The Moscow Murders and More

The USVI And Ther Motion For A Partial Summary Judgement Against JP Morgan (Parts 4-6) (12/31/24)

The case 1:22-cv-10904-JSR involves the Government of the United States Virgin Islands (USVI) against JPMorgan Chase & Co. The case primarily focuses on the allegations that JPMorgan Chase facilitated and benefited from Jeffrey Epstein's illegal activities, particularly his sex trafficking enterprise.Summary of the Memorandum of Law in Support of Motion for Partial Summary Judgment

Background and Legal Context:
- The USVI government argues that JPMorgan Chase had actual knowledge of Epstein’s illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.
Key Arguments:
- Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein’s illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.
- Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.
- Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein’s suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.
Legal Standards and Precedent:
- The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.
Request for Partial Summary Judgment:
- The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase’s liability for facilitating Epstein’s criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.
Conclusion:
- The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.

The document is part of the ongoing legal battle to hold JPMorgan Chase accountable for its alleged role in facilitating Jeffrey Epstein's criminal network through its banking services.

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to contact me:

bobbycapucci@protonmail.com

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Microsoft Word - MSJ BRIEF 7.24.23 Final WORD_Highlighted Black for Redactions (courtlistener.com)

Duration:: 35m
Broadcast on:: 31 Dec 2024
Audio Format:: other

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JP Morgan argued that the government must allege that it received revenue from Epstein in exchange for the bank's furtherance of Epstein's sex trafficking venture. The court is not convinced that the benefit element should be read in that way. Order at 31 and indeed the statutory language imposes no such casual relationship requirement. JP Morgan admits it receive fees and other revenue from providing services to Epstein's affiliated entities order at 31. In any event from at least 2006 to Epstein's arrest in 2019 JP Morgan knowingly benefited from furthering Epstein's sex trafficking venture. In her about two thousand time period Sandy Warner then head of JP Morgan told Staley then head of PB you should meet Epstein he's one of the most connected people I know in New York Warner was right. By 2003 Epstein had introduced Staley to Google's founders Sir J. Bryn and Larry Page and helped source billionaire hedge fund hybrid genre Glenn Dubin. By then Epstein was also bringing in over eight million dollars in revenue to the private bank. The top revenue and nearly double the amount of the next highest client. In 2003 Epstein through the trading of his accounts and that of Leslie Wexner generates one of the largest annual revenue flows of private clients in the private bank. The following year Epstein facilitated JP Morgan's acquisition of hybrid a game changing acquisition for JP Morgan. Hybrid a hedge fund with seven billion in assets under management was co-founded by Epstein's close friend Dubin and Epstein was a founding investor. Epstein advised both JP Morgan and hybrid on the acquisition and work with diamond then CEO and waiting Bill Harrison then CEO and other JP Morgan chase executive management on acquisition. Epstein was paid 15 million dollars in consulting fees for his work on the acquisition. Epstein also continued to facilitate introductions to the bank including a meeting between Staley and the Sultan of Dubai. This sets the stage for 2006 after Epstein was arrested for felony sex crimes and confessed his conduct to Staley when JP Morgan could have exited Epstein but did not. Instead at the rapid response meeting the private bank imposed a condition on his accounts supposedly to mitigate the risk he could remain in a banking but not an investment client but when it later benefited the bank the restrictions were ignored and by 2011 Epstein was the private bank's investment arms biggest revenue producer. The rapid response meeting was a fiction in other respects though JP Morgan was supposedly considering terminating its relationship with Epstein at precisely the same time. The bank was actively trying to find a New York home for Epstein's accounts as the advisor to the Google founders a relationship that would become one of the largest in the private bank. The bank was also actively growing the Epstein relationship between post indictment and post conviction rapid response meetings Epstein's assets under management increased fourfold from 32 million to over 120 million. By September 3rd 2008 when Epstein's private banker Casey thought his assets were a probable outflow pending diamond review Epstein's accounts were worth more than 156 million and needless to say were not outflowed. Within months of public reports that Epstein was engaged in sexual abuse of girls potentially tied to MC2 