In his 54-page opinion, Judge Jed Rakoff resolved motions to dismiss in the consolidated Epstein-survivor suits against JPMorgan Chase and Deutsche Bank, peeling back several legal theories while allowing core claims to proceed. He rejected defendants’ efforts to toss allegations under federal and territorial racketeering statutes, finding those claims insufficiently tied to Epstein’s sex-trafficking venture. But Rakoff preserved the plaintiffs’ key causes of action under the Trafficking Victims Protection Act (TVPA) and negligence theories, ruling that the surviving complaints adequately allege that the banks either knew or should have known of Epstein’s illicit conduct and materially supported it through “routine” banking services that allegedly enabled his operations.
Rakoff’s opinion also granted class certification under Rule 23(b)(3), finding that plaintiffs satisfied numerosity, commonality, typicality, and adequacy, and that common questions of law or fact would predominate over individual issues. He recognized certain individualized elements—such as causation, coercion, or statute-of-limitations questions—but deemed them “peripheral” and manageable via case-management tools.
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