any empirical support, for examples, see Table 3.¶

News.com.au, Father interrogated for child trafficking because his daughter did not look like him, (Apr. 21, 2017), retrieved from: httns:thvww.news.contatiltravel/travel-undatesiincidents/father-interrozated-for-childtraffacking-because-his-daughter-did-not-look-like-himinews-story/dad68db2c0d0a3425a80b0k545fa245.¶

{sup}18 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 on premises.¶

Table 3. Sample of Blue Campaign “Indicia” and Countervailing Information¶

Applicable Staff	Blue Campaign “General Indicator”	Countervailing Information
All hotel and motel staff	Individuals have few or no personal items—such as no luggage or other bags.	There is no empirical evidence to support this purported “indicum.” Publicly criticized for potentially ensnaring female travelers traveling alone, particularly for business. {sup}119
Housekeeping, Maintenance, and Room Services	Refusal of cleaning services for multiple days.	There is no empirical evidence to support this purported “indicum.” Particularly following the COVID pandemic, refusal of cleaning services is common and, for disease safety, many hotels did not/do not provide it without explicit request.
Housekeeping, Maintenance, and Room Services	Smell of bodily fluids and musk.	There is no empirical evidence to support this purported “indicum.” Publicly criticized for potentially ensnaring sexual activity between consenting adults and violations to rights to privacy. {sup}120
Housekeeping, Maintenance, and Room Services; as well as Concierge, Bellman, Front Desk, Security, and Valet Staff	The same person reserving multiple rooms.	There is no empirical evidence to support this purported “indicum.” Larger families with more than four people, including my own, reserve multiple, adjacent rooms.
Housekeeping, Maintenance, and Room Services	Evidence of pornography.	There is no empirical evidence to support this purported “indicum.” Publicly criticized for potentially ensnaring sexual activity between consenting adults and violations to rights to privacy. {sup}121
Housekeeping, Maintenance, and Room Services	Provocative clothing and shoes.	There is no empirical evidence to support this purported “indicum.” Publicly criticized for policing adult female clothing choice and violations to rights to privacy. {sup}122
Housekeeping, Maintenance, and Room Services	Excessive amounts of sex paraphernalia in rooms (condoms, lubricant, lotion, etc.)	There is no empirical evidence to support this purported “indicum.” Publicly criticized for potentially ensnaring sexual activity between consenting adults and violations to rights to privacy. {sup}123
Concierge, Bellman, Front Desk, Security, and Valet Staff	Room paid for with cash or pre-loaded credit card.	There is no empirical evidence to suggest that paying cash for a room is a reliable indicum of trafficking. Moreover, this is a common need for

¹¹⁹ See, for example: Nolan [REDACTED], E., Are You a Woman Traveling Alone? Marriott Might Be Watching You, Reason (2019), retrieved from: https://reason.com/2019/02/05/hotel-surveillance-state-sex-trafficking/; Song, S., When Anti-Sex Trafficking Policies like the Marriott’s Do More Harm Than Good, Paper Magazine (Jan. 30, 2019), retrieved from: https://www.papermag.com/marriott-hotels-sex-trafficking-training-2627520121.html?rebelltitem=9#rebelltitem9.¶

{sup}120 Id.¶

{sup}121 Id.¶

{sup}122 Id.¶

{sup}123 Id.¶

Applicable Staff	Blue Campaign “General Indicator”	Countervailing Information
		homeless populations, as well as for survivors of domestic violence and other persons in need of emergency and temporary housing. Claiming that “accepting cash” is an indication of human trafficking is not only unsupported by empirical research, but suggests an elitist, unreliable, and subjective perception of reality. Denying rooms to homeless populations, simply due to mode of payment, can have legal repercussions. {sup}124
Concierge, Bellman, Front Desk, Security, and Valet Staff	Individuals leaving room infrequently, not at all, or at odd hours.	There is no empirical evidence to support this purported “indicum.”

Ultimately, given the lack of qualitative or quantitative evidence to support the efficacy of these purported “indicia” and interventions, they should be applied cautiously, if at all. While these so-called “indicia” have not been adequately empirically tested, extant reliable principles and scientific methods suggest that implementation and training of these “indicia” will have no bearing on a business’s ability to prevent, identify, or intervene against human trafficking on premises and may actually result in high rates of false accusations. At present, any suggestion otherwise is based on unsupported speculation or subjective belief.¶

Sensitivity and Specificity¶

Measures for sensitivity and specificity are basic tenets for evaluations of screening tools and interventions across disciplines. For example, in the field of criminology, these measures have been used to evaluate models and instruments regarding the prediction of violent re-offending{sup}125 and to evaluate screening tools for assessing risk of suicide and self-harm among adult offenders.{sup}126 These measures are generally accepted and recognized across disciplines as being appropriate for evaluating the reliability of performance factors, which is why various scholars, including myself, have noted the need for research to refine purported human trafficking indicators and “to develop and test the sensitivity and specificity of screening tools to identify victims of human trafficking” in a variety of settings (e.g., law enforcement, healthcare, social work, beauty, transportation, banking, hospitality, agriculture, etc.).{sup}127¶

¹²⁴ In Ireland, a homeless family was awarded €22,000 in compensation after a hotel refused to honor their booking without a credit card. See Lucey, S., Hotel discriminated against homeless family by demanding credit card, Irish Legal News (Mar. 2, 2022), retrieved from: https://www.irishlegal.com/articles/hotel-discriminated-against-homeless-family-by-demanding-credit-card.¶

{sup}125 DeLisi, Matt, and Michael G. Vaughn. The Gottfredson–Hirschi critiques revisited: Reconciling self-control theory, criminal careers, and career criminals. International Journal of offender therapy and comparative criminology, 52.5, 520-537 (2008).¶

{sup}126 Amanda E., et al. Screening tools assessing risk of suicide and self-harm in adult offenders: a systematic review, International Journal of Offender Therapy and Comparative Criminology, 54.5, 803-828 (2010).¶

¹²⁷ See, for example, Hemmings, Stacey, et al. Responding to the health needs of survivors of human trafficking: a systematic review, BMC Health Services Research 16.1, 1-9 (2016), retrieved from: https://bmchealthservres.biomedcentral.com/counter/pdf/10.1186/s12913-016-1538-8.pdf.¶

Although the efficacy of available interventions for sex trafficking victim identification and thirdparty intervention is relatively unknown, I can, to a reasonable degree of social scientific certainty, opine that many of the “red flags” touted by the Plaintiff’s proposed experts have low rates of sensitivity and specificity.¶

Specifically, the Plaintiff’s named experts claim that large cash withdrawals and payments from one individual to a another are indicia or sex trafficking. For example, in her report, Ms. Carr writes:¶

“In my opinion, the indictment combined with the previous knowledge of accusations of Epstein’s use of cash to pay for sex with minors plus the scope of his cash withdrawals are extremely strong, if not conclusive, indications of sex trafficking. ” {sup}128¶

Not only does Ms. Carr fail to provide any empirical basis for her conclusion, but these purported “indicia” are completely absent from “best practice” guidance documents on anti-trafficking interventions for the financial services industry that were available at the time of the alleged victimization period, as well as apparently absent from those that were developed thereafter. Additionally, based on my research, education, and experience, these purported indicia are hypothesized to have low rates of sensitivity and specificity.¶

Herein, the term sensitivity is defined as the ability of law enforcement, service providers, and other third parties to correctly identify true victims of human trafficking (true positive). The term specificity refers to the ability of law enforcement, service providers, and other third parties to correctly identify persons who are not victims of human trafficking (true negative).¶

In regard to sex trafficking victim identification, low sensitivity means that even if these protocols were implemented, victims of human trafficking would continue to be misidentified as nonvictims, criminals, or co-conspirators. Low specificity means that even if these protocols were implemented, persons who are not victims of human trafficking would be misidentified as being possible victims.¶

These hypotheses are informed by my background, training, and expertise on the high rates of misidentification of victims even by trained professionals, including law enforcement. Moreover, there is a growing body of civil litigation regarding misidentification resulting from misguided “red flag” training on human trafficking.¶

A human trafficking “red flag” training or indicia with low specificity can be criticized as being too eager to find a positive result, even when it is not present. Implementing a human trafficking “red flag” training or indicia that has not been tested for sensitivity or specificity could result in false accusations/investigations of human trafficking against law abiding citizens.¶

{sup}123 Carr Report, ¶ 86.¶

Ultimately, although anti-trafficking training and interventions may be well-intentioned, they are largely untested or unsupported by rigorous empirical research. Extant information suggests that many “indicia” have low rates of specificity and misidentification, as well as missed opportunities for intervention, persist. More importantly, there is no reliable, empirical, or evidentiary basis for the legal conclusions leveled by the Plaintiffs named experts or the allegation that cash withdrawals are an indication of sex trafficking, much less a strong or conclusive indicator. It is more likely than not that even ifJPMC had instituted an additional screening requirement for “cash withdrawals” on “high risk” clients, it would have had no measurable impact on Epstein’s criminal activity.¶

VIII.”BEST PRACTICES” IN THE FINANCIAL SERVICES INDUSTRY¶

Opinion¶

There is no reliable formula or common, generalizable indicia that JPMC could have used to make an actionable determination of trafficking in this particular case. Additionally, although there is no reliable intervention that JPMC could have used to prevent Epstein’s criminal activity, JPMC nevertheless chose to end the banking relationship with Epstein six years prior to his trafficking indictment for alleged pre-2006 conduct.¶

Basis¶

The potential “indicators” of trafficking advised to the financial services industry by various organizations have not been empirically validated and include very few “signs” that would typically catalyze law enforcement intervention.¶

Moreover, as previously discussed, the Plaintiff’s own named expert acknowledges that “the framework of legislation, regulations, and other measures needed to engage companies in the eradication of human trafficking…(was) still in the early stages of development’ in 2014.129 This is consistent with the fact that, although the TWA was passed in 2000, the majority of guidance for businesses was released after 2014 (see, for examples, Figure 8), but has yet to be empirically tested for sensitivity and specificity.¶

{sup}12° Emphasis added. Cam Bridgette, et al., Human trafficking law and policy, LexisNexis, p. 181 (2014)..¶

Figure 8. Sample of Human Trafficking Awareness and the Banking Industry 2000 to Present¶

For example, in 2009, the United Nations Office on Drugs and Crime published a fact sheet on human trafficking. While the fact sheet mentioned that “no industry or economic sector is immune to human trafficking,” it omitted any reference to banks, much less any guidance for¶

the financial services industry.130 This is likely because data was very limited at the time. In fact, the largest data collection on crime in the United States—the FBI Uniform Crime Report (UCR)— did not even collect data on human trafficking until 2013.131 “Best practice” guidance on how the financial services industry became more widely disseminated in 2014, with the United States Department of Treasury, Financial Crimes Enforcement Network (FinCEN) Advisory on Human Trafficking,132 followed by reports by the Polaris Project,133 House Hearings134, United Nations Briefings,I35 Supplemental Guidance from FinCENI36 and a Fact Sheet from the U.S. State Department.137¶

Additionally, even in 2018, various anti-trafficking advocates were acknowledging that these purported “red flags” were constantly changing. For example, at a Congressional hearing entitled Following the Money: How Human Traffickers Exploit U.S. Financial Markets,138 Bassem Banafa, a Financial Forensics Consultant, and Tina Frundt, human trafficking survivor, as well as Founder and Director of Courtney’s House, testified that many financial institutions were collaborating with social service organizations to identify red flags of trafficking, but they were “changing constantly.”¶

Even if these purported trafficking indicia were available at the time of the alleged victimization period, which they were not, and even if these purported trafficking indicia were static and reliably based in empirical research, which they are not, it is more likely than not that these¶

D0 U.N. Office on Drugs and Crime, Human Trafficking FAQs, retrieved from: hups://www.unodc.orgiunodc/en/human-trafficking/faqs.htinl.¶

O1FBI: UCR, 2019 Crime in the United States, Human Trafficking, retrieved from: https://tter.thi.vvicrime-in-theu.s/2019/crimc-in-thc-u.s.-2019/additional-data-collectionalhuman-trafficking.¶

O2 U.S. Dep’t of Treas., FinCEN, Advisory: Guidance on Recognizing Activity that May be Associated with Haman Smuggling and Human Trafficking — Financial Red Flags, (Sept. I I, 2014), retrieved from. Ntos://www.fincen.covisitesklefaultifilesiadvisorv/FIN-20I4-A008.odf.¶

Im Polaris, On-Ramps, Intersections, and Exit Routes: A Roadmap for Systems and Industries to Prevent and Disrupt Human Trafficking, Financial Services Industry, (2018), retrieved from: https://polarisproiect.orgAvocontent/unloads/2018/08/A -Roadmap-for-Svstems-and-Industries-to-Prevent-and-Disruot-Human -Tra ffick ing-Financial-Industry.pdf.¶

{sup}134 See, e.g., Following the Money: How Human Traffickers Exploit U.S. Financial Markets: Hearing Before the Subcomm. on Oversight & Investigations of the H. Comm. On Fin. Servs., 115 Cong. (Jan. 30, 2018), retrieved from: hit s://www. ovinfo. 0v/content/ k CHRG- I I5h 31327/html/CHRG-115hh 31327.htm.¶

{sup}13\$ See, e.g., Kovick, David & Rachel, Tackling Modern Slavery and Human Trafficking at Scale Through Financial Sector Leverage, (2019), retrieved from: https://shiflprgject.org/wpcontent/uploads/2020/0I /SecretariatBriefingPaper2.pdf.¶

{sup}136 U.S. Dep’t of Treas., FinCEN, Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity, (Oct. 12, 2020), retrieved from: httos://www.fincen.uovisitesidefaultffilestadvisorv/2020-10- 15/Advisory%20Human%20Trafficking%20508%20FINAL 0.pdf.¶

{sup}&quot; {sup}7 U.S. Dep’t of State, Off. to Monitor & Combat Trafficking in Persons, The Role of the Financial Sector: Promising Practices in the Eradication of Trafficking in Persons, (June 2021), retrieved from: https://www.state.gov/wp-content/uploads/2021/06/11e-Role-of-the-Financial-Sector-Promising-Practices-in-the-Eradication-of-Trafficking-in-Persons\_LOW.pdf.¶

{sup}115 Following the Money: How Human Traffickers Exploit U.S. Financial Markets: Hearing Before the Subcomm. on Oversight & Investigations of the H. Comm. On Fin. Servs., 115 Cong. (Jan. 30, 2018), retrieved from: hups://www.govinfo.govicontentipkg/CHRG-1 5htirg31327/html/CHRG-115hhrg3 I 327.htm.¶

indicia would not have led to any intervention regarding Epstein’s crimes (for examples, see Table 4).¶

Table 4. FinCEN Red Flags of Human Trafficking: 2014{sup}139¶

FinCEN “Red Flag”: 2014	Application to Present Case
”A business customer does not exhibit normal payroll expenditures (e.g., wages, payroll taxes, social security contributions). Payroll costs can be non-existent or extremely low for the size of the customer’s alleged operations, workforce and/or business line/model.”	Not alleged and/or not supported by extant discovery.
”Substantial deductions to wages. To the extent a financial institution is able to observe, a customer with a business may deduct large amounts from the wages of its employees alleging extensive charges (e.g., housing and food costs), where the employees only receive a small fraction of their wages; this may occur before or after the payment of wages.”	Not alleged and/or not supported by extant discovery.
”Cashing of payroll checks where the majority of the funds are kept by the employer or are deposited back into the employer’s account. This activity may be detected by those financial institutions that have access to paystubs and other payroll records.”	Not alleged and/or not supported by extant discovery.
”Transactional activity (credits and/or debits) inconsistent with a customer’s alleged employment, business or expected activity, or where transactions lack a business or apparent lawful purpose.”	Not supported by extant discovery. {sup}140
”Cash deposits or wire transfers are kept below $3,000 or $10,000 in apparent efforts to avoid record keeping requirements or the filing of Currency Transaction Reports (CTRs), respectively.”	Alleged, but JPMC filed SARs in 2002 and 2003 reporting such activity.
”A customer’s account appears to function as a funnel account, where cash deposits occur in cities/states where the customer does not reside or conduct business. Frequently, in the case of funnel accounts, the funds are quickly withdrawn (same day) after the deposits are made.”	Not alleged and/or not supported by extant discovery.
”Multiple, apparently unrelated, customers sending wire transfers to the same beneficiary. These wire senders may also use similar transactional information including but not limited to a common address and phone number. When questioned to the extent circumstances allow, the wire senders may have no apparent relation to the recipient of the funds or know the purpose of the wire transfers.”	Not alleged and/or not supported by extant discovery.
Transactions conducted by individuals, escorted by a third party (e.g., under the pretext of requiring an interpreter), to transfer funds (that may seem to be their salaries) to other countries.”	Not alleged and/or not supported by extant discovery.
Frequent payments to online escort services for advertising, including small posting fees to companies of online classifieds as well as more expensive, higher-end advertising and website hosting companies.	Not alleged and/or not supported by extant discovery.
Frequent transactions, inconsistent with expected activity and/or line of business, carried out by a business customer in apparent efforts to provide sustenance to individuals (e.g., payment for housing, lodging, regular vehicle rentals, purchases of large amounts of food).	Not alleged to be known by JPMC at the time.
Payments to employment or student recruitment agencies that are not licensed/registered or that have labor violations.	Not alleged and/or not supported by extant discovery.
A customer establishes an account or visits a branch to conduct transactions while always escorted by a third party (e.g., under the pretext of requiring an interpreter).	Not alleged and/or not supported by extant discovery.