JP Morgan moved forward with renewing Epstein's loan to MC2. The bank's only concern are we comfortable taking on additional credit exposure just ahead of his pending plea arrangement JP Morgan also kept banking Epstein despite its knowledge of his sex trafficking because it was trying to settle lawsuits he had against the bank one related to his investments at Bear Stearns and another in redacted. In 2011 as JP Morgan had near settled Epstein's claims against Bear Stearns Cutler wrote the air dose I would like to put it and him behind us not a person that we should do business with period but as shanker then general counsel explained to air dose at the conclusion of JE approval of Bear Stearns settlement asked when we are offboarding JE I reminded him that we have the other matter outstanding at the time the bank was still trying to settle redacted in 2008 Bear Stearns now part of JP Morgan had made it known that it wanted to keep Epstein as a brokerage client despite his felony conviction. Allen a screenberg former chairman of Bear Stearns and now with JP Morgan also wanted to continue to do business with Epstein and sought an exception to the felony policy which on paper required that the GC Cutler approved retaining Epstein in addition throughout spring and summer of 2011 Epstein helped air dose and Staley who JP Morgan admits were involved in the decision to maintain Epstein at the bank put together a proposal for a hundred billion dollar donor advised fund for the Gates Foundation which air dose and Staley presented to the Gates Foundation on August 31st of 2011 air dose communicated frequently with Epstein redacted during DAF development and pitch process throughout Epstein continued to connect JP Morgan with the world's dignitaries and wealthiest people including among others Gates Boris Nickelich advisor to Gates summers the sultan of Dubai Prince Andrew Barack Netanyahu David Gurgen former advisor to Nixon Ford Reagan in Clinton Pritzker and Mandelson Epstein also continued to bring in significant revenues to the bank Epstein was also a personal resource to Staley and air dose to business executives who JP Morgan does not dispute were involved in the decision to maintain Epstein at the bank Epstein helped Staley with redacted in 2005 Erdos personally sought Epstein's help in resolving a six hundred million dollar tax issue for redacted in December of 2008 after Bernie Madoff's investment scandal was uncovered Erdos wrote to Staley Glenn and I have been going back and forth all night we have hundreds of clients can you call JE to get the scoop from down there post exit JP Morgan continued to benefit from Epstein until months before his 2019 arrest Duffy then CEO of US PB gave Epstein former JP Morgan banker Justin Nelson permission to continue the relationship with Epstein as a potential source of referrals Nelson met with Epstein eight to ten times twice as many times as Casey who had been the main banker for a decade prior to the exit including about business with Leon Black CEO of private equity behemoth Apollo global management in 2019 a few months before Epstein was arrested JP Morgan was still taking referrals from Epstein to JP Morgan obstructed enforcement of the TVPA and violation of US code 18 section 1591D by 2007 JP Morgan knew of an effort to enforce the TVPA and intentionally obstruct or attempt to obstruct that enforcement effort order at 33 though Epstein confessed the conduct except the ages JP Morgan redacted and instead actively handled payments to Epstein's lawyers who it knew were discrediting the victims hiring private investigators to target witnesses and negotiating a deal where federal prosecutors would and did defer prosecution of TVPA charges further next section redacted JP Morgan redacted the payments to redacted and Maxwell and credit cards to redacted and redacted including for monthly travel through Paris Europe and the US Virgin Islands and the US and revoked a credit card to redacted who had talked to police the DDR information Epstein provided for redacted or any of the other girls Epstein referred to the bank the payments to the girls and women including with Eastern European names or their names and locations which it also had JP Morgan redacted and redacted that it helped Epstein financially back Brunel and MC's two since 2005 super part one in 2019 Brunel was charged with rape of miners and under investigation for trafficking tied to Epstein and was and was widely known including by JP Morgan years earlier as among the sleaziest people in the fashion industry a conveyor belt not a casting couch even when it knew that the feds that subpoenaed bear sterns for Epstein's account and transaction information related to its investigation redacted and redacted super one in 2010 JP Morgan learned of a new federal investigation of Epstein for child sex trafficking but redacted redacted redacted and redacted JP Morgan's own due diligence on Epstein shows it knew that names and contact information of material witnesses and additional victims would have been extremely useful in investigations and prosecuting the federal case JP Morgan had the names and information for dozens of accomplices victims and other material witnesses including