A willful misconduct clause is added to most every contract between companies that is written and agreed to. Where is your proof that JPM has been adjudicated as having violated that clause and that they have been ordered to cough up a specific penalty amount?
Why can't you simply admit that all you have is hope and theories, but that you can't really prove anything?
How about this: go ahead and state clearly here that you have "proven" that returns are coming to legacy escrow (and it wouldn't hurt to show a document and explain just how it proves it).
Stop trying to obfuscate by making it seem like you got me with a document that you know doesn't prove that.