{sup}139 As Pesce points out, “JPMC’s monitoring was consistent with FinCEN’s future guidance. If JPMC had been monitoring Epstein’s transactions against the red flags issued by FinCEN in 2014, they would not have alerted for review.” Pesce Report, ¶ 97.¶

{sup}140 While this is alleged by the Plaintiff, there is no evidence in the record or empirical evidence to support this contention.¶

FinCEN “Red Flag”: 2014	Application to Present Case
Correspondingly, the third party escorting the customer may always have possession of the customer’s ID.
Common signer(s)/custodian(s) in apparently. unrelated business and/or personal accounts. Similarly, common information (e.g., address, phone number, employment information) used to open multiple accounts in different names.	Not alleged and/or not supported by extant discovery.
Accounts of foreign workers or students where the employer or employment agency serves as a custodian.	Not alleged and/or not supported by extant discovery.
Unexplained/unjustified lifestyle incommensurate with employment or business line. Profits/deposits significantly greater than that of peers in similar professions/ business lines.	Not alleged and/or not supported by extant discovery.
Inflows are largely received in cash where substantial cash receipts are inconsistent with the customer’s line of business. Extensive use of cash to purchase assets and to conduct transactions.	Not alleged and/or not supported by extant discovery.

Based on my review of the extant discovery, the FinCEN “red flags” of human trafficking that were available in 2014 either do not appear to be consistently evident in the present case, or were not alleged to have been observed by JPMC. Six years later, in 2020, FinCEN released a Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity,{sup}141 which contained a number of “behavioral indicators” and these also are not consistently evident in the allegations regarding the present matter or are not alleged to have been observed by JPMC (see Table 5).¶

Table 5. FinCEN Behavioral Indicators of Human Trafficking: 2020¶

FinCEN “Behavioral Indicators”: 2020	Application to Present Case
A third party speaks on behalf of the customer (a third party may insist on being present and/ or translating).	Not alleged and unsupported by extant discovery.
A third party insists on being present for every aspect of the transaction.	Not alleged and unsupported by extant discovery.
A third party attempts to fill out paperwork without consulting the customer.	Alleged regarding [REDACTED].
A third party maintains possession and/or control of all documents or money.	Not alleged and unsupported by extant discovery.
A third party claims to be related to the customer, but does not know critical details.	Not alleged and unsupported by extant discovery.
A prospective customer uses, or attempts to use, third-party identification (of someone who is not present) to open an account.	Not alleged and unsupported by extant discovery.
A third party attempts to open an account for an unqualified minor.	Not alleged and unsupported by extant discovery.
A third party commits acts of physical aggression or intimidation toward the customer.	Not alleged to have been observed by JPMC.
A customer shows signs of poor hygiene, malnourishment, fatigue, signs of physical and/or sexual abuse, physical restraint, confinement, or torture.	Not alleged and unsupported by extant discovery.
A customer shows lack of knowledge of their whereabouts, cannot clarify where they live or where they are staying, or provides scripted, confusing, or inconsistent stories in response to inquiry.	Not alleged and unsupported by extant discovery.

{sup}141 U.S. Dep’t of Treas., FinCEN, Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity, (Oct. 15, 2020), retrieved from: https://www.fincen.gov/sites/default/files/advisory/2020-10-15/Advisory%20Human%20Trafficking%20508%20FINAL\_0.pdf.¶

Ultimately, the Plaintiff and the Plaintiff’s named experts can point to no policies, procedures, or internal controls employed by JPMC that were less than industry standards at the time. More importantly, the financial services industry was repeatedly recognized for its efforts to combat trafficking in persons. For example, in 2018 anti-trafficking nonprofit Polaris published a report stating, in part, “the financial services industry should be applauded for its innovative and proactive efforts to meet this challenge and continue its efforts to stay on top of shifting pattems.”142¶

Similarly, Mr. Cyrus Vance, District Attorney for New York County, also testified about “working closely with banks and financial institutions.” Mr. Vance remarked that the collaborative partnerships with banks were so effective that traffickers had turned to “alternative methods of payment” to “allow them to remain anonymous, such as prepaid gift cards and cryptocurrencies.”143 Unlike the traditional banking industry, some members of the cryptocurrency community were “specifically catering to traffickers,” according Mr. Vance, who requested legislative and regulatory solutions to address trafficking facilitation from cryptocurrency.144¶

Based on the information reviewed in this case, like much of the financial services industry, JPMC appears to have employed innovative and proactive efforts to meet the challenge of combating trafficking in persons and made efforts stay on top of shifting patterns. As proof to this point, JPMC chose to proactively end their business relationship with Epstein six years before law enforcement indicted him for any trafficking offense, even when there was no legal requirement to do so.¶

{sup}142 Polaris Project, On-Ramps, Intersections, and Erit Routes: A Roadmap for Systems and Industries to Prevent and Disrupt Human Trafficking, at p. 6I, (July 2018), retrieved from: httos://oolarisoroiect.oritiwo-¶

content/ualoads/2018/08/A-Roadmao-for-Svstems-and-lndustries-to-Prevent-and-Disruot-Human-Traffickinitxdf. “3Following the Money: How Human Traffickers Exploit U.S. Financial Markets: Hearing Before the Subcomm. on Oversight & Investigations of the H. Comm. On Fin. Servs.. 115 Cong. (Jan. 30, 2018), retrieved from: https://www.govinfo.govicontent/pkg/CHRG- II 51Thrg31327/html/CHRG-115hlirg31327.htm.¶

laId.¶

IX. ACTUAL OR CONSTRUCTIVE KNOWLEDGE¶

Opinion¶

Based on my research, education, and experience, there were no reliable indicia of trafficking available to the financial services industry during the alleged victimization period in the present matter. Moreover, there are no reliable data or research to support the conclusion that the scope of Epstein’s cash withdrawals rises to the level of establishing a private business knew or should have known that he was engaged in sex trafficking. Any suggestion otherwise is based on misinformation, unsupported speculation or subjective belief ecological fallacies, or fallacies of composition, and is counterfactual. Establishing actual or constructive knowledge in a third party liability case involving a TVPRA claim would require, at a minimum, the availability of an evidence-based and reliable indicia. However, even in the absence of reliable indicators and legal requirements JPMC chose to proactively sever the relationship with Epstein six years prior to his trafficking indictment.¶

Basis¶

In general, alleged victims of sex trafficking involving third parties may assert that there were subtle “red flags” that should have been noticed. For example, in the hotel industry, plaintiffs and purported experts may contend that asking for extra towels, turning down room service, or having multiple cell phones, “excessive” condoms, lingerie, and gift cards in the room are “red flags” of trafficking that hotel staff should have noticed and acted upon these purported indicia. Similarly, in the present matter the Plaintiff and the Plaintiff’s named experts claim that cash withdrawals and round-dollar wire payments are “strong” or “conclusive” evidence of trafficking. I am not aware of any empirical evidence to support the reliability of these “red flags” and anecdotal data suggests these that these supposed “red flags” have low rates of sensitivity and specificity145 in a business setting. Moreover, even if these purported “red flags” were reported by employees to law enforcement, most of them are not illegal and are therefore unactionable. As such, there is no evidence to support the conclusion that the scope of Epstein’s cash¶

Figure 9. Blue Lightning Initiative for Aviation Personnel “Indicators”¶

le Low sensitivity herein means that victims of human trafficking arc often misidentified as non-victims, criminals, or co-conspirators. Low specificity herein means that persons who are not victims of human trafficking are often misidentified as being victims.¶

withdrawals or round-dollar wire payments rise to the level of establishing a private business knew or should have known that he was engaged in sex trafficking.¶

In a private business setting, relying upon unsupported indicia to catalyze interventions may be impracticable and can expose the business to allegations of civil rights violations and/or defamation.¶

For instance, as previously mentioned, one of the supposed “indicators” or “red flags” that private businesses in the aviation industry were trained on was “a non-genuine relationship; particularly parent/guardian-child” (see Figure 9).146 However, there was absolutely no empirical evidence to support this “indicator” or “red flag” as being a valid indicium of trafficking and anecdotal evidence suggests that it may have remarkably low rates of specificity. According to multiple airline patrons, employees began falsely accusing and/or initiating investigations for trafficking against predominately mixed-race passengers, even though they were law abiding (for example, see DelVecchia v. Frontier Airlines, Inc., Case No. 2:19-cv-01322-ICID-NJK (D. Nev.).¶

{sup}16Blue Lightning Initiative, A Guide for Aviation Personnel to Recognize and Report Suspected Human Trafficking, Hidden in Plane Sight http://hiddeninplanesightorewp-content/uploadsfafa-cobranded-blue-lightningpocket-guide-5.pdc.¶

X. REBUTTAL¶

Bridgette Carr¶

Credentials¶

Ms. Carr is an attorney in good standing with the Michigan Bar,1°’ who has not previously testified as an expert in any trial or deposition.148 According to Ms. Carr’s resume, which is included as Exhibit A of her report, she has served as a professor at the University of Michigan Law School for the last 12 years, as well as a co-director of the human trafficking clinic and lab at the law school. While Ms. Carr certainly has a wealth of experience providing direct legal representation to victims of human trafficking and immigrants, from the information provided Ms. Cart does not appear to have the education, experience, or expertise to empirically assess the reliability of social scientific research, including that of trafficking entrapment and enmeshment schemes, indicia, and anti-trafficking interventions. Instead of applying any reliable or generally accepted methodology to inform her opinions in the present matter, the overwhelming majority of Ms. Cares report attempts to support her opinions through her anecdotal experiences and epistemic trespassing assessments of extant research, as opposed to reliable methods.¶

Methodoloev,¶

Ms. Can’s so called “methodology” is outlined on page 3, paragraphs 13-15, of her report.¶

Ms. Can claims that she will be offering opinions in four areas:149¶

• 1. How sex trafficking presents in cases in the United States;
• 2. Typical signs of human trafficking;
• 3. The power dynamics at work in human trafficking; and
• 4. How victim vulnerabilities are identified and exploited.

In support of these opinions, Ms. Carr relies upon nondescript sources of information, which she conceptualizes as “methodologies.” With regards to her generalized assessment:¶

• I. Ms. Carr applies her knowledge of human trafficking to the documents, depositions, victims’ statements, and other information to assess whether Jeffrey Epstein’s behavior and the victims’ experiences are consistent with human trafficking of minors or adults; and

{sup}&quot; 7 Carr Report, ¶ 3.¶

Hs M. 1 7.¶

{sup}149id. 13.¶

• 2. Ms. Carr applies her knowledge of human trafficking to the documents, depositions, victims’ statements, and other information to assess whether the information identified by or available to JPMorgan Chase Bank, N.A. reflects “red flags” of trafficking.‘5°

The application of Ms. Carr’s “knowledge of human trafficking” to the discovery materials does not appear to be a reliable “methodology,” but rather a subjective interpretation of discovery, which is no different than a non-scientific process employed by any trier of fact.¶

For example, with regards to her specific assessment:¶

• I. Ms. Carr first claims that she reviewed “authoritative literature” in the field of human trafficking to identify “generally accepted and reliable typologies and indicators of trafficking;s151
• 2. Next, Ms. Can claims that she applied these “typologies and indicators” to the documents and testimony that she reviewed, including documents and financial information available to, reviewed by, or created by JPMorgam152
• 3. Ms. Can• also conducted “an interview” with who she concludes is an Epstein victim, despite being previously categorized as a co-conspirator by law enforcement;153 and
• 4. Finally, Ms. Can “assess[ed]” whether the aforementioned information is “consistent with typologies and indicators of human trafficking.”154

As introduced in Section II of this report, a methodology is generally understood to reference the specific methods, procedures, or practices needed to derive or interpret data within the scope of a particular discipline. The reliability of the methodology is then dependent on the accuracy of the results, which is typically measured through the statistical consistency of the findings.¶

The reliability of Ms. Carr’s so-called methods is questionable at best for a number of reasons, which are discussed further in the section below, but include:¶

• I. Ms. Can’s review of the “authoritative literature” was not systematic or replicable. She did not perform any assessment on the methodological rigor of the research or the generalizability of the findings. Moreover, she failed to reference any research, method, or finding that could be used to assess the reliability of the “typologies and indicators of trafficking” that she references, much less any meta-analysis that would suggest a “general acceptance” or consistency of these findings;
• 2. Ms. Carr does not appear to be formally trained in conducting qualitative interviews. While she may have anecdotal experience in conducting interviews of her clients through her capacity as an attorney providing legal services to victims of trafficking, this is not

{sup}14 Id.113.¶

In M.1 14.¶

^'” M.

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. 1. Targeting of vulnerable individuals; and
2. 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. 1. Overt threats and violence; and
2. 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]	3. None of these women or girls were determined to be trafficked by Ghislaine Maxwell. 4. These individuals did receive the payments they were promised for providing massages, which is not a false pretense. 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: 1. [REDACTED] is accused by [REDACTED] of being a co-conspirator. 2. None of these women or girls were determined to be trafficked by Ghislaine Maxwell. 3. Trafficking situations can involve violence, threats, and harm for the purpose of exploitation, where an individual is induced into modern slavery, which is not consistent with the totality of the circumstances of these individuals. 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: 1. The term coercion has a very specific meaning regarding trafficking claims. It should not be interpreted as a synonym for "convincing" or "persuading", which is how Ms. Carr appears to be using it in her report.229 2. [REDACTED] is accused by [REDACTED] of being a co-conspirator. 3. None of these women or girls were determined to be trafficked by Ghislaine Maxwell. 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: 1. The term coercion has a very specific meaning regarding trafficking claims. It should not be interpreted as a synonym for "convincing" or "persuading", which is how Ms. Carr appears to be using it in her report230. 2. [REDACTED] is accused by [REDACTED] of being a co-conspirator. 3. [REDACTED] was accused of being a co-conspirator by law enforcement. 4. None of these women or girls were determined to be trafficked by Ghislaine Maxwell. 5. Ms. Carr ignores countervailing evidence to the statements. For example, that Epstein told his alleged victims what to wear and how to cut, color, and style their hair. Emails illustrate that alleged victims would ask Epstein's advice on these stylistic choices, for money and appointments to

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&quot; 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
Produced Document	CU 0161
Produced Document	CU\_0162
Produced Document	CU 0163
Produced Document	CU 0164
Produced Document	CU\_0166
Produced Document	CU\_0168
Produced Document	CU 0170
Produced Document	CU\_0172
Produced Document	CU\_0174
Produced Document	CU 0176
Produced Document	CU\_0178
Produced Document	CU\_0180
Produced Document	CU 0181
Produced Document	CU 0182
Produced Document	CU 0182
Produced Document	CU 0183
Produced Document	CU 0184
Produced Document	CU 0184
Produced Document	CU 0185
Produced Document	ESTATE\_JPM004680
Produced Document	ESTATE JPM004682
Produced Document	ESTATE JPM004692
Produced Document	ESTATE\_JPM004702

Document Type	Description
Produced Document	ESTATE JPM004703
Produced Document	ESTATE \_JPM004705
Produced Document	ESTATE\_JPM004706
Produced Document	ESTATE JPM004707
Produced Document	ESTATE JPM004708
Produced Document	ESTATE\_JPM004709
Produced Document	ESTATE JPM004710
Produced Document	ESTATE JPM004711
Produced Document	ESTATE\_JPM004714
Produced Document	ESTATE JPM004715
Produced Document	ESTATE JPM004717
Produced Document	ESTATE JPM004718
Produced Document	ESTATE JPM004719
Produced Document	ESTATE JPM004720
Produced Document	ESTATE JPM004721
Produced Document	ESTATE JPM004722
Produced Document	ESTATE\_JPM004723
Produced Document	ESTATE JPM004724
Produced Document	ESTATE JPM004725
Produced Document	ESTATE\_JPM004726
Produced Document	ESTATE JPM004727
Produced Document	ESTATE JPM004728
Produced Document	ESTATE\_JPM004729
Produced Document	ESTATE JPM004730
Produced Document	ESTATE JPM004731
Produced Document	ESTATE\_JPM004732
Produced Document	ESTATE\_JPM004733
Produced Document	ESTATE JPM004734
Produced Document	ESTATE JPM004735
Produced Document	ESTATE JPM004736
Produced Document	ESTATE JPM004737
Produced Document	ESTATE \_JPM004738
Produced Document	ESTATE JPM004740
Produced Document	ESTATE JPM004741
Produced Document	ESTATE JPM004742
Produced Document	ESTATE JPM004743
Produced Document	ESTATE JPM004744
Produced Document	ESTATE JPM004745
Produced Document	ESTATE JPM004746
Produced Document	ESTATE JPM004747
Produced Document	ESTATE\_JPM004748
Produced Document	ESTATE JPM004749
Produced Document	ESTATE JPM004750
Produced Document	ESTATE\_JPM004751