for example his pilots his assistants and his accountants who JP Morgan later acknowledged controlled movement of Epstein's funds that potentially assisted in facilitating the sex trafficking as well as the long list of dignitaries and ultra wealthy men Epstein referred or connected to the bank redacted super part one by Epstein's arrest in 2006 there should have been a constant stream of information from JPMC to the FBI about Epstein's ongoing redacted human trafficking is an ongoing crime with harm incurred every day that the crime continues redacted and redacted there's no genuine dispute that Epstein would have been federally charged with sex trafficking much earlier three the US VIs requested relief for violations of the TVPA declaratory judgment and injunction the government requests that the court declare JP Morgan violated TVPA is section 1591 and to ND by participating in Epstein sex trafficking venture and obstructing federal law enforcement efforts to enforce the TVPA against Epstein from 2006 to 2019 the government seeks an injunction to prevent JP Morgan from participating in trafficking ventures in the future and obstructing efforts to stop such ventures in violation of the TVPA civil penalties the government has proven even greater participation by JP Morgan in Epstein sex trafficking than the NYS DFS found against Deutsche Bank and seeks at least 150 million in civil penalties other remedies the government defers its request for discouragement compensatory and punitive damages and other appropriate relief for JP Morgan's TVPA violations until trial part 4 JP Morgan's equitable and fault-shifting defenses do not apply to the government's TVPA parents patriarch claims this in an action by the government of the Virgin Islands to vindicate public rights while JP Morgan seeks to shift focus away from its own failings and point blame on the government such equitable or fault-shifting defenses are legally barred CEG city of New York verse FedEx ground package system incorporated 314 FRD 348 357 SDNY 2016 when acting in a capacity to enforce public rights and the public interest government entities are not subject to all equitable defenses such as latches or estoppel that could ordinarily be invoked against a private actor quoting state of New York verse UPS Incorporated 160 F dot SUPP 3D 629 640 SDNY 2016 at 3 59 contention that all government plaintiffs were negligent in their discretionary tax enforcement is impermissible where the government seeks to vindicate the public interest via enforcement of a public statutory right the court therefore should grant summary judgment for the government on JP Morgan's affirmative defense number five six unclean hands seven latches and eight comparative and contributory negligence or fault answer an affirmative defenses because they seek to do precisely what the law prohibits shift fault to the government plaintiff bringing suit to vindicate the public rights JP Morgan's attempts to distract from its violations of the TVPA described above by claiming that the government should have done more is particularly galling the government must comply with constitutional and legal principles that protect all individuals by ensuring that investigations cannot proceed without concrete evidence JP Morgan had that evidence in spades in its own files the government did not JP Morgan knowingly handled virtually every financial transaction Epstein needed to operate a sex trafficking venture from the millions in cash withdrawals and payments to co-conspirators recruiters and victims to the millions in payments to lawyers and publicists for the ongoing coverup JP Morgan had virtually every financial detail of Epstein's venture from payments to young women in Lithuania and Russia to transfers for the purchase of a helicopter by Maxwell to a revoked credit card for an alleged recruiter who talked to the police in real time and kept virtually all of it and thus its own outsized role under wraps until Epstein was dead and gone super part one it is Ryan Seacrest here there was a recent social media trend which consisted of flying on a plane with no music no movies no entertainment but a better trend would be going to Chumba casino calm it's like having a mini social casino in your pocket Chumba casino has over a hundred online casino style games all absolutely free it's the most fun you can have online and on a plane so grab your free welcome bonus now at Chumba casino calm sponsor by Chumba casino no purchase necessary VGW group void we're prohibited by law 18 plus terms and conditions apply the government cause of action against JP Morgan arise under the TV PA's parents patreon provision for state attorneys general which provides that where the attorney general of the state has reason to believe that an interest of the residents of that state has been threatened or adversely affected by any person who violates section 1591 the attorney general of the state as parents patreon may bring a civil action against such person on behalf of the residents of the state in an appropriate district court of the United States to obtain appropriate relief U.S. code 18 section 1595 D the TV PA makes clear that a state attorney general plaintiff brings suit