Document Type	Description
Produced Document	ESTATE JPM004752
Produced Document	ESTATE \_JPM004753
Produced Document	ESTATE\_JPM004754
Produced Document	ESTATE JPM004755
Produced Document	ESTATE JPM004756
Produced Document	ESTATE JPM004758
Produced Document	ESTATE JPM004760
Produced Document	ESTATE\_JPM004763
Produced Document	ESTATE\_JPM004765
Produced Document	ESTATE JPM004766
Produced Document	ESTATE JPM004767
Produced Document	ESTATE JPM004768
Produced Document	ESTATE JPM004769
Produced Document	ESTATE JPM004770
Produced Document	ESTATE JPM004771
Produced Document	ESTATE JPM004772
Produced Document	ESTATE\_JPM004773
Produced Document	ESTATE JPM004774
Produced Document	ESTATE JPM004775
Produced Document	ESTATE\_JPM004776
Produced Document	ESTATE JPM004777
Produced Document	ESTATE JPM004780
Produced Document	ESTATE\_JPM004781
Produced Document	ESTATE JPM004782
Produced Document	ESTATE JPM004783
Produced Document	ESTATE\_JPM004784
Produced Document	ESTATE\_JPM004786
Produced Document	ESTATE JPM004787
Produced Document	ESTATE JPM004788
Produced Document	ESTATE JPM004789
Produced Document	ESTATE JPM004790
Produced Document	ESTATE \_JPM004791
Produced Document	ESTATE JPM004793
Produced Document	ESTATE JPM004795
Produced Document	ESTATE JPM004796
Produced Document	ESTATE JPM004797
Produced Document	ESTATE JPM004799
Produced Document	ESTATE\_JPM004801
Produced Document	ESTATE JPM004802
Produced Document	ESTATE JPM004803
Produced Document	ESTATE\_JPM004804
Produced Document	ESTATE JPM004805
Produced Document	ESTATE JPM004807
Produced Document	ESTATE JPM004808

Document Type	Description
Produced Document	ESTATE JPM004809
Produced Document	ESTATE JPM004810
Produced Document	ESTATE\_JPM004811
Produced Document	ESTATE JPM004813
Produced Document	ESTATE JPM004815
Produced Document	ESTATE\_JPM004816
Produced Document	ESTATE JPM004817
Produced Document	ESTATE\_JPM004818
Produced Document	ESTATE\_JPM004819
Produced Document	ESTATE JPM004820
Produced Document	ESTATE JPM004821
Produced Document	ESTATE JPM004822
Produced Document	ESTATE JPM004823
Produced Document	ESTATE JPM004824
Produced Document	ESTATE JPM004826
Produced Document	ESTATE JPM004828
Produced Document	ESTATE\_JPM004830
Produced Document	ESTATE JPM004832
Produced Document	ESTATE JPM004834
Produced Document	ESTATE\_JPM004836
Produced Document	ESTATE JPM004837
Produced Document	ESTATE JPM004838
Produced Document	ESTATE\_JPM004846
Produced Document	ESTATE JPM004849
Produced Document	ESTATE JPM004850
Produced Document	ESTATE\_JPM004851
Produced Document	ESTATE\_JPM004852
Produced Document	ESTATE JPM004853
Produced Document	ESTATE JPM004854
Produced Document	ESTATE JPM004855
Produced Document	ESTATE JPM004856
Produced Document	ESTATE JPM004857
Produced Document	ESTATE JPM004859
Produced Document	ESTATE JPM004861
Produced Document	ESTATE JPM004862
Produced Document	ESTATE JPM004863
Produced Document	ESTATE JPM004864
Produced Document	ESTATE JPM004865
Produced Document	ESTATE JPM004866
Produced Document	ESTATE JPM004873
Produced Document	ESTATE\_JPM004874
Produced Document	ESTATE JPM004875
Produced Document	ESTATE JPM004876
Produced Document	ESTATE JPM004878

Document Type	Description
Produced Document	ESTATE JPM004879
Produced Document	ESTATE \_JPM004880
Produced Document	ESTATE\_JPM004881
Produced Document	ESTATE JPM004882
Produced Document	ESTATE JPM004883
Produced Document	ESTATE JPM004885
Produced Document	ESTATE JPM004886
Produced Document	ESTATE\_JPM004887
Produced Document	ESTATE\_JPM004889
Produced Document	ESTATE JPM004890
Produced Document	ESTATE JPM004892
Produced Document	ESTATE JPM004893
Produced Document	ESTATE JPM004895
Produced Document	ESTATE JPM004896
Produced Document	ESTATE JPM004897
Produced Document	ESTATE JPM004899
Produced Document	ESTATE\_JPM004902
Produced Document	ESTATE JPM004903
Produced Document	ESTATE JPM004904
Produced Document	ESTATE\_JPM004905
Produced Document	ESTATE JPM004907
Produced Document	ESTATE JPM004909
Produced Document	ESTATE\_JPM004911
Produced Document	ESTATE JPM004913
Produced Document	ESTATE JPM004915
Produced Document	ESTATE\_JPM004917
Produced Document	ESTATE\_JPM004919
Produced Document	ESTATE JPM004921
Produced Document	ESTATE JPM004922
Produced Document	ESTATE \_WM004924
Produced Document	ESTATE JPM004925
Produced Document	ESTATE JPM004926
Produced Document	ESTATE JPM004928
Produced Document	ESTATE JPM004929
Produced Document	ESTATE JPM004931
Produced Document	ESTATE JPM004933
Produced Document	ESTATE JPM004935
Produced Document	ESTATE JPM004936
Produced Document	ESTATE JPM004937
Produced Document	ESTATE JPM004939
Produced Document	ESTATE\_JPM004940
Produced Document	ESTATE JPM004942
Produced Document	ESTATE JPM004944
Produced Document	ESTATE\_JPM004946

Document Type	Description
Produced Document	ESTATE JPM004949
Produced Document	ESTATE JPM004952
Produced Document	ESTATE\_JPM004955
Produced Document	ESTATE JPM004959
Produced Document	ESTATE JPM004963
Produced Document	ESTATE JPM004964
Produced Document	ESTATE JPM004966
Produced Document	ESTATE\_JPM004968
Produced Document	ESTATE\_JPM004969
Produced Document	ESTATE JPM004970
Produced Document	ESTATE JPM004971
Produced Document	ESTATE JPM004972
Produced Document	ESTATE JPM004973
Produced Document	ESTATE JPM004974
Produced Document	ESTATE JPM004975
Produced Document	ESTATE JPM004976
Produced Document	ESTATE\_JPM004977
Produced Document	ESTATE JPM004978
Produced Document	ESTATE JPM004979
Produced Document	ESTATE\_JPM004981
Produced Document	ESTATE JPM004983
Produced Document	ESTATE JPM004984
Produced Document	ESTATE\_JPM004985
Produced Document	ESTATE JPM004986
Produced Document	ESTATE JPM004987
Produced Document	ESTATE\_JPM004988
Produced Document	ESTATE\_JPM004990
Produced Document	ESTATE JPM004991
Produced Document	ESTATE JPM004992
Produced Document	ESTATE JPM004994
Produced Document	ESTATE JPM004996
Produced Document	ESTATE JPM004997
Produced Document	ESTATE JPM004998
Produced Document	ESTATE JPM004999
Produced Document	ESTATE JPM005001
Produced Document	ESTATE JPM005002
Produced Document	ESTATE JPM005004
Produced Document	ESTATE\_JPM005006
Produced Document	ESTATE JPM005007
Produced Document	ESTATE JPM005009
Produced Document	ESTATE\_JPM005010
Produced Document	ESTATE JPM005012
Produced Document	ESTATE JPM005013
Produced Document	ESTATE \_WM005014

Document Type	Description
Produced Document	ESTATE JPM005016
Produced Document	ESTATE JPM005017
Produced Document	ESTATE\_JPM005019
Produced Document	ESTATE JPM005020
Produced Document	ESTATE JPM005022
Produced Document	ESTATE JPM005024
Produced Document	ESTATE JPM005026
Produced Document	ESTATE\_JPM005029
Produced Document	ESTATE JPM005030
Produced Document	ESTATE JPM005031
Produced Document	ESTATE JPM005032
Produced Document	ESTATE JPM005033
Produced Document	ESTATE JPM005034
Produced Document	ESTATE JPM005035
Produced Document	ESTATE JPM005036
Produced Document	ESTATE JPM005037
Produced Document	ESTATE\_JPM005038
Produced Document	ESTATE JPM005039
Produced Document	ESTATE JPM005041
Produced Document	ESTATE\_JPM005043
Produced Document	ESTATE JPM005045
Produced Document	ESTATE JPM005046
Produced Document	ESTATE\_JPM005047
Produced Document	ESTATE JPM005048
Produced Document	ESTATE JPM005050
Produced Document	ESTATE\_JPM005052
Produced Document	ESTATE\_JPM005055
Produced Document	ESTATE JPM005056
Produced Document	ESTATE JPM005057
Produced Document	ESTATE JPM005059
Produced Document	ESTATE JPM005060
Produced Document	ESTATE JPM005061
Produced Document	ESTATE JPM005062
Produced Document	ESTATE JPM005063
Produced Document	ESTATE JPM005064
Produced Document	ESTATE JPM005066
Produced Document	ESTATE JPM005068
Produced Document	ESTATE JPM005069
Produced Document	ESTATE JPM005070
Produced Document	ESTATE JPM005071
Produced Document	ESTATE\_JPM005073
Produced Document	ESTATE JPM005075
Produced Document	ESTATE JPM005077
Produced Document	ESTATE JPM005079

Document Type	Description
Produced Document	ESTATE JPM005080
Produced Document	ESTATE\_JPM005082
Produced Document	ESTATE\_JPM005084
Produced Document	ESTATE JPM005086
Produced Document	ESTATE\_JPM005089
Produced Document	ESTATE\_JPM005090
Produced Document	ESTATE JPM005092
Produced Document	ESTATE\_JPM005094
Produced Document	ESTATE\_JPM005095
Produced Document	ESTATE JPM005096
Produced Document	ESTATE JPM005097
Produced Document	ESTATE JPM005099
Produced Document	ESTATE JPM005103
Produced Document	ESTATE JPM005104
Produced Document	ESTATE JPM005105
Produced Document	ESTATE JPM005106
Produced Document	ESTATE\_JPM005107
Produced Document	ESTATE JPM005108
Produced Document	ESTATE IPM005109
Produced Document	ESTATE\_JPM005110
Produced Document	ESTATE JPM005111
Produced Document	ESTATE JPM005112
Produced Document	ESTATE\_JPM005113
Produced Document	ESTATE JPM005114
Produced Document	ESTATE JPM005116
Produced Document	ESTATE\_JPM005118
Produced Document	ESTATE\_JPM005119
Produced Document	ESTATE JPM005121
Produced Document	ESTATE JPM005122
Produced Document	ESTATE\_JPM005124
Produced Document	ESTATE JPM005125
Produced Document	ESTATE\_JPM005126
Produced Document	ESTATE\_JPM005127
Produced Document	ESTATE JPM005129
Produced Document	ESTATE JPM005130
Produced Document	ESTATE\_JPM005132
Produced Document	ESTATE JPM005133
Produced Document	ESTATE JPM005134
Produced Document	ESTATE JPM005135
Produced Document	ESTATE JPM005136
Produced Document	ESTATE\_JPM005137
Produced Document	ESTATE JPM005138
Produced Document	ESTATE JPM005139
Produced Document	ESTATE JPM005140

Document Type	Description
Produced Document	ESTATE JPM005141
Produced Document	ESTATE i PM005143
Produced Document	ESTATE JPM005145
Produced Document	ESTATE JPM005148
Produced Document	ESTATE JPM005151
Produced Document	ESTATE JPM005152
Produced Document	ESTATE JPM005153
Produced Document	ESTATE \_JPM005155
Produced Document	ESTATE JPM005157
Produced Document	ESTATE JPM005158
Produced Document	ESTATE JPM005159
Produced Document	ESTATE i PM005160
Produced Document	ESTATE JPM005161
Produced Document	ESTATE JPM005162
Produced Document	ESTATE JPM005163
Produced Document	ESTATE JPM005165
Produced Document	ESTATE JPM005166
Produced Document	ESTATE JPM005167
Produced Document	ESTATE JPM005168
Produced Document	ESTATE\_JP MO05169
Produced Document	ESTATE JPM005170
Produced Document	ESTATE JPM005171
Produced Document	ESTATE\_JPM005172
Produced Document	ESTATE JPM005174
Produced Document	ESTATE JPM005175
Produced Document	ESTATE\_JPM005176
Produced Document	ESTATE\_JPM005178
Produced Document	ESTATE JPM005180
Produced Document	ESTATE JPM005181
Produced Document	ESTATE JPM005182
Produced Document	ESTATE JPM005183
Produced Document	ESTATE JPM005184
Produced Document	ESTATE JPM005185
Produced Document	ESTATE JPM005186
Produced Document	ESTATE JPM005188
Produced Document	ESTATE i PM005189
Produced Document	ESTATE JPM005190
Produced Document	ESTATE \_JPM005191
Produced Document	ESTATE JPM005193
Produced Document	ESTATE JPM005194
Produced Document	ESTATE\_JPM005195
Produced Document	ESTATE JPM005196
Produced Document	ESTATE JPM005197
Produced Document	ESTATE JPM005198

Document Type	Description
Produced Document	ESTATE JPM005199
Produced Document	ESTATE \_JPM005201
Produced Document	ESTATE \_JPM005202
Produced Document	ESTATE JPM005203
Produced Document	ESTATE JPM005205
Produced Document	ESTATE JPM005207
Produced Document	ESTATE JPM005209
Produced Document	ESTATE JPM005211
Produced Document	ESTATE \_JPM005212
Produced Document	ESTATE JPM005213
Produced Document	ESTATE JPM005215
Produced Document	ESTATE JPM005218
Produced Document	ESTATE JPM005220
Produced Document	ESTATE JPM005222
Produced Document	ESTATE JPM005225
Produced Document	ESTATE JPM005226
Produced Document	ESTATE\_JPM005228
Produced Document	ESTATE JPM005230
Produced Document	ESTATE JPM005233
Produced Document	ESTATE\_JPM005234
Produced Document	ESTATE JPM005237
Produced Document	ESTATE JPM005238
Produced Document	ESTATE\_JPM005240
Produced Document	ESTATE JPM005242
Produced Document	ESTATE JPM005243
Produced Document	ESTATE\_JPM005245
Produced Document	ESTATE\_JPM005246
Produced Document	ESTATE JPM005247
Produced Document	ESTATE JPM005248
Produced Document	ESTATE JPM005249
Produced Document	ESTATE JPM005251
Produced Document	ESTATE JPM005252
Produced Document	ESTATE JPM005253
Produced Document	ESTATE JPM005255
Produced Document	ESTATE JPM005256
Produced Document	ESTATE JPM005257
Produced Document	ESTATE JPM005258
Produced Document	ESTATE JPM005260
Produced Document	ESTATE JPM005262
Produced Document	ESTATE JPM005265
Produced Document	ESTATE\_JPM005268
Produced Document	ESTATE JPM005270
Produced Document	ESTATE JPM005272
Produced Document	ESTATE JPM005275

Document Type	Description
Produced Document	ESTATE JPM005279
Produced Document	ESTATE\_JPM005283
Produced Document	ESTATE\_JPM005285
Produced Document	ESTATE JPM005287
Produced Document	ESTATE\_JPM005290
Produced Document	ESTATE\_JPM005291
Produced Document	ESTATE JPM005295
Produced Document	ESTATE\_JPM005300
Produced Document	ESTATE\_JPM005305
Produced Document	ESTATE JPM005311
Produced Document	ESTATE JPM005318
Produced Document	ESTATE\_JPM005319
Produced Document	ESTATE JPM005320
Produced Document	ESTATE JPM005321
Produced Document	ESTATE JPM005322
Produced Document	ESTATE JPM005323
Produced Document	ESTATE\_JPM005324
Produced Document	ESTATE JPM005325
Produced Document	ESTATE JPM005327
Produced Document	ESTATE\_JPM005328
Produced Document	ESTATE JPM005329
Produced Document	ESTATE JPM005331
Produced Document	ESTATE\_JPM005333
Produced Document	ESTATE JPM005334
Produced Document	ESTATE JPM005336
Produced Document	ESTATE\_JPM005337
Produced Document	ESTATE\_JPM005338
Produced Document	ESTATE JPM005339
Produced Document	ESTATE JPM005340
Produced Document	ESTATE\_JPM005341
Produced Document	ESTATE JPM005342
Produced Document	ESTATE\_JPM005343
Produced Document	ESTATE\_JPM005344
Produced Document	ESTATE JPM005345
Produced Document	ESTATE JPM005347
Produced Document	ESTATE\_JPM005349
Produced Document	ESTATE JPM005350
Produced Document	ESTATE\_JPM005351
Produced Document	ESTATE JPM005352
Produced Document	ESTATE JPM005353
Produced Document	ESTATE\_JPM005354
Produced Document	ESTATE JPM005356
Produced Document	ESTATE JPM005357
Produced Document	ESTATE JPM005359

Document Type	Description
Produced Document	ESTATE JPM005361
Produced Document	ESTATE\_JPM005363
Produced Document	ESTATE\_JPM005364
Produced Document	ESTATE JPM005366
Produced Document	ESTATE\_JPM005368
Produced Document	ESTATE\_JPM005371
Produced Document	ESTATE JPM005374
Produced Document	ESTATE\_JPM005376
Produced Document	ESTATE\_JPM005378
Produced Document	ESTATE JPM005380
Produced Document	ESTATE JPM005381
Produced Document	ESTATE JPM005383
Produced Document	ESTATE JPM005385
Produced Document	ESTATE\_JPM005386
Produced Document	ESTATE JPM005387
Produced Document	ESTATE JPM005389
Produced Document	ESTATE\_JPM005391
Produced Document	ESTATE JPM005393
Produced Document	ESTATE JPM005395
Produced Document	ESTATE\_JPM005397
Produced Document	ESTATE JPM005398
Produced Document	ESTATE JPM005399
Produced Document	ESTATE\_JPM005401
Produced Document	ESTATE JPM005403
Produced Document	ESTATE JPM005405
Produced Document	ESTATE\_JPM005408
Produced Document	ESTATE\_JPM005410
Produced Document	ESTATE JPM005413
Produced Document	ESTATE JPM005414
Produced Document	ESTATE\_JPM005415
Produced Document	ESTATE JPM005417
Produced Document	ESTATE\_JPM005418
Produced Document	ESTATE\_JPM005419
Produced Document	ESTATE JPM005421
Produced Document	ESTATE JPM005422
Produced Document	ESTATE\_JPM005423
Produced Document	ESTATE JPM005425
Produced Document	ESTATE JPM005428
Produced Document	ESTATE JPM005431
Produced Document	ESTATE JPM005435
Produced Document	ESTATE\_JPM005437
Produced Document	ESTATE JPM005439
Produced Document	ESTATE JPM005440
Produced Document	ESTATE JPM005442

Document Type	Description
Produced Document	ESTATE JPM005444
Produced Document	ESTATE\_JPM005446
Produced Document	ESTATE\_JPM005448
Produced Document	ESTATE JPM005449
Produced Document	ESTATE\_JPM005450
Produced Document	ESTATE\_JPM005452
Produced Document	ESTATE JPM005453
Produced Document	ESTATE\_JPM005454
Produced Document	ESTATE\_JPM005456
Produced Document	ESTATE JPM005457
Produced Document	ESTATE JPM005459
Produced Document	ESTATE\_JPM005461
Produced Document	ESTATE JPM005463
Produced Document	ESTATE JPM005465
Produced Document	ESTATE JPM005467
Produced Document	ESTATE JPM005468
Produced Document	ESTATE\_JPM005470
Produced Document	ESTATE JPM005472
Produced Document	ESTATE JPM005474
Produced Document	ESTATE\_JPM005476
Produced Document	ESTATE JPM005479
Produced Document	ESTATE JPM005480
Produced Document	ESTATE\_JPM005481
Produced Document	ESTATE JPM005483
Produced Document	ESTATE JPM005484
Produced Document	ESTATE\_JPM005485
Produced Document	ESTATE\_JPM005487
Produced Document	ESTATE JPM005489
Produced Document	ESTATE JPM005492
Produced Document	ESTATE\_JPM005493
Produced Document	ESTATE JPM005495
Produced Document	ESTATE\_JPM005497
Produced Document	ESTATE\_JPM005500
Produced Document	ESTATE JPM005503
Produced Document	ESTATE JPM005505
Produced Document	ESTATE\_JPM005507
Produced Document	ESTATE JPM005509
Produced Document	ESTATE JPM005510
Produced Document	ESTATE JPM005511
Produced Document	ESTATE JPM005513
Produced Document	ESTATE\_JPM005515
Produced Document	ESTATE JPM005517
Produced Document	ESTATE JPM005519
Produced Document	ESTATE\_JPM005521

Document Type	Description
Produced Document	ESTATE JPM005524
Produced Document	ESTATE\_JPM005525
Produced Document	ESTATE\_JPM005526
Produced Document	ESTATE JPM005527
Produced Document	ESTATE\_JPM005529
Produced Document	ESTATE\_JPM005534
Produced Document	ESTATE JPM005535
Produced Document	ESTATE\_JPM005536
Produced Document	ESTATE\_JPM005538
Produced Document	ESTATE JPM005539
Produced Document	ESTATE JPM005540
Produced Document	ESTATE\_JPM005542
Produced Document	ESTATE JPM005543
Produced Document	ESTATE JPM005544
Produced Document	ESTATE JPM005545
Produced Document	ESTATE JPM005546
Produced Document	ESTATE\_JPM005547
Produced Document	ESTATE JPM005549
Produced Document	ESTATE JPM005551
Produced Document	ESTATE\_JPM005553
Produced Document	ESTATE JPM005554
Produced Document	ESTATE JPM005555
Produced Document	ESTATE\_JPM005556
Produced Document	ESTATE JPM005557
Produced Document	ESTATE JPM005558
Produced Document	ESTATE\_JPM005559
Produced Document	ESTATE\_JPM005561
Produced Document	ESTATE JPM005562
Produced Document	ESTATE JPM005563
Produced Document	ESTATE\_JPM005564
Produced Document	ESTATE JPM005565
Produced Document	ESTATE\_JPM005566
Produced Document	ESTATE\_JPM005567
Produced Document	ESTATE JPM005568
Produced Document	ESTATE JPM005570
Produced Document	ESTATE\_JPM005572
Produced Document	ESTATE JPM005575
Produced Document	ESTATE JPM005578
Produced Document	ESTATE JPM005582
Produced Document	ESTATE JPM005583
Produced Document	ESTATE\_JPM005585
Produced Document	ESTATE JPM005587
Produced Document	ESTATE JPM005589
Produced Document	ESTATE\_JPM005590

Document Type	Description
Produced Document	ESTATE JPM00559 I
Produced Document	ESTATE\_JPM005592
Produced Document	ESTATE\_JPM005593
Produced Document	ESTATE JPM005594
Produced Document	ESTATE\_JPM005596
Produced Document	ESTATE\_JPM005598
Produced Document	ESTATE JPM005599
Produced Document	ESTATE\_JPM005600
Produced Document	ESTATE\_JPM005601
Produced Document	ESTATE JPM005602
Produced Document	ESTATE JPM005603
Produced Document	ESTATE\_JPM005604
Produced Document	ESTATE JPM005605
Produced Document	ESTATE JPM005606
Produced Document	ESTATE JPM005607
Produced Document	ESTATE JPM005609
Produced Document	ESTATE\_JPM005611
Produced Document	ESTATE JPM005612
Produced Document	ESTATE JPM005613
Produced Document	ESTATE\_JPM005614
Produced Document	ESTATE JPM005615
Produced Document	ESTATE JPM005616
Produced Document	ESTATE\_JPM005618
Produced Document	ESTATE JPM005619
Produced Document	ESTATE JPM005620
Produced Document	ESTATE\_JPM005621
Produced Document	ESTATE\_JPM005622
Produced Document	ESTATE JPM005624
Produced Document	ESTATE JPM005625
Produced Document	ESTATE\_JPM005627
Produced Document	ESTATE JPM005629
Produced Document	ESTATE\_JPM005631
Produced Document	ESTATE\_JPM005633
Produced Document	ESTATE JPM005634
Produced Document	ESTATE JPM005636
Produced Document	ESTATE\_JPM005637
Produced Document	ESTATE JPM005638
Produced Document	ESTATE\_JPM005639
Produced Document	ESTATE JPM005641
Produced Document	ESTATE JPM005643
Produced Document	ESTATE\_JPM005644
Produced Document	ESTATE JPM005645
Produced Document	ESTATE JPM005646
Produced Document	ESTATE JPM005647

Document Type	Description
Produced Document	ESTATE JPM005648
Produced Document	ESTATE\_JPM005649
Produced Document	ESTATE\_JPM005650
Produced Document	ESTATE JPM005651
Produced Document	ESTATE\_JPM005652
Produced Document	ESTATE\_JPM005654
Produced Document	ESTATE JPM005656
Produced Document	ESTATE\_JPM005657
Produced Document	ESTATE\_JPM005659
Produced Document	ESTATE JPM005660
Produced Document	ESTATE JPM005661
Produced Document	ESTATE\_JPM005662
Produced Document	ESTATE JPM005663
Produced Document	ESTATE JPM005664
Produced Document	ESTATE JPM005665
Produced Document	ESTATE JPM005667
Produced Document	ESTATE\_JPM005669
Produced Document	ESTATE JPM005670
Produced Document	ESTATE JPM005671
Produced Document	ESTATE\_JPM005672
Produced Document	ESTATE JPM005673
Produced Document	ESTATE JPM005674
Produced Document	ESTATE\_JPM005675
Produced Document	ESTATE JPM005676
Produced Document	ESTATE JPM005677
Produced Document	ESTATE\_JPM005678
Produced Document	ESTATE\_JPM005679
Produced Document	ESTATE JPM005681
Produced Document	ESTATE JPM005683
Produced Document	ESTATE\_JPM005684
Produced Document	ESTATE JPM005685
Produced Document	ESTATE\_JPM005687
Produced Document	ESTATE\_JPM005688
Produced Document	ESTATE JPM005689
Produced Document	ESTATE JPM005691
Produced Document	ESTATE\_JPM005693
Produced Document	ESTATE JPM005694
Produced Document	ESTATE JPM005695
Produced Document	ESTATE JPM005696
Produced Document	ESTATE JPM005697
Produced Document	ESTATE\_JPM005698
Produced Document	ESTATE JPM005699
Produced Document	ESTATE JPM005700
Produced Document	ESTATE JPM005701

Document Type	Description
Produced Document	ESTATE JPM005703
Produced Document	ESTATE \_JPM005704
Produced Document	ESTATE JPM005705
Produced Document	ESTATE JPM005706
Produced Document	ESTATE JPM005707
Produced Document	ESTATE JPM005708
Produced Document	ESTATE JPM005709
Produced Document	ESTATE\_JPM005710
Produced Document	ESTATE JPM005711
Produced Document	ESTATE JPM005712
Produced Document	ESTATE JPM005713
Produced Document	ESTATE JPM005714
Produced Document	ESTATE JPM005715
Produced Document	ESTATE JPM005716
Produced Document	ESTATE JPM005718
Produced Document	ESTATE JPM005719
Produced Document	ESTATE\_JPM005720
Produced Document	ESTATE JPM005722
Produced Document	ESTATE JPM005725
Produced Document	ESTATE\_JPM005726
Produced Document	ESTATE JPM005728
Produced Document	ESTATE JPM005729
Produced Document	ESTATE \_WM005730
Produced Document	ESTATE JPM005732
Produced Document	ESTATE JPM005733
Produced Document	ESTATE\_JPM005734
Produced Document	ESTATE\_JPM005735
Produced Document	ESTATE JPM005737
Produced Document	ESTATE JPM005738
Produced Document	ESTATE JPM005739
Produced Document	ESTATE JPM005741
Produced Document	ESTATE JPM005742
Produced Document	ESTATE JPM005744
Produced Document	ESTATE JPM005746
Produced Document	ESTATE JPM005749
Produced Document	ESTATE JPM005750
Produced Document	ESTATE JPM005752
Produced Document	ESTATE\_JPM005753
Produced Document	ESTATE JPM005755
Produced Document	ESTATE JPM005757
Produced Document	ESTATE\_JPM005758
Produced Document	ESTATE JPM005759
Produced Document	ESTATE JPM005760
Produced Document	ESTATE JPM005761

Document Type	Description
Produced Document	ESTATE JPM005762
Produced Document	ESTATE JPM005763
Produced Document	ESTATE\_JPM005765
Produced Document	ESTATE JPM005767
Produced Document	ESTATE JPM005768
Produced Document	ESTATE JPM005769
Produced Document	ESTATE JPM005770
Produced Document	ESTATE\_JPM005771
Produced Document	ESTATE JPM005772
Produced Document	ESTATE JPM005773
Produced Document	ESTATE JPM005774
Produced Document	ESTATE JPM005775
Produced Document	ESTATE JPM005777
Produced Document	ESTATE JPM005778
Produced Document	ESTATE JPM005779
Produced Document	ESTATE JPM005780
Produced Document	ESTATE\_JPM005781
Produced Document	ESTATE JPM005782
Produced Document	ESTATE JPM005783
Produced Document	ESTATE\_JPM005784
Produced Document	ESTATE JPM005785
Produced Document	ESTATE JPM005786
Produced Document	ESTATE\_JPM005787
Produced Document	ESTATE JPM005788
Produced Document	ESTATE JPM005789
Produced Document	ESTATE\_JPM005790
Produced Document	ESTATE\_JPM005791
Produced Document	ESTATE JPM005792
Produced Document	ESTATE JPM005793
Produced Document	ESTATE JPM005794
Produced Document	ESTATE JPM005795
Produced Document	ESTATE JPM005796
Produced Document	ESTATE JPM005797
Produced Document	ESTATE JPM005798
Produced Document	ESTATE JPM005799
Produced Document	ESTATE JPM005800
Produced Document	ESTATE JPM005801
Produced Document	ESTATE\_JPM005802
Produced Document	ESTATE JPM005803
Produced Document	ESTATE JPM005804
Produced Document	ESTATE\_JPM005805
Produced Document	ESTATE JPM005806
Produced Document	ESTATE JPM005807
Produced Document	ESTATE JPM005808

Document Type	Description
Produced Document	ESTATE JPM005809
Produced Document	ESTATE JPM005810
Produced Document	ESTATE \_JPM005811
Produced Document	ESTATE JPM005812
Produced Document	ESTATE JPM005813
Produced Document	ESTATE JPM005814
Produced Document	ESTATE JPM005815
Produced Document	ESTATE\_JPM005816
Produced Document	ESTATE \_WM005817
Produced Document	ESTATE JPM005818
Produced Document	ESTATE JPM005819
Produced Document	ESTATE JPM005820
Produced Document	ESTATE JPM005821
Produced Document	ESTATE JPM005822
Produced Document	ESTATE JPM005823
Produced Document	ESTATE JPM005824
Produced Document	ESTATE\_JPM005825
Produced Document	ESTATE JPM005826
Produced Document	ESTATE JPM005827
Produced Document	ESTATE\_JPM005828
Produced Document	ESTATE JPM005829
Produced Document	ESTATE JPM005830
Produced Document	ESTATE \_WM005831
Produced Document	ESTATE JPM005832
Produced Document	ESTATE JPM005833
Produced Document	ESTATE\_JPM005834
Produced Document	ESTATE\_JPM005835
Produced Document	ESTATE JPM005836
Produced Document	ESTATE JPM005837
Produced Document	ESTATE JPM005838
Produced Document	ESTATE JPM005839
Produced Document	ESTATE JPM005840
Produced Document	ESTATE \_JPM005841
Produced Document	ESTATE JPM005842
Produced Document	ESTATE JPM005844
Produced Document	ESTATE JPM005846
Produced Document	ESTATE JPM005847
Produced Document	ESTATE\_JPM005848
Produced Document	ESTATE JPM005850
Produced Document	ESTATE JPM005852
Produced Document	ESTATE\_JPM005854
Produced Document	ESTATE JPM005856
Produced Document	ESTATE JPM005857
Produced Document	ESTATE JPM005858

Document Type	Description
Produced Document	ESTATE JPM005859
Produced Document	ESTATE JPM005860
Produced Document	ESTATE JPM005862
Produced Document	ESTATE JPM005863
Produced Document	ESTATE JPM005864
Produced Document	ESTATE JPM005865
Produced Document	ESTATE JPM005867
Produced Document	ESTATE JPM005868
Produced Document	ESTATE\_JPM005869
Produced Document	ESTATE JPM005870
Produced Document	ESTATE JPM005871
Produced Document	ESTATE JPM005872
Produced Document	ESTATE JPM016779
Produced Document	ESTATE JPM016780
Produced Document	ESTATE JPM016781
Produced Document	ESTATE JPM016782
Produced Document	ESTATE\_JPM016783
Produced Document	ESTATE JPMO 16784
Produced Document	ESTATE JPM016785
Produced Document	ESTATE JPM016786
Produced Document	ESTATE JPMO 16787
Produced Document	ESTATE JPM016788
Produced Document	ESTATE JPM0 16789
Produced Document	ESTATE JPMO 16790
Produced Document	ESTATE JPM016791
Produced Document	ESTATE \_JPM016792
Produced Document	ESTATE JPM016793
Produced Document	ESTATE JPM016794
Produced Document	ESTATE JPM016795
Produced Document	ESTATE JPM016796
Produced Document	ESTATE JPM016797
Produced Document	ESTATE \_JPM016798
Produced Document	ESTATE JPM016799
Produced Document	ESTATE JPM016800
Produced Document	ESTATE JPM016801
Produced Document	ESTATE JPM016802
Produced Document	ESTATE JPMO 16803
Produced Document	ESTATE JPM016804
Produced Document	ESTATE JPMO 16805
Produced Document	ESTATE JPMO 16806
Produced Document	ESTATE\_JPM016807
Produced Document	ESTATE JPMO 16808
Produced Document	ESTATE JPM016809
Produced Document	ESTATE JPM016810