not as a private litigant on behalf of itself but as parents patreon i.e. the sovereign on behalf of the residents of the state to obtain appropriate relief for an interest of those residents that has been or is threatened or adversely affected by JP Morgan's prohibited conduct in denying JP Morgan's motion to dismiss the court confirmed this plain reading of the TV PA the court found that the government satisfies the elements of parents patreon standing including that it alleges an injury to a quasi sovereign interest that affects a sufficiently substantial segment of its population order at 17 the court explained that the government asserted interest in protecting residents from the harmful effects of criminal sex trafficking enterprises flourishing in the islands directly parallels the interest that Puerto Rico successfully asserted in snap at 18 cleaned up having found that the government alleges a quasi sovereign interest and is vindicating public rights the court now should hold that JP Morgan's equitable and false shifting defenses do not apply as a matter of law the government's TV PA claims under section 1595 D is one exclusively pursued by state governments and not by private parties just as under the CCTA in FedEx and UPS the TV PA makes it clear by predicating a state's claim upon it showing that an interest of the residents of that state has been or is threatened or adversely affected by any person who violates section 1591 US code 18 section 1595 D the dismissal opinion makes it clear still that the government is acting in a public enforcement capacity by holding the government alleges an injury to a quasi sovereign interest and seeks relief to the territory's injury that would be unavailable to individual plaintiffs order at 18 since the government is enforcing the TV PA in its capacity as a sovereign not as a privately interested litigant JP Morgan's equitable and false shifting defenses are barred as a matter of law and discovery has not shown otherwise JP Morgan has generally cited three issues forming the basis of its false shifting affirmative defenses one Epstein's registration as a sex offender to the Virgin Islands economic Development Commission EDC's provision of tax benefits to Epstein's companies under a federally authorized tax benefit program and three actions taken by Cecile Dajang whom Epstein employed as explained below JP Morgan claims of a government-wide conspiracy to protect Epstein are both legally unsound and factually unsupported the defense based on these allegations cannot survive summary judgment a JP Morgan's defenses are barred as applied to sex offender registry issues JP Morgan argues that the government's purportedly improper enforcement of sex offender registry requirements with respect to Epstein supports its equitable and/or false shifting defenses this argument is without basis I the government's investigations or monitoring of Epstein cannot form the basis of viable affirmative defenses JP Morgan essentially argues that the government should have more aggressively investigated Epstein or monitored his whereabouts but that argument suffers from a fatal flaw even as the convicted sex offender Epstein possessed constitutional rights that the government was required to respect nothing however granted Epstein a constitutional right to conduct business with JP Morgan or to be free from JP Morgan scrutiny JP Morgan's attempts to equate its own compliance failures with the government's actions have no legal basis and thus amount a little more than a brazen attempt to distract from its own regulatory failings the officials within the Virgin Islands government responsible for sex offender registration and monitoring are not responsible for Epstein's crimes the laws required Epstein to register which he did and to provide notification of travel overseas but the government cannot enter his island or conduct searches without concrete evidence that crimes were being committed all witnesses confirm that the government never received such evidence JP Morgan has attempted to point news articles or complaints filed by anonymous victims in other states as evidence that the Virgin Islands government failed to pursue but those documents do not and cannot underpin a government investigation the government cannot search Epstein's property without a warrant which can only be issued upon probable cause newspaper reports are anonymous statements do not constitute sufficient basis for probable cause because mirror journalistic prose is not the kind of underlying factual data upon which a magistrate can exercise appropriate judgment Donovan versus said clearing die casting company 655 f.2d 793 797 7 circuit 1981 we need not be labor the point with all newspaper reports are not of sufficient reliability to form the basis of fourth amendment probable cause determination these cases are consistent with the undisputed witness testimony confirming that the Department of Justice could not initiate investigations or pursue warrants based upon these type of hearsay statements as witnesses confirmed absent and actual complaint from a victim or eyewitness evidence brought to the Department of Justice's attention the department cannot initiate investigations