Document Type	Description
Produced Document	ESTATE JPM016811
Produced Document	ESTATE JPM016812
Produced Document	ESTATE JPM016813
Produced Document	ESTATE JPM016814
Produced Document	ESTATE JPM016815
Produced Document	ESTATE JPM016816
Produced Document	ESTATE JPM016817
Produced Document	ESTATE \_JPM016818
Produced Document	ESTATE \_JPM016819
Produced Document	ESTATE JPMO 16820
Produced Document	ESTATE JPM016821
Produced Document	ESTATE JPM0 16822
Produced Document	ESTATE JPM016823
Produced Document	ESTATE JPM016824
Produced Document	ESTATE JPMO 16825
Produced Document	ESTATE JPMO 16826
Produced Document	ESTATE\_JPM0 16827
Produced Document	ESTATE JPMO 16828
Produced Document	ESTATE JPMO 16829
Produced Document	ESTATE JPM0 16830
Produced Document	ESTATE JPM016831
Produced Document	ESTATE JPMO 16832
Produced Document	ESTATE JPM0 16833
Produced Document	ESTATE JPMO 16834
Produced Document	ESTATE JPMO 16835
Produced Document	ESTATE \_JPM0 16836
Produced Document	ESTATE JPM0 16837
Produced Document	ESTATE JPMO 16838
Produced Document	ESTATE \_JPM016839
Produced Document	ESTATE JPM016840
Produced Document	ESTATE JPM016841
Produced Document	ESTATE \_JPM016842
Produced Document	ESTATE \_JPM016843
Produced Document	ESTATE JPMO 16844
Produced Document	ESTATE JPM016845
Produced Document	ESTATE JPM016846
Produced Document	ESTATE JPMO 16847
Produced Document	ESTATE \_JPM016848
Produced Document	ESTATE JPMO 16849
Produced Document	ESTATE JPMO 16850
Produced Document	ESTATE\_JPM016851
Produced Document	ESTATE JPMO 16852
Produced Document	ESTATE JPMO 16853
Produced Document	ESTATE JPM0 16854

Document Type	Description
Produced Document	ESTATE JPM016855
Produced Document	ESTATE JPM016856
Produced Document	ESTATE JPM016857
Produced Document	ESTATE JPM016858
Produced Document	ESTATE JPM016859
Produced Document	ESTATE JPM016860
Produced Document	ESTATE JPM016861
Produced Document	ESTATE \_JPM016862
Produced Document	ESTATE JPM016863
Produced Document	ESTATE JPM016864
Produced Document	ESTATE JPM016865
Produced Document	ESTATE JPM016866
Produced Document	ESTATE JPM016867
Produced Document	ESTATE JPM016868
Produced Document	ESTATE JPM016869
Produced Document	ESTATE JPM016870
Produced Document	ESTATE\_JPM016871
Produced Document	ESTATE JPMO 16872
Produced Document	ESTATE JPM016873
Produced Document	ESTATE JPM0 16874
Produced Document	ESTATE JPMO 16875
Produced Document	ESTATE JPM016876
Produced Document	ESTATE JPM0 16877
Produced Document	ESTATE JPMO 16878
Produced Document	ESTATE JPMO 16879
Produced Document	ESTATE \_JPM0 16880
Produced Document	ESTATE\_JPM016881
Produced Document	ESTATE JPM016882
Produced Document	ESTATE JPM016883
Produced Document	ESTATE JPM016884
Produced Document	ESTATE JPM016885
Produced Document	ESTATE \_JPM016886
Produced Document	ESTATE JPM016887
Produced Document	ESTATE JPM016888
Produced Document	ESTATE JPM016889
Produced Document	ESTATE JPM016890
Produced Document	ESTATE JPM016891
Produced Document	ESTATE JPM016892
Produced Document	ESTATE JPMO 16893
Produced Document	ESTATE JPMO 16894
Produced Document	ESTATE\_JPM016895
Produced Document	ESTATE JPMO 16896
Produced Document	ESTATE JPM016897
Produced Document	ESTATE JPM0 16898

Document Type	Description
Produced Document	ESTATE JPM016899
Produced Document	ESTATE \_JPM016900
Produced Document	ESTATE JPM016901
Produced Document	ESTATE JPM016902
Produced Document	ESTATE JPM016903
Produced Document	ESTATE JPM016904
Produced Document	ESTATE JPM016905
Produced Document	ESTATE \_JPM016906
Produced Document	ESTATE JPM016907
Produced Document	ESTATE JPM016908
Produced Document	ESTATE JPM016909
Produced Document	ESTATE JPM016910
Produced Document	ESTATE JPM016911
Produced Document	ESTATE JPM016912
Produced Document	ESTATE JPM016913
Produced Document	ESTATE JPM016914
Produced Document	ESTATE\_JPM016915
Produced Document	ESTATE JPM016916
Produced Document	ESTATE JPM016917
Produced Document	ESTATE \_JPM016918
Produced Document	ESTATE JPM016919
Produced Document	ESTATE JPM016920
Produced Document	ESTATE \_JPM016921
Produced Document	ESTATE JPMO 16922
Produced Document	ESTATE JPMO 16923
Produced Document	ESTATE \_JPM0 16924
Produced Document	ESTATE JPM016925
Produced Document	ESTATE JPM016926
Produced Document	ESTATE JPM016927
Produced Document	ESTATE JPM016928
Produced Document	ESTATE JPM016929
Produced Document	ESTATE \_JPM016930
Produced Document	ESTATE JPM016931
Produced Document	ESTATE JPM016932
Produced Document	ESTATE JPM016933
Produced Document	ESTATE JPM016934
Produced Document	ESTATE JPM016935
Produced Document	ESTATE\_JPM016936
Produced Document	ESTATE JPM016937
Produced Document	ESTATE JPM016938
Produced Document	ESTATE\_JPM016939
Produced Document	ESTATE JPMO 16940
Produced Document	ESTATE JPM016941
Produced Document	ESTATE JPM0 16942

Document Type	Description
Produced Document	ESTATE JPM016943
Produced Document	ESTATE \_WM016944
Produced Document	ESTATE JPM016945
Produced Document	ESTATE JPM016946
Produced Document	ESTATE JPM016947
Produced Document	ESTATE JPM016948
Produced Document	ESTATE JPM016949
Produced Document	ESTATE \_JPM016950
Produced Document	ESTATE JPM016951
Produced Document	ESTATE JPM016952
Produced Document	ESTATE JPM016953
Produced Document	ESTATE JPM016954
Produced Document	ESTATE JPM016955
Produced Document	ESTATE JPM016956
Produced Document	ESTATE JPMO 16957
Produced Document	ESTATE JPM016958
Produced Document	ESTATE\_JPM016959
Produced Document	ESTATE JPMO 16960
Produced Document	ESTATE JPM016961
Produced Document	ESTATE \_JPM016962
Produced Document	ESTATE JPMO 16963
Produced Document	ESTATE JPM016964
Produced Document	ESTATE JPM0 16965
Produced Document	ESTATE JPMO 16966
Produced Document	ESTATE JPMO 16967
Produced Document	ESTATE \_JPM0 16968
Produced Document	ESTATE\_JPM016969
Produced Document	ESTATE JPM016970
Produced Document	ESTATE JPM016971
Produced Document	ESTATE JPM016972
Produced Document	ESTATE JPM016973
Produced Document	ESTATE \_JPM016974
Produced Document	ESTATE JPM016975
Produced Document	ESTATE JPM016976
Produced Document	ESTATE JPM016977
Produced Document	ESTATE JPM016978
Produced Document	ESTATE JPMO 16979
Produced Document	ESTATE JPM016980
Produced Document	ESTATE JPM016981
Produced Document	ESTATE JPMO 16982
Produced Document	ESTATE\_JPM016983
Produced Document	ESTATE JPMO 16984
Produced Document	ESTATE JPM016985
Produced Document	ESTATE JPMO 16986

Document Type	Description
Produced Document	ESTATE JPM016987
Produced Document	ESTATE JPM016988
Produced Document	ESTATE JPM016989
Produced Document	ESTATE JPM016990
Produced Document	ESTATE JPM016991
Produced Document	ESTATE JPM016992
Produced Document	ESTATE JPM016993
Produced Document	ESTATE \_JPM016994
Produced Document	ESTATE\_JPM016995
Produced Document	ESTATE JPM016996
Produced Document	ESTATE JPM016997
Produced Document	ESTATE JPM016998
Produced Document	ESTATE JPM016999
Produced Document	ESTATE JPM017000
Produced Document	ESTATE JPM017001
Produced Document	ESTATE JPM017002
Produced Document	ESTATE\_JPM017003
Produced Document	ESTATE JPM017004
Produced Document	ESTATE JPM017005
Produced Document	ESTATE\_JPM017006
Produced Document	ESTATE JPM017007
Produced Document	ESTATE JPM017008
Produced Document	ESTATE\_JPM017009
Produced Document	ESTATE JPM017010
Produced Document	ESTATE JPM017011
Produced Document	ESTATE\_JPM017012
Produced Document	ESTATE\_JPM017013
Produced Document	ESTATE JPM017014
Produced Document	ESTATE JPM017015
Produced Document	ESTATE JPM017016
Produced Document	ESTATE JPM017017
Produced Document	ESTATE \_JPM017018
Produced Document	ESTATE JPM017019
Produced Document	ESTATE JPM017020
Produced Document	ESTATE JPM017021
Produced Document	ESTATE JPM017022
Produced Document	ESTATE JPM017023
Produced Document	ESTATE JPM017024
Produced Document	ESTATE JPM017025
Produced Document	ESTATE JPM017026
Produced Document	ESTATE\_JPM017027
Produced Document	ESTATE JPM017028
Produced Document	ESTATE JPM017029
Produced Document	ESTATE JPM017030

Document Type	Description
Produced Document	ESTATE JPM017031
Produced Document	ESTATE \_WM017032
Produced Document	ESTATE \_JPM017033
Produced Document	ESTATE JPM017034
Produced Document	ESTATE JPM017035
Produced Document	ESTATE JPM017036
Produced Document	ESTATE JPM017037
Produced Document	ESTATE JPM017038
Produced Document	ESTATE JPM017039
Produced Document	ESTATE JPM017040
Produced Document	ESTATE JPM017041
Produced Document	ESTATE JPM017042
Produced Document	ESTATE JPM017043
Produced Document	ESTATE JPM017044
Produced Document	ESTATE JPM017045
Produced Document	ESTATE JPM017046
Produced Document	ESTATE JPM017047
Produced Document	ESTATE JPM017048
Produced Document	ESTATE JPM017049
Produced Document	ESTATE JPM017050
Produced Document	ESTATE JPM017051
Produced Document	ESTATE JPM017052
Produced Document	ESTATE\_JPM017053
Produced Document	ESTATE JPM017054
Produced Document	ESTATE JPM017055
Produced Document	ESTATE\_JPM017056
Produced Document	ESTATE\_JPM017057
Produced Document	ESTATE JPM017058
Produced Document	ESTATE JPM017059
Produced Document	ESTATE JPM017060
Produced Document	ESTATE JPM017061
Produced Document	ESTATE \_JPM017062
Produced Document	ESTATE JPM017063
Produced Document	ESTATE JPM017064
Produced Document	ESTATE JPM017065
Produced Document	ESTATE \_JPM017066
Produced Document	ESTATE JPM017067
Produced Document	ESTATE JPM017068
Produced Document	ESTATE JPM017069
Produced Document	ESTATE JPM017070
Produced Document	ESTATE \_JPM017071
Produced Document	ESTATE JPM017072
Produced Document	ESTATE JPM017073
Produced Document	ESTATE JPM017074

Document Type	Description
Produced Document	ESTATE JPM017075
Produced Document	ESTATE \_JPM017076
Produced Document	ESTATE \_JPM017077
Produced Document	ESTATE JPM017078
Produced Document	ESTATE JPM017079
Produced Document	ESTATE JPM017080
Produced Document	ESTATE JPM017081
Produced Document	ESTATE \_JPM017082
Produced Document	ESTATE\_JPM017083
Produced Document	ESTATE JPM017084
Produced Document	ESTATE JPM017085
Produced Document	ESTATE JPM017086
Produced Document	ESTATE JPM017087
Produced Document	ESTATE JPM017088
Produced Document	ESTATE JPM017089
Produced Document	ESTATE JPM017090
Produced Document	ESTATE JPM017091
Produced Document	ESTATE JPM017092
Produced Document	ESTATE JPM017093
Produced Document	ESTATE\_JPM017094
Produced Document	ESTATE JPM017095
Produced Document	ESTATE JPM017096
Produced Document	ESTATE JPM017097
Produced Document	ESTATE JPM017098
Produced Document	ESTATE JPM017099
Produced Document	ESTATE\_JPM017100
Produced Document	ESTATE\_JPM017101
Produced Document	ESTATE JPM017102
Produced Document	ESTATE JPM017103
Produced Document	ESTATE JPM017104
Produced Document	ESTATE JPM017105
Produced Document	ESTATE \_JPM017106
Produced Document	ESTATE JPM017107
Produced Document	ESTATE JPM017108
Produced Document	ESTATE JPM017109
Produced Document	ESTATE JPM017110
Produced Document	ESTATE JPM017111
Produced Document	ESTATE JPM017112
Produced Document	ESTATE JPM017113
Produced Document	ESTATE JPM017114
Produced Document	ESTATE\_JPM017115
Produced Document	ESTATE JPM017116
Produced Document	ESTATE JPM017117
Produced Document	ESTATE JPM017118

Document Type	Description
Produced Document	ESTATE JPM017119
Produced Document	ESTATE \_JPM017120
Produced Document	ESTATE JPM017121
Produced Document	ESTATE JPM017122
Produced Document	ESTATE JPM017123
Produced Document	ESTATE JPM017124
Produced Document	ESTATE JPM017125
Produced Document	ESTATE \_JPM017126
Produced Document	ESTATE \_JPM017127
Produced Document	ESTATE JPM017128
Produced Document	ESTATE JPM017129
Produced Document	ESTATE JPM017130
Produced Document	ESTATE JPM01713 I
Produced Document	ESTATE JPM017132
Produced Document	ESTATE JPM017133
Produced Document	ESTATE JPM017134
Produced Document	ESTATE\_JPM017135
Produced Document	ESTATE JPM017136
Produced Document	ESTATE JPM017137
Produced Document	ESTATE JPM017138
Produced Document	ESTATE JPM017139
Produced Document	ESTATE JPM017140
Produced Document	ESTATE JPM017141
Produced Document	ESTATE JPM017142
Produced Document	ESTATE JPM017143
Produced Document	ESTATE\_JPM017144
Produced Document	ESTATE JPM017145
Produced Document	ESTATE JPM017146
Produced Document	ESTATE JPM017147
Produced Document	ESTATE JPM017148
Produced Document	ESTATE JPM017149
Produced Document	ESTATE \_JPM017150
Produced Document	ESTATE \_JPM017151
Produced Document	ESTATE JPM017152
Produced Document	ESTATE JPM017153
Produced Document	ESTATE JPM017154
Produced Document	ESTATE JPM017155
Produced Document	ESTATE \_JPM017156
Produced Document	ESTATE JPM017157
Produced Document	ESTATE JPM017158
Produced Document	ESTATE\_JPM017159
Produced Document	ESTATE JPM017160
Produced Document	ESTATE JPM017161
Produced Document	ESTATE JPM017162

Document Type	Description
Produced Document	ESTATE JPM017163
Produced Document	ESTATE JPM017164
Produced Document	ESTATE JPM017165
Produced Document	ESTATE JPM017166
Produced Document	ESTATE JPM017167
Produced Document	ESTATE JPM017168
Produced Document	ESTATE JPM017169
Produced Document	ESTATE \_JPM017170
Produced Document	ESTATE \_JPM017171
Produced Document	ESTATE JPM017172
Produced Document	ESTATE JPM017173
Produced Document	ESTATE JPM017174
Produced Document	ESTATE JPM017175
Produced Document	ESTATE JPM017176
Produced Document	ESTATE JPM017177
Produced Document	ESTATE JPM017178
Produced Document	ESTATE\_JPM017179
Produced Document	ESTATE JPM017180
Produced Document	ESTATE JPM017181
Produced Document	ESTATE JPM017182
Produced Document	ESTATE JPM017183
Produced Document	ESTATE JPM017184
Produced Document	ESTATE JPM017185
Produced Document	ESTATE JPM017186
Produced Document	ESTATE JPM017187
Produced Document	ESTATE JPM017188
Produced Document	ESTATE JPM017189
Produced Document	ESTATE JPM017190
Produced Document	ESTATE \_JPM017191
Produced Document	ESTATE JPM017192
Produced Document	ESTATE JPM017193
Produced Document	ESTATE \_JPM017194
Produced Document	ESTATE \_JPM017195
Produced Document	ESTATE JPM017196
Produced Document	ESTATE JPM017197
Produced Document	ESTATE JPM017198
Produced Document	ESTATE JPM017199
Produced Document	ESTATE \_JPM017200
Produced Document	ESTATE JPM017201
Produced Document	ESTATE JPMO 17202
Produced Document	ESTATE \_JPM017203
Produced Document	ESTATE JPMO 17204
Produced Document	ESTATE JPM017205
Produced Document	ESTATE JPMO 17206

Document Type	Description
Produced Document	ESTATE JPM017207
Produced Document	ESTATE \_JPM017208
Produced Document	ESTATE \_JPM017209
Produced Document	ESTATE JPM017210
Produced Document	ESTATE JPM017211
Produced Document	ESTATE JPM017212
Produced Document	ESTATE JPM017213
Produced Document	ESTATE \_JPM017214
Produced Document	ESTATE \_JPM017215
Produced Document	ESTATE JPM017216
Produced Document	ESTATE JPM017217
Produced Document	ESTATE JPM017218
Produced Document	ESTATE JPM017219
Produced Document	ESTATE JPM017220
Produced Document	ESTATE JPM017221
Produced Document	ESTATE JPM017222
Produced Document	ESTATE\_JPM017223
Produced Document	ESTATE JPMO 17224
Produced Document	ESTATE JPM017225
Produced Document	ESTATE JPM017226
Produced Document	ESTATE JPMO 17227
Produced Document	ESTATE JPM017228
Produced Document	ESTATE\_WMO 17229
Produced Document	ESTATE JPMO 17230
Produced Document	ESTATE JPM017231
Produced Document	ESTATE \_JPM0 17232
Produced Document	ESTATE JPM0 17233
Produced Document	ESTATE JPMO 17234
Produced Document	ESTATE \_JPM017235
Produced Document	ESTATE JPM017236
Produced Document	ESTATE JPMO 17237
Produced Document	ESTATE \_JPM017238
Produced Document	ESTATE \_JPM017239
Produced Document	ESTATE JPMO 17240
Produced Document	ESTATE JPM017241
Produced Document	ESTATE JPM0 17242
Produced Document	ESTATE JPMO 17243
Produced Document	ESTATE \_JPM017244
Produced Document	ESTATE JPMO 17245
Produced Document	ESTATE JPMO 17246
Produced Document	ESTATE\_JPM017247
Produced Document	ESTATE JPMO 17248
Produced Document	ESTATE JPM017249
Produced Document	ESTATE JPM017250

Document Type	Description
Produced Document	ESTATE JPM01725 I
Produced Document	ESTATE JPM0 17252
Produced Document	ESTATE JPM017253
Produced Document	ESTATE JPM017254
Produced Document	ESTATE JPM017255
Produced Document	ESTATE JPM017256
Produced Document	ESTATE JPMO 17257
Produced Document	ESTATE JPM017258
Produced Document	ESTATE \_JPM017259
Produced Document	ESTATE JPMO 17260
Produced Document	ESTATE JPM017261
Produced Document	ESTATE JPM0 17262
Produced Document	ESTATE JPM017263
Produced Document	ESTATE JPM017264
Produced Document	ESTATE JPMO 17265
Produced Document	ESTATE JPM017266
Produced Document	ESTATE\_JPM017267
Produced Document	ESTATE JPMO 17268
Produced Document	ESTATE JPM017269
Produced Document	ESTATE JPM017270
Produced Document	ESTATE JPM017271
Produced Document	ESTATE JPM017272
Produced Document	ESTATE JPM0 17273
Produced Document	ESTATE JPMO 17274
Produced Document	ESTATE JPM017275
Produced Document	ESTATE \_JPM017276
Produced Document	ESTATE JPM017277
Produced Document	ESTATE JPM017278
Produced Document	ESTATE \_JPM017279
Produced Document	ESTATE JPM017280
Produced Document	ESTATE JPM017281
Produced Document	ESTATE \_JPM017282
Produced Document	ESTATE \_JPM017283
Produced Document	ESTATE JPMO 17284
Produced Document	ESTATE JPM017285
Produced Document	ESTATE JPM0 17286
Produced Document	ESTATE JPMO 17287
Produced Document	ESTATE \_JPM017288
Produced Document	ESTATE JPMO 17289
Produced Document	ESTATE JPMO 17290
Produced Document	ESTATE\_JPM017291
Produced Document	ESTATE JPMO 17292
Produced Document	ESTATE JPM017293
Produced Document	ESTATE JPM017294

Document Type	Description
Produced Document	ESTATE JPM017295
Produced Document	ESTATE JPM017296
Produced Document	ESTATE JPM017297
Produced Document	ESTATE JPM017298
Produced Document	ESTATE JPM017299
Produced Document	ESTATE JPM017300
Produced Document	ESTATE JPM017301
Produced Document	ESTATE \_JPM017302
Produced Document	ESTATE \_JPM017303
Produced Document	ESTATE JPM017304
Produced Document	ESTATE JPM017305
Produced Document	ESTATE JPM0 17306
Produced Document	ESTATE JPM017307
Produced Document	ESTATE JPM017308
Produced Document	ESTATE JPMO 17309
Produced Document	ESTATE JPM017310
Produced Document	ESTATE\_JPM017311
Produced Document	ESTATE JPM017312
Produced Document	ESTATE JPM017313
Produced Document	ESTATE JPM017314
Produced Document	ESTATE JPM017315
Produced Document	ESTATE JPM017316
Produced Document	ESTATE JPM017317
Produced Document	ESTATE JPM017318
Produced Document	ESTATE JPM017319
Produced Document	ESTATE \_JPM0 17320
Produced Document	ESTATE JPM017321
Produced Document	ESTATE JPM017322
Produced Document	ESTATE \_JPM017323
Produced Document	ESTATE JPM017324
Produced Document	ESTATE JPMO 17325
Produced Document	ESTATE \_JPM017326
Produced Document	ESTATE JPM017327
Produced Document	ESTATE JPMO 17328
Produced Document	ESTATE JPM017329
Produced Document	ESTATE JPM017330
Produced Document	ESTATE JPM017331
Produced Document	ESTATE \_JPM017332
Produced Document	ESTATE JPMO 17333
Produced Document	ESTATE JPMO 17334
Produced Document	ESTATE\_JPM017335
Produced Document	ESTATE JPMO 17336
Produced Document	ESTATE JPM017337
Produced Document	ESTATE JPMO 17338

Document Type	Description
Produced Document	ESTATE JPM017339
Produced Document	ESTATE \_JPM017340
Produced Document	ESTATE JPM017341
Produced Document	ESTATE JPM017342
Produced Document	ESTATE JPM017343
Produced Document	ESTATE JPM017344
Produced Document	ESTATE JPMO 17345
Produced Document	ESTATE \_JPM017346
Produced Document	ESTATE JPM017347
Produced Document	ESTATE JPM017348
Produced Document	ESTATE JPM017349
Produced Document	ESTATE JPM017350
Produced Document	ESTATE JPM017351
Produced Document	ESTATE JPM017352
Produced Document	ESTATE JPM017353
Produced Document	ESTATE JPM017354
Produced Document	ESTATE \_JPM017355
Produced Document	ESTATE JPM017356
Produced Document	ESTATE JPM017357
Produced Document	ESTATE JPM017358
Produced Document	ESTATE JPM017359
Produced Document	ESTATE JPM017360
Produced Document	ESTATE\_JPM017361
Produced Document	ESTATE JPM017362
Produced Document	ESTATE JPM017363
Produced Document	ESTATE\_JPM017364
Produced Document	ESTATE\_JPM017365
Produced Document	ESTATE JPM017366
Produced Document	ESTATE JPM017367
Produced Document	ESTATE JPM017368
Produced Document	ESTATE JPM017369
Produced Document	ESTATE JPM017370
Produced Document	ESTATE JPM017371
Produced Document	ESTATE JPM017372
Produced Document	ESTATE JPM017373
Produced Document	ESTATE JPM017374
Produced Document	ESTATE JPM017375
Produced Document	ESTATE JPM017376
Produced Document	ESTATE JPM017377
Produced Document	ESTATE JPM017378
Produced Document	ESTATE\_JPM017379
Produced Document	ESTATE JPM017380
Produced Document	ESTATE JPM017381
Produced Document	ESTATE JPM017382

Document Type	Description
Produced Document	ESTATE JPM017383
Produced Document	ESTATE JPM017384
Produced Document	ESTATE JPM017385
Produced Document	ESTATE JPM017386
Produced Document	ESTATE JPM017387
Produced Document	ESTATE JPM017388
Produced Document	ESTATE JPMO 17389
Produced Document	ESTATE \_JPM017390
Produced Document	ESTATE \_JPM017391
Produced Document	ESTATE JPMO 17392
Produced Document	ESTATE JPM017393
Produced Document	ESTATE JPM0 17394
Produced Document	ESTATE JPM017395
Produced Document	ESTATE JPM017396
Produced Document	ESTATE JPMO 17397
Produced Document	ESTATE JPM017398
Produced Document	ESTATE\_JPM017399
Produced Document	ESTATE JPMO 17400
Produced Document	ESTATE JPM017401
Produced Document	ESTATE JPM017402
Produced Document	ESTATE JPMO 17403
Produced Document	ESTATE JPM017404
Produced Document	ESTATE JPM0 17405
Produced Document	ESTATE JPM017406
Produced Document	ESTATE JPMO 17407
Produced Document	ESTATE\_JPM0 17408
Produced Document	ESTATE JPM017409
Produced Document	ESTATE JPM017410
Produced Document	ESTATE \_JPM017411
Produced Document	ESTATE JPM017412
Produced Document	ESTATE JPM017413
Produced Document	ESTATE \_JPM017414
Produced Document	ESTATE \_JPM017415
Produced Document	ESTATE JPM017416
Produced Document	ESTATE JPM017417
Produced Document	ESTATE JPM017418
Produced Document	ESTATE JPM017419
Produced Document	ESTATE \_JPM017420
Produced Document	ESTATE JPM017421
Produced Document	ESTATE JPMO 17422
Produced Document	ESTATE\_JPM017423
Produced Document	ESTATE JPMO 17424
Produced Document	ESTATE JPM017425
Produced Document	ESTATE JPM017426

Document Type	Description
Produced Document	ESTATE JPM017427
Produced Document	ESTATE JPM017428
Produced Document	ESTATE JPM017429
Produced Document	ESTATE JPM017430
Produced Document	ESTATE JPM017431
Produced Document	ESTATE JPM017432
Produced Document	ESTATE JPM017433
Produced Document	ESTATE \_JPM017434
Produced Document	ESTATE JPM017435
Produced Document	ESTATE JPMO 17436
Produced Document	ESTATE JPM017437
Produced Document	ESTATE JPM017438
Produced Document	ESTATE JPM017439
Produced Document	ESTATE JPM017440
Produced Document	ESTATE JPM017441
Produced Document	ESTATE JPM017442
Produced Document	ESTATE\_JPM017443
Produced Document	ESTATE JPM017444
Produced Document	ESTATE JPM017445
Produced Document	ESTATE\_JPM017446
Produced Document	ESTATE JPM017447
Produced Document	ESTATE JPM017448
Produced Document	ESTATE\_JPM017449
Produced Document	ESTATE JPM017450
Produced Document	ESTATE JPM017451
Produced Document	ESTATE \_JPM017452
Produced Document	ESTATE JPM017453
Produced Document	ESTATE JPM017454
Produced Document	ESTATE JPM017455
Produced Document	ESTATE JPM017456
Produced Document	ESTATE JPM017457
Produced Document	ESTATE \_JPM017458
Produced Document	ESTATE JPM017459
Produced Document	ESTATE JPM017460
Produced Document	ESTATE JPM017461
Produced Document	ESTATE JPM017462
Produced Document	ESTATE JPM017463
Produced Document	ESTATE \_JPM017464
Produced Document	ESTATE JPM017465
Produced Document	ESTATE JPM017466
Produced Document	ESTATE\_JPM017467
Produced Document	ESTATE JPM017468
Produced Document	ESTATE JPM017469
Produced Document	ESTATE JPM017470

Document Type	Description
Produced Document	ESTATE JPM017471
Produced Document	ESTATE JPM017472
Produced Document	ESTATE JPM017473
Produced Document	ESTATE JPM017474
Produced Document	ESTATE JPM017475
Produced Document	ESTATE \_JPM017476
Produced Document	ESTATE JPMO 17477
Produced Document	ESTATE JPM017478
Produced Document	ESTATE \_JPM017479
Produced Document	ESTATE JPMO 17480
Produced Document	ESTATE JPM017481
Produced Document	ESTATE JPM0 17482
Produced Document	ESTATE JPM017483
Produced Document	ESTATE JPM017484
Produced Document	ESTATE JPMO 17485
Produced Document	ESTATE JPM017486
Produced Document	ESTATE\_JPM017487
Produced Document	ESTATE JPMO 17488
Produced Document	ESTATE JPM017489
Produced Document	ESTATE\_WMO 17490
Produced Document	ESTATE JPM017491
Produced Document	ESTATE JPM017492
Produced Document	ESTATE JPM0 17493
Produced Document	ESTATE JPMO 17494
Produced Document	ESTATE JPMO 17495
Produced Document	ESTATE \_JPM0 17496
Produced Document	ESTATE JPM017497
Produced Document	ESTATE JPM017498
Produced Document	ESTATE \_JPM017499
Produced Document	ESTATE JPM017500
Produced Document	ESTATE JPM017501
Produced Document	ESTATE \_JPM017502
Produced Document	ESTATE \_JPM017503
Produced Document	ESTATE JPMO 17504
Produced Document	ESTATE JPM017505
Produced Document	ESTATE JPM0 17506
Produced Document	ESTATE JPMO 17507
Produced Document	ESTATE \_JPM017508
Produced Document	ESTATE JPMO 17509
Produced Document	ESTATE JPM017510
Produced Document	ESTATE\_JPM017511
Produced Document	ESTATE JPM017512
Produced Document	ESTATE JPM017513
Produced Document	ESTATE JPM017514

Document Type	Description
Produced Document	ESTATE JPM017515
Produced Document	ESTATE JPM017516
Produced Document	ESTATE JPM017517
Produced Document	ESTATE JPM017518
Produced Document	ESTATE JPM017519
Produced Document	ESTATE JPM017520
Produced Document	ESTATE JPM017521
Produced Document	ESTATE \_JPM017522
Produced Document	ESTATE \_JPM017523
Produced Document	ESTATE JPMO 17524
Produced Document	ESTATE JPM017525
Produced Document	ESTATE JPM0 17526
Produced Document	ESTATE JPM017527
Produced Document	ESTATE JPM017528
Produced Document	ESTATE JPMO 17529
Produced Document	ESTATE JPM017530
Produced Document	ESTATE\_JPM017531
Produced Document	ESTATE JPMO 17532
Produced Document	ESTATE JPM017533
Produced Document	ESTATE JPM017534
Produced Document	ESTATE JPMO 17535
Produced Document	ESTATE JPM017536
Produced Document	ESTATE JPM0 17537
Produced Document	ESTATE JPMO 17538
Produced Document	ESTATE JPMO 17539
Produced Document	ESTATE \_JPM0 17540
Produced Document	ESTATE JPM017541
Produced Document	ESTATE JPM017542
Produced Document	ESTATE \_JPM017543
Produced Document	ESTATE JPM017544
Produced Document	ESTATE JPMO 17545
Produced Document	ESTATE \_JPM017546
Produced Document	ESTATE JPM017547
Produced Document	ESTATE JPMO 17548
Produced Document	ESTATE JPM017549
Produced Document	ESTATE JPM0 17550
Produced Document	ESTATE JPM017551
Produced Document	ESTATE JPM017552
Produced Document	ESTATE JPMO 17553
Produced Document	ESTATE JPMO 17554
Produced Document	ESTATE\_JPM017555
Produced Document	ESTATE JPMO 17556
Produced Document	ESTATE JPM017557
Produced Document	ESTATE JPM0 17558