JP Morgan's complaints concerning the adequacy of address verification checks fair no better no provision in the law requires the Virgin Islands to perform such checks which are done to confirm that registrant resides at the address provided to the government the checks were performed roughly annually in conjunction with the US Marshals and other federal partners the applicable law required address checks to verify that an offender is living where they reported they do not however authorize entry into private property or dispense with the requirements of the fourth amendment the government officials may not enter a sex offenders property or conduct a search absent consent or a warrant based on probable cause that protection is the reason that in certain years the US Marshals and Virgin Islands officials did not proceed beyond Epstein's dock if an offender refused entry the government officials performing the check did not possess authorization to enter one virgin island witness testified that she conferred with the federal government concerning this practice and was told that it was similar to a situation where a landowner has placed a gate at the border to his property the officials were not permitted to proceed beyond that gate without a warrant nor was it improper or unusual for the government to confirm addresses at a sex offenders place of employment as was done one year with Epstein to the discretionary act of granting a waiver of notification periods for overseas travel is not grounds to shift fault to the government following his conviction in florida Epstein was required to register as a sex offender with the virgin island's department of justice in 2012 the legislature amended its sex offender laws in part to obtain federal funding for its sex offender unit the u.s government approved the changes to the law in advance JP Morgan is sought to make hay of the fact that Epstein's attorneys consulted with lawmakers concerning the proposed changes but those arguments prove nothing the legislature rejected Epstein's proposed changes the amended statute required that all sex offenders required to register in this jurisdiction shall appear in person at the department of justice at least 21 calendar days prior to any intended travel outside of the United States and provide information about their intended travel as provided the same provision then states that the attorney general may at his discretion reduce this 21 day notice requirement if a sex offender requests such a reduction and provides information in support of his request other statutory provisions confirm that nothing under this chapter shall be construed as a waiver of sovereign immunity for the united states virgin islands its departments and agencies Epstein applied for and received a discretionary waiver of his travel notification requirements pursuant to these statutory provisions but this waiver does not constitute misconduct or otherwise from the basis of a valid affirmative defense the provision of streamline travel notice requirements upon satisfactory proof is statutorily mandated and or vested in the attorney general's discretion case law is clear that such discretionary actions do not support shifting fault to the government the defense fails as a factual matter as well the statutory waiver of which JP Morgan complains applied only to international travel while the government had a policy in place to require notification of travel outside of the territory but within the united states nothing in the federally approved virgin island statute required such notification nor did this provision of such a waiver somehow enable Epstein's crimes testimony is clear that Epstein never failed to register as a sex offender and there is no evidence that he failed to notify of travel there is no evidence that permitting Epstein to email his international travel notifications 24 hours in advance instead of appearing in person 21 days in advance somehow enabled him more latitude to commit his crimes notifications or not authorizations or requests the government has no ability to restrict his travel moreover entry into the territory from overseas is controlled by federal authorities not the virgin island's government any attacks on the granting of the waiver itself are meritless then attorney general Frazier testified that he relied on representations of Epstein's counsel informing his decision and that those representations were satisfactory to conclude that there was not an undue risk to the community that would arise from the waiver Epstein's lawyers represented to mr. Frazier that other states permitted Epstein to provide email notification of his travels and affirm that there is no public safety necessity in requiring Epstein to notify the department in person each time he travels to and from the jurisdiction JP Morgan's defense thus rests not on whether the decision was authorized under law it most certainly was but on whether the attorney general in 2012 exercise sufficient discretion in granting the waiver this is precisely what case law cited above precludes government officials performing discretionary functions generally are shielded from liability or civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known be JP Morgan's defenses are barred as applied to the economic development commission grant of tax benefits to Epstein's companies the EDC operates under the umbrella of the us vi economic development authority which is a semi-autonomous instrumentality of the government and is governed by a board of individuals appointed by the governor virgin island code 29 section 1101 a the eda is a public corporation having legal existence and personality separate and apart from the government of the virgin islands and the officers controlling it thus to the extent JP Morgan conflates entities and treats edc actions as attributable to the government cmts opposition at two its arguments find no support in virgin island's law the tax benefits are authorized by a federal statute pursuant to which the edc administers a unique economic development program for the us vi allowing residents of the territory to exempt certain income if it's connected with the conduct of a trade or a business within the virgin islands the substance and procedures for the edc's provision of tax benefits are set by statute and regulation it's the policy and determination of the government of the virgin islands that certain industrial development benefits should be made available for development and expansion of such industrial or business activities as are determined pursuant to this sub-chapter to be in the public interest by advancing the growth development and or diversification of the economy of the territory of the virgin islands the factual record bears this out the edc granted incentives to two of Epstein's companies financial trust company and southern trust company the first grant of benefits to an Epstein owned company occurred 1999 to a financial trust in 2009 financial trust applied for and received an extension of benefits Epstein formed a new company southern trust which applied for and received tax benefits in 2012 in each of those cases the grant of benefits was performed in compliance with all statutory and regulatory procedures and requirements the company submitted applications for the benefits edc held public hearings during which the benefits were discussed and the applicants were provided the opportunity to present their case and answer questions the edc then held decision meetings where the board considered the applications and rendered decisions to the extent the jp morgan questions the reasoning behind those decisions that's precisely the type of second guessing the law precludes once benefits are granted virgin island law limits the edc's ability to modify them the commission may not require an applicant to meet qualifications or requirements in excess of those representations made by the applicant to the commission during the application process as a condition of granting an initial certificate indeed the law specifies that benefits granted are considered as being the nature of a contract between the government and the beneficiary the edc could not revoke suspend or modify the benefits based upon a felony conviction unless it concerned conduct connected with the operation of the beneficiaries business or industry thus Epstein's florida conviction was not grounds for a revocation at that time because no evidence was available to the edc that Epstein's solicitation of a minor for prostitution in florida was connected with the operation of his usvi businesses unlike jp morgan the edc did not have access to Epstein's companies daily financial transactions and was not aware of any connection between his conduct and the operation of his businesses how to have fun anytime anywhere step one go to chambeccasino.com chambeccasino.com got it step two collect your welcome bonus come to papa welcome bonus step three play hundreds of casino style games for free that's a lot of games all for free step four unleash your excitement chambeccasino has been delivering thrills for over a decade so claim your free welcome bonus now and live the chambe life visit chambeccasino.com indeed the edc reached out to Epstein's attorney in january of 2015 to inquire whether media reporting regarding allegations of misconduct had any connection to the business of Epstein's southern trust company his attorney responded to confirm we do not believe that these media discussions will have any impact on the business activities of stc jp morgan has pointed to a cost benefit ratio that purportedly shows in many years that the territory not the government received less than benefits than it gave up in tax revenue fact witness testimony however shows this analysis to be relevant because it uses an artificial baseline along tenured edc employee who was personally involved in the granting of benefits testified that the ratio doesn't give the full picture and can be misleading because unless the business already operated in the territory the government would not receive the tax revenue in the first place and has not lost anything the analysis applies to both the initial grants of benefits to both companies and to financial trust extension request during a march 2009 public hearing Epstein's attorney explained that a denial of an extension would likely cause a responsible business person to seriously consider