Document Type	Description
Produced Document	ESTATE JPM017559
Produced Document	ESTATE \_JPM017560
Produced Document	ESTATE \_JPM017561
Produced Document	ESTATE JPM017562
Produced Document	ESTATE JPM017563
Produced Document	ESTATE JPM017564
Produced Document	ESTATE JPM017565
Produced Document	ESTATE \_JPM017566
Produced Document	ESTATE \_JPM017567
Produced Document	ESTATE JPM017568
Produced Document	ESTATE JPM017569
Produced Document	ESTATE JPM017570
Produced Document	ESTATE JPM017571
Produced Document	ESTATE JPM017572
Produced Document	ESTATE JPMO 17573
Produced Document	ESTATE JPM017574
Produced Document	ESTATE\_JPM017575
Produced Document	ESTATE JPMO 17576
Produced Document	ESTATE JPM017577
Produced Document	ESTATE JPM017578
Produced Document	ESTATE JPMO 17579
Produced Document	ESTATE JPM017580
Produced Document	ESTATE JPM017581
Produced Document	ESTATE JPMO 17582
Produced Document	ESTATE JPM017583
Produced Document	ESTATE \_JPM0 17584
Produced Document	ESTATE JPM017585
Produced Document	ESTATE JPM017586
Produced Document	ESTATE \_JPM017587
Produced Document	ESTATE JPM017588
Produced Document	ESTATE JPM017589
Produced Document	ESTATE \_JPM017590
Produced Document	ESTATE \_JPM017591
Produced Document	ESTATE JPMO 17592
Produced Document	ESTATE JPM017593
Produced Document	ESTATE JPM0 17594
Produced Document	ESTATE JPMO 17595
Produced Document	ESTATE \_JPM017596
Produced Document	ESTATE JPMO 17597
Produced Document	ESTATE JPMO 17598
Produced Document	ESTATE\_JPM017599
Produced Document	ESTATE JPMO 17600
Produced Document	ESTATE JPM017601
Produced Document	ESTATE JPM0 17602

Document Type	Description
Produced Document	ESTATE JPM017603
Produced Document	ESTATE \_JPM017604
Produced Document	ESTATE \_JPM017605
Produced Document	ESTATE JPM017606
Produced Document	ESTATE JPM017607
Produced Document	ESTATE JPM017608
Produced Document	ESTATE JPM017609
Produced Document	ESTATE \_JPM017610
Produced Document	ESTATE \_WM017611
Produced Document	ESTATE JPMO 17612
Produced Document	ESTATE JPM017613
Produced Document	ESTATE JPM017614
Produced Document	ESTATE JPM017615
Produced Document	ESTATE JPM017616
Produced Document	ESTATE JPM017617
Produced Document	ESTATE JPM017618
Produced Document	ESTATE \_JPM017619
Produced Document	ESTATE JPM017620
Produced Document	ESTATE JPM017621
Produced Document	ESTATE \_WM017622
Produced Document	ESTATE JPM017623
Produced Document	ESTATE JPM017624
Produced Document	ESTATE JPM017625
Produced Document	ESTATE JPM017626
Produced Document	ESTATE JPM017627
Produced Document	ESTATE \_JPM017628
Produced Document	ESTATE\_JPM017629
Produced Document	ESTATE JPM017630
Produced Document	ESTATE JPM017631
Produced Document	ESTATE JPM017632
Produced Document	ESTATE JPM017633
Produced Document	ESTATE \_JPM017634
Produced Document	ESTATE JPM017635
Produced Document	ESTATE JPM017636
Produced Document	ESTATE JPM017637
Produced Document	ESTATE JPM017638
Produced Document	ESTATE JPM017639
Produced Document	ESTATE JPM017640
Produced Document	ESTATE JPM017641
Produced Document	ESTATE JPM017642
Produced Document	ESTATE\_JPM017643
Produced Document	ESTATE JPM017644
Produced Document	ESTATE JPM017645
Produced Document	ESTATE JPM017646

Document Type	Description
Produced Document	ESTATE JPM017647
Produced Document	ESTATE JPM017648
Produced Document	ESTATE JPM017649
Produced Document	ESTATE JPM017650
Produced Document	ESTATE JPM017651
Produced Document	ESTATE JPM017652
Produced Document	ESTATE JPMO 17653
Produced Document	ESTATE \_JPM017654
Produced Document	ESTATE \_JPM017655
Produced Document	ESTATE JPMO 17656
Produced Document	ESTATE JPM017657
Produced Document	ESTATE JPM0 17658
Produced Document	ESTATE JPM017659
Produced Document	ESTATE JPM017660
Produced Document	ESTATE JPM017661
Produced Document	ESTATE JPM017662
Produced Document	ESTATE\_JPM017663
Produced Document	ESTATE JPMO 17664
Produced Document	ESTATE JPM017665
Produced Document	ESTATE\_JPM017666
Produced Document	ESTATE JPMO 17667
Produced Document	ESTATE JPM017668
Produced Document	ESTATE JPM0 17669
Produced Document	ESTATE JPMO 17670
Produced Document	ESTATE JPM017671
Produced Document	ESTATE \_JPM017672
Produced Document	ESTATE JPM017673
Produced Document	ESTATE JPM017674
Produced Document	ESTATE \_JPM017675
Produced Document	ESTATE JPM017676
Produced Document	ESTATE JPMO 17677
Produced Document	ESTATE \_JPM017678
Produced Document	ESTATE JPM017679
Produced Document	ESTATE JPMO 17680
Produced Document	ESTATE JPM017681
Produced Document	ESTATE JPM0 17682
Produced Document	ESTATE JPMO 17683
Produced Document	ESTATE \_JPM017684
Produced Document	ESTATE JPMO 17685
Produced Document	ESTATE JPMO 17686
Produced Document	ESTATE \_JPM017687
Produced Document	ESTATE JPMO 17688
Produced Document	ESTATE JPM017689
Produced Document	ESTATE JPM017690

Document Type	Description
Produced Document	ESTATE JPM01769 I
Produced Document	ESTATE JPM017692
Produced Document	ESTATE JPM017693
Produced Document	ESTATE JPM017694
Produced Document	ESTATE JPM017695
Produced Document	ESTATE JPM017696
Produced Document	ESTATE JPMO 17697
Produced Document	ESTATE \_JPM017698
Produced Document	ESTATE \_JPM017699
Produced Document	ESTATE JPM017700
Produced Document	ESTATE JPM017701
Produced Document	ESTATE JPM0 17702
Produced Document	ESTATE JPM017703
Produced Document	ESTATE JPM017704
Produced Document	ESTATE JPMO 17705
Produced Document	ESTATE JPM017706
Produced Document	ESTATE\_JPM017707
Produced Document	ESTATE JPMO 17708
Produced Document	ESTATE JPM017709
Produced Document	ESTATE JPM017710
Produced Document	ESTATE JPM017711
Produced Document	ESTATE JPM017712
Produced Document	ESTATE JPM017713
Produced Document	ESTATE JPM017714
Produced Document	ESTATE JPM017715
Produced Document	ESTATE\_JPM017716
Produced Document	ESTATE JPM017717
Produced Document	ESTATE JPM017718
Produced Document	ESTATE JPM017719
Produced Document	ESTATE JPM017720
Produced Document	ESTATE JPM017721
Produced Document	ESTATE \_JPM017722
Produced Document	ESTATE \_JPM017723
Produced Document	ESTATE JPMO 17724
Produced Document	ESTATE JPM017725
Produced Document	ESTATE JPM0 17726
Produced Document	ESTATE JPMO 17727
Produced Document	ESTATE \_JPM017728
Produced Document	ESTATE JPMO 17729
Produced Document	ESTATE JPMO 17730
Produced Document	ESTATE \_JPM017731
Produced Document	ESTATE JPMO 17732
Produced Document	ESTATE JPM017733
Produced Document	ESTATE JPM0 17734

Document Type	Description
Produced Document	ESTATE JPM017735
Produced Document	ESTATE JPM0 17736
Produced Document	ESTATE JPM017737
Produced Document	ESTATE JPM017738
Produced Document	ESTATE JPM017739
Produced Document	ESTATE JPM017740
Produced Document	ESTATE JPM017741
Produced Document	ESTATE \_JPM017742
Produced Document	ESTATE \_JPM017743
Produced Document	ESTATE JPM017744
Produced Document	ESTATE JPM017745
Produced Document	ESTATE JPM017746
Produced Document	ESTATE JPM017747
Produced Document	ESTATE JPM017748
Produced Document	ESTATE JPMO 17749
Produced Document	ESTATE JPM017750
Produced Document	ESTATE\_JPM017751
Produced Document	ESTATE JPMO 17752
Produced Document	ESTATE JPM017753
Produced Document	ESTATE JPM017754
Produced Document	ESTATE JPMO 17755
Produced Document	ESTATE JPM017756
Produced Document	ESTATE JPM0 17757
Produced Document	ESTATE JPMO 17758
Produced Document	ESTATE JPM017759
Produced Document	ESTATE\_JPM0 17760
Produced Document	ESTATE \_JPM017761
Produced Document	ESTATE JPM017762
Produced Document	ESTATE JPM017763
Produced Document	ESTATE JPM017764
Produced Document	ESTATE JPMO 17765
Produced Document	ESTATE \_JPM017766
Produced Document	ESTATE \_JPM017767
Produced Document	ESTATE JPMO 17768
Produced Document	ESTATE JPM017769
Produced Document	ESTATE JPM0 17770
Produced Document	ESTATE JPM017771
Produced Document	ESTATE \_JPM017772
Produced Document	ESTATE JPMO 17773
Produced Document	ESTATE JPMO 17774
Produced Document	ESTATE\_JPM017775
Produced Document	ESTATE JPMO 17776
Produced Document	ESTATE JPM017777
Produced Document	ESTATE JPM0 17778

Document Type	Description
Produced Document	ESTATE JPM017779
Produced Document	ESTATE \_JPM017780
Produced Document	ESTATE \_JPM017781
Produced Document	ESTATE JPM017782
Produced Document	ESTATE JPM017783
Produced Document	ESTATE JPM017784
Produced Document	ESTATE JPMO 17785
Produced Document	ESTATE \_JPM017786
Produced Document	ESTATE \_JPM017787
Produced Document	ESTATE JPM017788
Produced Document	ESTATE JPM017789
Produced Document	ESTATE JPM0 17790
Produced Document	ESTATE JPM017791
Produced Document	ESTATE JPM017792
Produced Document	ESTATE JPMO 17793
Produced Document	ESTATE JPM017794
Produced Document	ESTATE\_JPM017795
Produced Document	ESTATE JPMO 17796
Produced Document	ESTATE JPM017797
Produced Document	ESTATE JPM017798
Produced Document	ESTATE JPMO 17799
Produced Document	ESTATE JPM017800
Produced Document	ESTATE JPM017801
Produced Document	ESTATE JPMO 17802
Produced Document	ESTATE JPMO 17803
Produced Document	ESTATE\_JPM0 17804
Produced Document	ESTATE JPM017805
Produced Document	ESTATE JPM017806
Produced Document	ESTATE \_JPM017807
Produced Document	ESTATE JPM017808
Produced Document	ESTATE JPM017809
Produced Document	ESTATE \_JPM017810
Produced Document	ESTATE \_JPM01781 I
Produced Document	ESTATE JPM017812
Produced Document	ESTATE JPM017813
Produced Document	ESTATE JPM017814
Produced Document	ESTATE JPM017815
Produced Document	ESTATE \_JPM017816
Produced Document	ESTATE JPM017817
Produced Document	ESTATE JPM017818
Produced Document	ESTATE\_JPM017819
Produced Document	ESTATE JPMO 17820
Produced Document	ESTATE JPM017821
Produced Document	ESTATE JPM017822

Document Type	Description
Produced Document	ESTATE JPM017823
Produced Document	ESTATE JPM017824
Produced Document	ESTATE JPM017825
Produced Document	ESTATE JPM017826
Produced Document	ESTATE JPM017827
Produced Document	ESTATE JPM017828
Produced Document	ESTATE JPMO 17829
Produced Document	ESTATE \_JPM017830
Produced Document	ESTATE \_JPM017831
Produced Document	ESTATE JPM017832
Produced Document	ESTATE JPM017833
Produced Document	ESTATE JPM0 17834
Produced Document	ESTATE JPM017835
Produced Document	ESTATE JPM017836
Produced Document	ESTATE JPMO 17837
Produced Document	ESTATE JPM017838
Produced Document	ESTATE\_JPM017839
Produced Document	ESTATE JPMO 17840
Produced Document	ESTATE JPM017841
Produced Document	ESTATE\_JPM017842
Produced Document	ESTATE JPMO 17843
Produced Document	ESTATE JPM017844
Produced Document	ESTATE JPM0 17845
Produced Document	ESTATE JPMO 17846
Produced Document	ESTATE JPMO 17847
Produced Document	ESTATE \_JPM0 17848
Produced Document	ESTATE JPM017849
Produced Document	ESTATE JPMO 17850
Produced Document	ESTATE \_JPM017851
Produced Document	ESTATE JPM017852
Produced Document	ESTATE JPMO 17853
Produced Document	ESTATE JPM017854
Produced Document	ESTATE \_JPM017855
Produced Document	ESTATE JPM017856
Produced Document	ESTATE JPMO 17857
Produced Document	ESTATE JPM0 17858
Produced Document	ESTATE JPMO 17859
Produced Document	ESTATE \_JPM017860
Produced Document	ESTATE JPM017861
Produced Document	ESTATE JPMO 17862
Produced Document	ESTATE\_JPM017863
Produced Document	ESTATE JPMO 17864
Produced Document	ESTATE JPM017865
Produced Document	ESTATE JPM017866

Document Type	Description
Produced Document	ESTATE JPM017867
Produced Document	ESTATE JPM017868
Produced Document	ESTATE JPM017869
Produced Document	ESTATE JPM017870
Produced Document	ESTATE JPM017871
Produced Document	ESTATE JPM017872
Produced Document	ESTATE JPM017873
Produced Document	ESTATE \_JPM017874
Produced Document	ESTATE JPM017875
Produced Document	ESTATE JPM017876
Produced Document	ESTATE JPM017877
Produced Document	ESTATE JPM017878
Produced Document	ESTATE JPM017879
Produced Document	ESTATE JPM017880
Produced Document	ESTATE JPM017881
Produced Document	ESTATE JPM017882
Produced Document	ESTATE \_JPM017883
Produced Document	ESTATE JPM017884
Produced Document	ESTATE JPM017885
Produced Document	ESTATE JPM017886
Produced Document	ESTATE JPM017887
Produced Document	ESTATE JPM017888
Produced Document	ESTATE\_JPM017889
Produced Document	ESTATE JPM017890
Produced Document	ESTATE JPM017891
Produced Document	ESTATE\_JPM017892
Produced Document	ESTATE\_JPM017893
Produced Document	ESTATE JPM017894
Produced Document	ESTATE JPM017895
Produced Document	ESTATE JPM017896
Produced Document	ESTATE JPM017897
Produced Document	ESTATE JPM017898
Produced Document	ESTATE JPM017899
Produced Document	ESTATE JPM017900
Produced Document	ESTATE JPM017901
Produced Document	ESTATE \_JPM017902
Produced Document	ESTATE JPM017903
Produced Document	ESTATE \_JPM017904
Produced Document	ESTATE JPM017905
Produced Document	ESTATE JPM017906
Produced Document	ESTATE\_JPM017907
Produced Document	ESTATE JPM017908
Produced Document	ESTATE JPM017909
Produced Document	ESTATE JPM017910

Document Type	Description
Produced Document	ESTATE JPM01791 I
Produced Document	ESTATE JPM017912
Produced Document	ESTATE JPM017913
Produced Document	ESTATE JPM017914
Produced Document	ESTATE JPM017915
Produced Document	ESTATE JPM017916
Produced Document	ESTATE JPM017917
Produced Document	ESTATE JPM017918
Produced Document	ESTATE \_JPM017919
Produced Document	ESTATE JPM017920
Produced Document	ESTATE JPM017921
Produced Document	ESTATE JPM0 17922
Produced Document	ESTATE JPM017923
Produced Document	ESTATE JPM017924
Produced Document	ESTATE JPMO 17925
Produced Document	ESTATE JPM017926
Produced Document	ESTATE\_JPM017927
Produced Document	ESTATE JPMO 17928
Produced Document	ESTATE JPM017929
Produced Document	ESTATE JPM0 17930
Produced Document	ESTATE JPM017931
Produced Document	ESTATE JPM017932
Produced Document	ESTATE\_WMO 17933
Produced Document	ESTATE JPMO 17934
Produced Document	ESTATE JPMO 17935
Produced Document	ESTATE \_JPM0 17936
Produced Document	ESTATE JPM017937
Produced Document	ESTATE JPM017938
Produced Document	ESTATE \_JPM017939
Produced Document	ESTATE JPM017940
Produced Document	ESTATE JPM017941
Produced Document	ESTATE \_JPM017942
Produced Document	ESTATE \_JPM017943
Produced Document	ESTATE JPMO 17944
Produced Document	ESTATE JPM017945
Produced Document	ESTATE JPM017946
Produced Document	ESTATE JPMO 17947
Produced Document	ESTATE \_WM017948
Produced Document	ESTATE JPMO 17949
Produced Document	ESTATE JPMO 17950
Produced Document	ESTATE\_JPM017951
Produced Document	ESTATE JPMO 17952
Produced Document	ESTATE JPM017953
Produced Document	ESTATE JPMO 17954