relocating the business if another territory offered similar benefits thus the edc could not assume that it would collect Epstein's tax revenue if the benefits were not extended the ratio further ignores ancillary benefits that accrue to the territory from the presence of high net worth individuals who engage in economic activity unrelated to their business that benefits the territory see jp morgan has no viable defense based on activity of cecil disjong jp morgan also argues that the activity of cecil disjong former first lady of the u.s. virgin islands and office manager of Epstein supports its defenses as first lady mr disjong had no statutory or regulatory authority mr disjong confirmed that there's no office of the first lady with a budget and she did not have an office first lady was largely a ceremonial position that entailed giving speeches and attending social events moreover the factual record shows that during the time that her husband was governor mr disjong was widely known and recognized to be employed by Epstein's business and acting on their behalf unlike the information that jp morgan redacted disjong's employment with Epstein was widely reported and numerous witnesses confirmed that they were familiar with her employment most importantly mr disjong had no responsibility for governmental decisions that formed the basis of jp morgan's flawed affirmative defenses she had no contact with the department of justice personnel responsible for sex offender registration and monitoring decisions concerning tax benefits were made by the edc's board members although the law at the time required the governor her husband to sign tax benefits certificates that process was a formality and could not happen without the edc's recommendation in the first place mr disjong denied knowing about her facilitating Epstein's crimes in the virgin islands although jp morgan is pointed to emails about arranging an ESL class for women in the virgin islands mr disjong testified that she was not aware these individuals were potential trafficking victims and documents may clear that the university merely agreed to offer an existing class for them although mr disjong's emails may have provided salacious fodder for jp morgan she ultimately was not responsible for any government decisions conclusion for the foregoing reasons the court should grant the government's motion for partial summary judgment this was signed by aerial smith the attorney general and it was dated july 24th 2023 all right so that wraps this document up in its entirety and we'll just keep it moving and considering the amount of documents we still have to go through our journey has just begun all of the information that goes with this episode can be found in the description box it is ryan c crest here there was a recent social media trend which consisted of flying on a plane with no music no movies no entertainment but a better trend would be going to chumba 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Background and Legal Context:
- The USVI government argues that JPMorgan Chase had actual knowledge of Epstein’s illegal activities and continued to provide banking services to him, thereby facilitating his operations. The bank is accused of turning a blind eye to these activities due to the lucrative business Epstein brought to the institution.
Key Arguments:
- Knowledge and Facilitation: The memorandum emphasizes that JPMorgan Chase had ample evidence of Epstein’s illegal conduct through various suspicious transactions and internal communications. The USVI government contends that despite this knowledge, the bank continued its relationship with Epstein, making it complicit in his criminal activities.
- Financial Benefits: It is argued that JPMorgan Chase financially benefited from its relationship with Epstein, which provided significant fees and business opportunities. The USVI government claims that the bank prioritized profits over legal compliance and ethical considerations.
- Breach of Duty: The memorandum argues that JPMorgan Chase breached its duty to report suspicious activities as required under the Bank Secrecy Act (BSA). By failing to report Epstein’s suspicious transactions, the bank is accused of aiding and abetting his sex trafficking operations.
Legal Standards and Precedent:
- The USVI government supports its arguments by referencing relevant legal standards and case law that outline the responsibilities of financial institutions to report and prevent illegal activities, particularly when there is clear evidence of wrongdoing.
Request for Partial Summary Judgment:
- The USVI government is seeking a partial summary judgment, which would establish JPMorgan Chase’s liability for facilitating Epstein’s criminal enterprise without the need for a full trial. The government argues that the evidence is clear and overwhelming, and thus a trial is unnecessary to prove the bank's liability.
Conclusion:
- The memorandum concludes by urging the court to grant the motion for partial summary judgment, holding JPMorgan Chase liable for its role in enabling Epstein's illegal activities. The USVI government asserts that this judgment is essential to ensure accountability and to prevent similar situations in the future.