Document Type	Description
Produced Document	ESTATE JPM017955
Produced Document	ESTATE JPM0 17956
Produced Document	ESTATE JPM017957
Produced Document	ESTATE JPM017958
Produced Document	ESTATE JPM017959
Produced Document	ESTATE JPM017960
Produced Document	ESTATE JPM017961
Produced Document	ESTATE \_JPM017962
Produced Document	ESTATE \_JPM017963
Produced Document	ESTATE JPMO 17964
Produced Document	ESTATE JPM017965
Produced Document	ESTATE JPM0 17966
Produced Document	ESTATE JPM017967
Produced Document	ESTATE JPM017968
Produced Document	ESTATE JPMO 17969
Produced Document	ESTATE JPM017970
Produced Document	ESTATE\_JPM017971
Produced Document	ESTATE JPMO 17972
Produced Document	ESTATE JPM017973
Produced Document	ESTATE JPM017974
Produced Document	ESTATE JPMO 17975
Produced Document	ESTATE JPM017976
Produced Document	ESTATE JPM0 17977
Produced Document	ESTATE JPMO 17978
Produced Document	ESTATE JPMO 17979
Produced Document	ESTATE \_JPM0 17980
Produced Document	ESTATE JPM017981
Produced Document	ESTATE JPM017982
Produced Document	ESTATE \_JPM017983
Produced Document	ESTATE JPM017984
Produced Document	ESTATE JPMO 17985
Produced Document	ESTATE \_JPM017986
Produced Document	ESTATE \_JPM017987
Produced Document	ESTATE JPMO 17988
Produced Document	ESTATE JPM017989
Produced Document	ESTATE JPM0 17990
Produced Document	ESTATE JPM017991
Produced Document	ESTATE \_JPM017992
Produced Document	ESTATE JPMO 17993
Produced Document	ESTATE JPMO 17994
Produced Document	ESTATE\_JPM017995
Produced Document	ESTATE JPMO 17996
Produced Document	ESTATE JPM017997
Produced Document	ESTATE JPM0 17998

Document Type	Description
Produced Document	ESTATE JPM017999
Produced Document	ESTATE \_JPM018000
Produced Document	ESTATE JPM018001
Produced Document	ESTATE JPM018002
Produced Document	ESTATE JPM018003
Produced Document	ESTATEJPM018004
Produced Document	ESTATE JPM018005
Produced Document	ESTATE \_JPM018006
Produced Document	ESTATE\_JPM018007
Produced Document	ESTATE JPM018008
Produced Document	ESTATE JPM018009
Produced Document	ESTATE JPM018010
Produced Document	ESTATE JPM018011
Produced Document	ESTATE JPM018012
Produced Document	ESTATE JPM018013
Produced Document	ESTATE JPM018014
Produced Document	ESTATE \_JPM018015
Produced Document	ESTATE JPM018016
Produced Document	ESTATE JPM018017
Produced Document	ESTATE \_WM018018
Produced Document	ESTATE JPM018019
Produced Document	ESTATE JPM018020
Produced Document	ESTATE \_WM018021
Produced Document	ESTATE JPM018022
Produced Document	ESTATE JPM018023
Produced Document	ESTATE\_JPM018024
Produced Document	ESTATE\_JPM018025
Produced Document	ESTATE JPM018026
Produced Document	ESTATE JPM018027
Produced Document	ESTATE JPM018028
Produced Document	ESTATE JPM018029
Produced Document	ESTATE \_JPM018030
Produced Document	ESTATE JPM018031
Produced Document	ESTATE JPM018032
Produced Document	ESTATE JPM018033
Produced Document	ESTATE JPM018034
Produced Document	ESTATE JPM018035
Produced Document	ESTATE \_JPM018036
Produced Document	ESTATE JPM018037
Produced Document	ESTATE JPM018038
Produced Document	ESTATE\_JPM018039
Produced Document	ESTATE JPM018040
Produced Document	ESTATE JPM018041
Produced Document	ESTATE JPM018042

Document Type	Description
Produced Document	ESTATE JPM018043
Produced Document	ESTATE JPM018044
Produced Document	ESTATE\_JPM018045
Produced Document	ESTATE JPM018046
Produced Document	ESTATE JPM018047
Produced Document	ESTATE JPM018048
Produced Document	ESTATE JPM018049
Produced Document	ESTATE JPM018050
Produced Document	ESTATE JPM018051
Produced Document	ESTATE JPM018052
Produced Document	ESTATE JPM018053
Produced Document	ESTATE JPM018054
Produced Document	ESTATE JPM018055
Produced Document	ESTATE JPM018056
Produced Document	ESTATE JPM018057
Produced Document	ESTATE JPM018058
Produced Document	ESTATE JPM018059
Produced Document	ESTATE JPM018060
Produced Document	ESTATE JPM018061
Produced Document	ESTATE JPM018062
Produced Document	ESTATE JPM018063
Produced Document	ESTATE JPM018064
Produced Document	ESTATE JPM018065
Produced Document	ESTATE JPM018066
Produced Document	ESTATE JPM018067
Produced Document	ESTATE JPM018068
Produced Document	ESTATE\_JPM018069
Produced Document	ESTATE JPM018070
Produced Document	ESTATE JPM018071
Produced Document	ESTATE JPM018072
Produced Document	ESTATE JPM018073
Produced Document	ESTATE JPM018074
Produced Document	ESTATE JPM018075
Produced Document	ESTATE JPM018076
Produced Document	ESTATE JPM018077
Produced Document	ESTATE JPM018078
Produced Document	ESTATE JPM018079
Produced Document	ESTATE JPM018080
Produced Document	ESTATE JPM018081
Produced Document	ESTATE JPM018082
Produced Document	ESTATE JPM018083
Produced Document	ESTATE JPM018084
Produced Document	ESTATE JPM018085
Produced Document	ESTATE JPM018086

Document Type	Description
Produced Document	ESTATE JPM018087
Produced Document	ESTATE \_JPM018088
Produced Document	ESTATE \_JPM018089
Produced Document	ESTATE JPM018090
Produced Document	ESTATE JPM018091
Produced Document	ESTATE JPM018092
Produced Document	ESTATE JPM018093
Produced Document	ESTATE \_JPM018094
Produced Document	ESTATE JPM018095
Produced Document	ESTATE JPM018096
Produced Document	ESTATE JPM018097
Produced Document	ESTATE JPM018098
Produced Document	ESTATE JPM018099
Produced Document	ESTATE JPM018100
Produced Document	ESTATE JPM018101
Produced Document	ESTATE JPM018102
Produced Document	ESTATE \_JPM018103
Produced Document	ESTATE JPM018104
Produced Document	ESTATE JPM018105
Produced Document	ESTATE\_JPM018106
Produced Document	ESTATE JPM018107
Produced Document	ESTATE JPM018108
Produced Document	ESTATE JPM018109
Produced Document	ESTATE JPM018110
Produced Document	ESTATE JPM018111
Produced Document	ESTATE \_JPM018112
Produced Document	ESTATE JPM018113
Produced Document	ESTATE JPM018114
Produced Document	ESTATE JPM018115
Produced Document	ESTATE JPM018116
Produced Document	ESTATE JPM018117
Produced Document	ESTATE JPM018118
Produced Document	ESTATE JPM018119
Produced Document	ESTATE JPM018120
Produced Document	ESTATE JPM018121
Produced Document	ESTATE JPM018122
Produced Document	ESTATE JPM018123
Produced Document	ESTATE JPM018124
Produced Document	ESTATE JPM018125
Produced Document	ESTATE JPM018126
Produced Document	ESTATE\_JPM018127
Produced Document	ESTATE JPM018128
Produced Document	ESTATE JPM018129
Produced Document	ESTATE \_WM018130

Document Type	Description
Produced Document	ESTATE JPM01813 I
Produced Document	ESTATE JPM018132
Produced Document	ESTATE JPM018133
Produced Document	ESTATE JPM018134
Produced Document	ESTATE JPM018135
Produced Document	ESTATE JPM018136
Produced Document	ESTATE JPM018137
Produced Document	ESTATE \_JPM018138
Produced Document	ESTATE \_JPM018139
Produced Document	ESTATE JPM018140
Produced Document	ESTATE JPM018141
Produced Document	ESTATE JPM018142
Produced Document	ESTATE JPM018143
Produced Document	ESTATE JPM018144
Produced Document	ESTATE JPM018145
Produced Document	ESTATE JPM018146
Produced Document	ESTATE\_JPM018147
Produced Document	ESTATE JPM018148
Produced Document	ESTATE JPM018149
Produced Document	ESTATE JPM018150
Produced Document	ESTATE JPM018151
Produced Document	ESTATE JPM018152
Produced Document	ESTATE\_WM018153
Produced Document	ESTATE JPM018154
Produced Document	ESTATE JPM018155
Produced Document	ESTATE JPM018156
Produced Document	ESTATE \_JPM018157
Produced Document	ESTATE JPM018158
Produced Document	ESTATE \_JPM018159
Produced Document	ESTATE JPM018160
Produced Document	ESTATE JPM018161
Produced Document	ESTATE \_JPM018162
Produced Document	ESTATE \_JPM018163
Produced Document	ESTATE JPM018164
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
Produced Document	ESTATE JPM018177
Produced Document	ESTATE JPM018178
Produced Document	ESTATE JPM018179
Produced Document	ESTATE JPM018180
Produced Document	ESTATE JPM018181
Produced Document	ESTATE \_JPM018182
Produced Document	ESTATE JPM018183
Produced Document	ESTATE JPM018184
Produced Document	ESTATE JPM018185
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
Produced Document	ESTATE JPM018198
Produced Document	ESTATE JPM018199
Produced Document	ESTATE\_JPM018200
Produced Document	ESTATE\_JPM018201
Produced Document	ESTATE JPM018202
Produced Document	ESTATE JPM018203
Produced Document	ESTATE JPM018204
Produced Document	ESTATE JPM018205
Produced Document	ESTATE \_JPM018206
Produced Document	ESTATE JPM018207
Produced Document	ESTATE JPM018208
Produced Document	ESTATE JPM018209
Produced Document	ESTATE JPM018210
Produced Document	ESTATE JPM018211
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
Produced Document	JDoe\_JPMC\_007436
Produced Document	JDoe JPMC 007438
Produced Document	JDoe JPMC 007449
Produced Document	JDoe\_JPMC\_007449
Produced Document	JDoe\_JPMC\_007465
Produced Document	JDoe JPMC 007470
Produced Document	JDoe\_JPMC\_007472
Produced Document	JDoe\_JPMC\_007474
Produced Document	JDoe JPMC 007486
Produced Document	JDoe\_JPMC\_007489
Produced Document	JDoe\_JPMC\_007492
Produced Document	JDoe JPMC 007509
Produced Document	JDoe\_JPMC\_007514
Produced Document	JDoe\_JPMC\_007514
Produced Document	JDoe JPMC 007567
Produced Document	JDoe JPMC 007650
Produced Document	JDoe\_JPMC\_007653
Produced Document	JDoe JPMC 007656
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
Produced Document	JDoe\_JPMC\_007715

Document Type	Description
Produced Document	JDoe JPMC 007718
Produced Document	JDoe\_JPMC\_007723
Produced Document	JDoe\_JPMC\_007725
Produced Document	JDoe JPMC 007726
Produced Document	JDoe\_JPMC\_007727
Produced Document	JDoe\_JPMC\_007731
Produced Document	JDoe JPMC 007733
Produced Document	JDoe\_JPMC\_007735
Produced Document	JDoe\_JPMC\_007737
Produced Document	JDoe JPMC 007738
Produced Document	JDoe JPMC 007739
Produced Document	JDoe\_JPMC\_007740
Produced Document	JDoe JPMC 007741
Produced Document	JDoe JPMC 007742
Produced Document	JDoe JPMC\_007743
Produced Document	JDoe JPMC 007744
Produced Document	JDoe\_JPMC\_007745
Produced Document	JDoe JPMC 007746
Produced Document	JDoe JPMC 007747
Produced Document	JDoe\_JPMC\_007748
Produced Document	JDoe JPMC 007749
Produced Document	JDoe JPMC 007750
Produced Document	JDoe\_JPMC\_007751
Produced Document	JDoe\_JPMC\_007752
Produced Document	JDoe JPMC 007753
Produced Document	JDoe\_JPMC\_007754
Produced Document	JDoe\_JPMC\_007755
Produced Document	JDoe JPMC 007756
Produced Document	JDoe\_JPMC\_007757
Produced Document	JDoe\_JPMC\_007758
Produced Document	JDoe JPMC 007759
Produced Document	JDoe\_JPMC\_007760
Produced Document	JDoe\_JPMC\_007761
Produced Document	JDoe JPMC 007762
Produced Document	JDoe JPMC 007763
Produced Document	JDoe\_JPMC\_007764
Produced Document	JDoe JPMC 007765
Produced Document	JDoe JPMC 007766
Produced Document	JDoe JPMC 007767
Produced Document	JDoe JPMC 007768
Produced Document	JDoe\_JPMC\_007769
Produced Document	JDoe JPMC 007770
Produced Document	JDoe JPMC 007771
Produced Document	JDoe\_JPMC\_007772

Document Type	Description
Produced Document	JDoe JPMC 007773
Produced Document	JDoe\_JPMC\_007774
Produced Document	JDoe\_JPMC\_007775
Produced Document	JDoe JPMC 007776
Produced Document	JDoe\_JPMC\_007777
Produced Document	JDoe\_JPMC\_007778
Produced Document	JDoe JPMC 007779
Produced Document	JDoe\_JPMC\_007780
Produced Document	JDoe\_JPMC\_007781
Produced Document	JDoe JPMC 007782
Produced Document	JDoe JPMC 007783
Produced Document	JDoe\_JPMC\_007784
Produced Document	JDoe JPMC 007785
Produced Document	JDoe\_JPMC\_007786
Produced Document	JDoe JPMC 007787
Produced Document	JDoe JPMC 007788
Produced Document	JDoe\_JPMC\_007789
Produced Document	JDoe JPMC\_007790
Produced Document	JDoe JPMC 007791
Produced Document	JDoe\_JPMC\_007792
Produced Document	JDoe JPMC 007793
Produced Document	JDoe JPMC 007794
Produced Document	JDoe\_JPMC\_007795
Produced Document	JDoe\_JPMC\_007796
Produced Document	JDoe JPMC 007797
Produced Document	JDoe\_JPMC\_007798
Produced Document	JDoe\_JPMC\_007799
Produced Document	JDoe JPMC 007800
Produced Document	JDoe\_JPMC\_007801
Produced Document	JDoe\_JPMC\_007802
Produced Document	JDoe JPMC 007803
Produced Document	JDoe\_JPMC\_007804
Produced Document	JDoe\_JPMC\_007805
Produced Document	JDoe JPMC 007806
Produced Document	JDoe JPMC 007807
Produced Document	JDoe\_JPMC\_007808
Produced Document	JDoe JPMC 007809
Produced Document	JDoe JPMC 007810
Produced Document	JDoe JPMC 007811
Produced Document	JDoe JPMC 007812
Produced Document	JDoe\_JPMC\_007813
Produced Document	JDoe JPMC 007814
Produced Document	JDoe JPMC 007815
Produced Document	JDoe\_JPMC\_007816

Document Type	Description
Produced Document	JDoe JPMC 007817
Produced Document	JDoe\_JPMC\_007818
Produced Document	JDoe\_JPMC\_007819
Produced Document	JDoe JPMC 007820
Produced Document	JDoe\_JPMC\_007821
Produced Document	JDoe\_JPMC\_007822
Produced Document	JDoe JPMC 007823
Produced Document	JDoe\_JPMC\_007824
Produced Document	JDoe\_JPMC\_007825
Produced Document	JDoe JPMC 007826
Produced Document	JDoe JPMC 007827
Produced Document	JDoe\_JPMC\_007828
Produced Document	JDoe JPMC 007829
Produced Document	JDoe JPMC 007830
Produced Document	JDoe JPMC 007831
Produced Document	JDoe JPMC 007832
Produced Document	JDoe\_JPMC\_007833
Produced Document	JDoe JPMC 007834
Produced Document	JDoe JPMC 007835
Produced Document	JDoe\_JPMC\_007836
Produced Document	JDoe JPMC 007837
Produced Document	JDoe JPMC 007838
Produced Document	JDoe\_JPMC\_007839
Produced Document	JDoe\_JPMC\_007840
Produced Document	JDoe JPMC 007841
Produced Document	JDoe\_JPMC\_007842
Produced Document	JDoe\_JPMC\_007843
Produced Document	JDoe JPMC 007844
Produced Document	JDoe\_JPMC\_007845
Produced Document	JDoe\_JPMC\_007846
Produced Document	JDoe JPMC 007847
Produced Document	JDoe\_JPMC\_007848
Produced Document	JDoe\_JPMC\_007849
Produced Document	JDoe JPMC 007850
Produced Document	JDoe JPMC 007851
Produced Document	JDoe\_JPMC\_007852
Produced Document	JDoe JPMC 007853
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. ¶